Under the revised Energy Performance of Buildings Directive, the life-cycle global warming potential (GWP) of a new building must be calculated and disclosed on its energy performance certificate from 1 January 2028 for new buildings with a floor area over 1,000 m², and from 1 January 2030 for all new buildings. Member States must notify the Commission of a roadmap for national GWP limit values by 1 January 2027, with targets applying from 2030 (Directive (EU) 2024/1275, Article 7).
For developers and asset owners, the practical consequence is narrower than the dates suggest. A building completing in 2028 is being designed now. The carbon disclosed on its certificate is decided at concept stage, years before anyone requests the certificate.
The short version
| Date | What changes | Applies to |
|---|---|---|
| 1 January 2027 | Member States notify roadmaps for life-cycle GWP limit values | All EU Member States |
| 1 January 2028 | Life-cycle GWP disclosed on the energy performance certificate | New buildings over 1,000 m² useful floor area |
| 1 January 2030 | Same duty extends to all new buildings; first limit values in force | All new buildings |
- 1 January 2027 — Member States notify roadmaps for life-cycle GWP limit values, with targets from 2030 and a progressive downward trend.
- 1 January 2028 — life-cycle GWP disclosed on EPCs for new buildings over 1,000 m².
- 1 January 2030 — the same duty extends to all new buildings, and the first limit values must be in force.
- The method is EN 15978, the European standard for assessing the environmental performance of buildings — not a bespoke national metric.
- The Commission published Delegated Regulation (EU) 2026/52 on 4 May 2026, establishing the Union framework for the national calculation of life-cycle GWP; it entered into force on 24 May 2026.
- Disclosure is not the same as a limit. Disclosure starts in 2028; binding limit values arrive by 2030, and they ratchet downwards from there.
What exactly has to be disclosed?
The figure is the building’s greenhouse gas emissions across its whole life cycle. That covers production and transport of construction products, construction-site activity, energy used in operation, replacement of products during the building’s life, and finally demolition, waste management, reuse and recycling (European Commission, life-cycle GWP calculation framework, 2026).
In EN 15978 terms, this is the full modular picture — not upfront carbon alone. See what goes into the calculation, modules A to C. Materials are only one part, but for a new building they are the part that is already locked in by the time anyone measures. See embodied vs operational carbon for why that balance has shifted.
The number lands on the energy performance certificate. That is what makes this different from a voluntary assessment: the EPC is a document that follows the asset through sale, lease and financing.
Why does a 2028 deadline matter to a decision made in 2026?
Because the number is set long before it is reported.
A commercial building of any scale takes two to four years from concept to completion. A project starting design today and completing in 2028 or 2029 will be disclosing under the new regime. The structural system, the facade build-up and the decision to demolish or retain are all fixed in the first months of that timeline — and those are the decisions that determine most of the material carbon.
By the time a formal life-cycle assessment is commissioned, usually at detailed design or later, the expensive choices have been made. Changing them then means redesign, not substitution.
This is the gap pre-assessment material intelligence exists to close: an indicative, directionally reliable figure at concept stage, when the decision is still cheap.
What does this mean for a portfolio rather than a project?
Three things worth planning for.
Disclosure creates comparability. Once GWP sits on the EPC, buildings can be ranked on it. Whatever the regulation requires, the market will use the number — in valuation, in lending, in tenant selection. A poor figure will not be illegal in 2028. It will be visible, which for a saleable asset is often the more immediate problem.
Limit values are a hard gate, and they move. From 2030, Member States must have limit values in force, set with “a progressive downward trend” and differentiated by climatic zone and building typology (Directive (EU) 2024/1275, Article 7(5)). A specification that passes in 2030 is not guaranteed to pass in 2035. Designing to the current line is designing to be non-compliant later.
The reporting burden is per-asset, not per-portfolio. Every new building over 1,000 m² from 2028, then every new building from 2030. For an owner with a development pipeline, this is a recurring process, not a one-off exercise — which makes it worth systematising early rather than outsourcing each instance.
What are the national limit values going to be?
Nobody can tell you yet, and be sceptical of anyone who claims otherwise.
The roadmaps are due on 1 January 2027, and a roadmap does not have to fix a number — Member States may set limit values later in national regulation, provided the first ones are in force by 1 January 2030. Several countries already run national embodied-carbon regimes, and those will shape what they adopt, but the Union-level framework only sets how the calculation is done, not where each line falls.
The honest planning position: the method is knowable now, the threshold is not. That argues for building a baseline against EN 15978 today, so that when a number arrives you are measuring the gap rather than starting the measurement.
What should a developer or asset owner actually do before 2028?
Establish a baseline on live projects. You cannot manage a figure you have never calculated. An indicative assessment on current schemes tells you roughly where your portfolio sits against a limit that does not exist yet.
Move carbon into concept-stage decisions. The structural system is usually the largest single lever (CLT vs concrete vs steel), and on existing assets the demolish-or-retain decision dominates everything else (refurbishment vs demolition).
Check what your data is worth. A GWP figure is only as good as the material data behind it. Understand whether your numbers come from generic datasets like the ICE database or from product-specific EPDs, and where each is acceptable.
Distinguish estimate from assessment, in writing. An early-stage indicative figure supports a decision. It does not certify a building. Confusing the two in a board paper or an investor update is a governance risk, not just a technical one — see pre-assessment vs certified LCA.
Frequently asked questions
Does this apply to existing buildings? The Article 7 GWP disclosure duty applies to new buildings. Existing stock is addressed through other parts of the Directive, principally renovation and certification. But retention decisions on existing assets carry the largest carbon consequences of any choice available to an owner — see reuse vs new build.
Is the UK covered? No. The EPBD is EU law and does not apply post-Brexit. UK practice is shaped by voluntary frameworks and by client requirements rather than this directive, though the methodology and the direction of travel are broadly aligned.
Is disclosure the same as a carbon limit? No, and the difference matters commercially. From 2028 you must publish the number. From 2030 it must fall under a threshold. Two years separate embarrassment from non-compliance.
Which standard is used? EN 15978, the European standard for assessing the environmental performance of buildings, applied through the Union framework set out in Delegated Regulation (EU) 2026/52.
What if a Member State is late? Late transposition changes enforcement timing, not the direction. The 2030 date for all new buildings is in the Directive itself, and buildings designed today complete inside that window regardless.
Where this leaves you
The regulation converts embodied carbon from a voluntary commitment into a disclosed property of the asset. Nothing about that requires a new discipline — EN 15978 has existed for years, and the calculation is well understood. What changes is when you need the answer.
Elementa is built on Elementa’s seven building systems, on the EN 15978 module boundary for that reason: to give a defensible, indicative figure at the point where the design can still move, and to hand a clean baseline to whoever performs the certified assessment later.
Early figures are indicative and directional. They inform decisions; they do not replace a verified life-cycle assessment or an energy performance certificate.
Sources: Delegated Regulation (EU) 2026/52 (EUR-Lex); Directive (EU) 2024/1275 (EPBD recast), Article 7; European Commission — calculation framework for new building life-cycle GWP; Whole Life-Cycle GHG emission reporting for buildings (EU guidance). Dates verified August 2026; national limit values were not published at the time of writing.