From 1 January 2028, new buildings over 1,000 square metres must disclose their whole life carbon. The choices that set that number are being made now.
Every EU member state missed the 29 May 2026 deadline to put the recast Energy Performance of Buildings Directive into national law. On 15 July, the European Commission sent letters of formal notice to all 27. It gave them two months to respond.
The late paperwork does not move the dates in the directive. Public buildings must be zero-emission from 2028. All new buildings follow in 2030. There is a carbon test too. The whole life-cycle global warming potential of a building must be shown on its energy performance certificate. That means the carbon cost from materials to demolition. It starts on 1 January 2028 for new buildings over 1,000 square metres. It covers every new building from 1 January 2030.
From today, 2028 is 15 months away. A scheme at concept stage will be designed, bought and built inside that window.
The stock that is already standing
New builds are the smaller part of the problem. The Commission says around 40% of the energy used in the EU goes into buildings. It also says 85% of EU buildings were built before 2000, and 75% perform poorly.
So the existing estate is the main event for owners of offices, warehouses, shops and hotels. It is why Morson Praxis, a Manchester-headquartered building consultancy, starts with measurement. Its six-stage decarbonisation process opens with an estate assessment. Next comes a digital capture of the assets. Roadmaps, investment planning, delivery and optimisation follow. The firm applies it to retail, logistics, grocery, manufacturing and public sector estates.
A carbon plan built on guesses cannot be checked. Scan-to-BIM, mobile mapping and asset inspection give the model a measured start. They sit within the firm’s building consultancy services. These cover eight disciplines, from architecture and civil engineering to digital surveying and commercial risk.
What an early decision looks like
Two of the firm’s projects show the method. Both are UK schemes, so the directive does not govern them.
At IKEA’s Greenwich store, Morson Praxis was appointed for mechanical and electrical design at RIBA Stages 1 to 3. The contract was then novated to the contractor, Norstead, for Stages 4 and 5. A carbon target has to survive that change of hands. The store reached BREEAM Outstanding with a score of 90.4%. It has an 850 kWp solar array. Ground source heat pumps meet 88% of annual heating and cooling demand.
At the 280-room Hyatt Place London City East, the design followed the energy hierarchy of ‘be lean, be clean, be green’. Demand came down first. Two micro combined heat and power units and heat pump technology came after. The hotel achieved BREEAM Excellent and a sitewide carbon dioxide reduction of approximately 47.5%.
Both figures describe how the buildings run. Whole life carbon adds the materials and the build. That is why the firm’s net zero consultancy treats dynamic simulation modelling, sustainable materials, BREEAM and low carbon building services as one process. It does not write four separate reports.
What it means for owners
Owners of European property now work to two calendars. One belongs to national governments, which are still finishing the law. The other is fixed in the directive. It does not wait.
Any sustainability consultancy used to be asked how efficient a finished building would be. The question now is how much carbon the whole building will carry. And can anyone prove it?
