Home » Carbon budget plan – back on track or back to square one?

Carbon budget plan – back on track or back to square one?

Published: 12/11/2025

A new Carbon Budget and Growth Delivery Plan has been delivered by the government after months of speculation. At first glance, the plan appears to be a big step up from the previous iteration, which was deemed unlawful by the High Court.

However, closer inspection suggests there’s still room for improvement where whole life carbon reporting in new building work is concerned. BCIS executive director James Fiske assesses its potential.

Carbon budget plan – back on track or back to square one?

Decarbonisation progress in the built environment is at a sticking point.

The government has just published its new Carbon Budget and Growth Delivery Plan (CBGDP) and, while brimming with promising policies, there’s a frustrating lack of clear, immediate action on mandating whole life carbon reporting in new building work.

The built environment sector is more than capable of tracking and reducing whole life carbon in an accurate, meaningful way.

However, as outlined in AECOM’s impact assessment, professionals and businesses need the right tools, skills, methodology and data to make this happen, and full government buy-in is crucial.

For now, though, it’s on those in the sector to drive regulatory change from the bottom up.

Carbon budgeting without carbon reporting

There are a lot of plus points in the latest carbon budget plan.

Both the Future Homes Standard and the Future Buildings Standard have been confirmed for publication in the next few months, as has the Circular Economy Strategy – an initiative promising to reduce industrial waste, increase reuse, recycling and remanufacture efforts, and to encourage the uptake of low-carbon materials.

The government has also said it will investigate incentives for the use and lifetime extension of existing buildings and highlighted the need for further work to determine whether large-scale deployment of carbon-negative building materials, among other greenhouse gas removal (GGR) tech, is possible.

Speaking of which, there’s also a nod to ongoing policy development aimed at creating a resilient market for low-carbon industrial products too.

The policy framework in question includes focus on the steel, concrete and cement sectors and could standardise how producers measure, report and verify the embodied emissions of industrial products – supporting buyers to make greener purchasing decisions.

This is particularly welcome.

It is well known that carbon-intensive materials like cement and steel are responsible for a significant chunk of the built environment’s embodied emissions – partly because of how they’re made and partly because of how much they’re used.

This was reflected in a new international study(1) that has advocated for a ‘material revolution’ after concluding that, under a business-as-usual scenario, emissions generated by construction globally could more than double by 2050.

If successful, a policy framework that increases the transparency of high-quality carbon data on industrial construction products would be transformative for whole life carbon tracking in construction projects.

The only missing puzzle pieces are regulation that mandates the latter, and further investment in the right tools to support this (i.e. a national carbon dataset).

The CBGDP was a missed opportunity from the government to really get things moving in this regard.

On the one hand, whole life carbon assessments (WLCAs) do get a mention.

The government has confirmed its intention to encourage adoption of WLCAs and has recognised the role that reporting and standards play in the uptake of lower-carbon materials, resource-efficiency and embedding circular economy principles in the built environment.

But the CBGDP suggests the government will only begin promoting WLCA adoption from the fifth carbon budget – which starts in 2028.

If this timeline materialises, it could prove too little, too late in terms of meeting the net zero deadline.

It seems, in the near-term at least, building momentum behind better whole life carbon reporting rests on sector-level shoulders.

Leading the charge

A carbon mandate is expected and, while it’s not yet clear when it will land, those that prepare for its arrival will be best placed to hit the ground running – both in terms of compliance and gaining competitive advantages.

For most construction professionals, familiarity with carbon data, WLCAs and the RICS whole life carbon assessment standard(2) is important.

Improving how whole life carbon is tracked and reported, regardless of project scope or design, is a journey everyone in the sector should be part of.

However, when it comes to actively undertaking WLCAs, drawing meaningful results from them and using carbon data to benchmark and reduce a project’s footprint, there’s an obvious group of specialists for the job.

Quantity surveyors are already cost experts and, with a tool like BCIS Life Cycle Evaluator (which enables cost and carbon to be measured and reported simultaneously), they are well-placed to apply their skill set to carbon measurement.

AECOM’s impact assessment recommends that a clear definition of a competent carbon assessor be determined and that training is developed to upskill professionals in this area.

As a sector, the built environment is already making progress in this regard, but it’s still far from the widespread employment of a standardised approach to carbon reporting.

To bring this to fruition, businesses must recognise the value of surveyors as competent assessors and support their upskilling where required.

Familiarity with the RICS standard is a must and, together with exploring free resources such as the Built Environment Carbon Database (including how to use and submit data within the platform), can provide professionals with the basics of sound carbon measurement.

Ideally, professionals and businesses should be using these tools now, and from the outset of projects, to encourage change at a government level.

Better data sharing across the sector is also needed to develop what best in carbon practice looks like for different projects and to continue pushing carbon boundaries.

The hype around the promise to ‘decarbonise industry’ in the CBGDP wasn’t misplaced, but there was room for a bigger push on whole life carbon assessing at a project level.

Sometimes, you must be the horse that leads the way to water.

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BCIS Life Cycle Evaluator

BCIS’s Life Cycle Evaluator can be used to produce fully compliant whole life carbon assessments.

The tool enables users to understand the combined cost and carbon impact of projects and see where improvements can be made.

Find out more

(1) Nature – Carbon footprint of the construction sector is projected to double by 2050 globally – here

(2) RICS – Whole life carbon assessment (WLCA) for the built environment – here

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