Aligning the construction and real estate sector with climate neutrality goals is largely driven by the availability and transparency of operational and embodied carbon data across the industry. Recent EU regulations are poised to drive widespread adoption of whole life carbon assessment across the sector. These regulations are expected to drive data collection and analysis, enabling the creation of critical baseline values for buildings. In turn, this will help policymakers and industry leaders to pinpoint the source and scale of carbon emissions. By establishing benchmarks with progressively stricter targets, policymakers can steer the building sector toward near-zero emissions, offering clear guidance on how to reduce carbon emissions rapidly, significantly, and sustainably.

This report is intended to support European and national policymakers prepare for the implementation of regulations aimed at reducing the whole life carbon (WLC) impact of buildings. While the Energy Performance of Buildings Directive (EPBD) mandates that life cycle Global Warming Potential (GWP) measurement begin in 2028, a framework for assessment and a roadmap introducing limit values must be established and published by the end of 2027. Some leading European countries are moving ahead more quickly, having already regulated embodied carbon emissions prior to the 2024 revision of the Directive. In these markets, the first critical step was to develop a measurement methodology and use it to establish baselines for current building design. This report summarises the experiences of Czechia, Ireland, and Spain in taking these initial steps toward the consistent and effective implementation of WLC regulations.

The EU framework represents an opportunity to enhance transparency and consistency of methodologies among Member States, which could improve the comparability of WLC reporting and benchmarks. Transparency of WLC methods and assumptions is an essential step towards a more harmonised EU WLC approach. This is crucial because existing WLC assessment methods diverge in scope and assumptions, complicating comparisons. A proliferation of different WLC approaches in different Member States could lead to confusion and increased costs for the construction industry. At worst, it could lock in the divergence of national methodologies for an extended period.

Developing WLC methodologies and benchmarks in support of future limit values and targets is a gradual process, requiring EU Member States to overcome common challenges. This report provides valuable insights into the key features of WLC regulations, focusing on three European countries—other than the well-researched Nordic countries, France, and the Netherlands. It sets out initial baseline values based on common data collection and analysis templates, which will need to be regularly updated as data quality improves, EU-level requirements evolve, and further clarifications on WLC assessments are made.

Early quantitative results indicate that the product stage is the largest source of embodied carbon across all three countries and building types, highlighting that policymakers and industry should prioritise reducing upfront emissions for maximum impact. While these overall trends are consistent, specific values vary between countries due to differences in building practices, grid carbon intensity, assessment methodologies, and data sources. More granular and representative national benchmarks, as required by the recast EPBD, will provide a clear reference point for understanding national averages and identifying best practices in construction. These benchmarks will help determine which buildings and portfolios align with climate neutrality goals and guide the level of policy ambition needed. The goal of the INDICATE project is to contribute to establishing these initial benchmarks in countries where such efforts are still in early stages and to share the lessons learned across Europe.