Whole Life Carbon, Net Zero and the 2028 Horizon: What New Projects Must Know

If you’re starting a building project this year, here’s the uncomfortable truth: you might be designing to rules that won’t apply by the time the building’s finished.

Over the next 3 years, the UK is heading for the biggest shift in carbon regulation we’ve ever seen in construction. Not one big change, but a series of updates in quick succession – each adding new demands on how we design, build, and operate.

Some changes will be written into law. Others will be driven by planners, funders, or clients. However they arrive, they’re going to reshape how projects get delivered.

The projects that handle this well will be those thinking ahead today. The ones that don’t risk delays, redesign costs, or ending up with an asset that’s already behind the curve on day one.

At TSA Riley, we call this the Carbon Curve, and it’s getting steep, fast.

The Road to 2028: Paved With Changing Carbon Rules

The headline change is Part Z of the UK Building Regulations – a proposal to make Whole Life Carbon (WLC) assessment mandatory for most new buildings, with embodied carbon limits to follow. We expect reporting requirements around 2026–27, and limits from 2028 onwards.

Part Z will set the requirement, and it’s widely expected that the RICS Whole Life Carbon Assessment Standard, which was updated in 2024, will be the recognised method for compliance. Using it now means you’re already working to the likely future rulebook.

Next year’s Future Homes and Buildings Standards will set the baseline for ‘zero-carbon ready’ buildings. The UK Net Zero Carbon Buildings Standard, due in full by late 2025, will go further by combining operational and embodied carbon limits. For larger projects and infrastructure, PAS (Publicly Available Specification) 2080 already provides a recognised framework for managing carbon across the whole lifecycle.

Local planning authorities are also implementing new policies. London, Greater Manchester, Bristol, and others already require WLC statements and operational energy modelling for major applications.

When you consider the growing demand for Scope 1-3 carbon reporting in both public and private sector projects, it’s clear these shifts aren’t isolated – they’re converging.

Why This Matters Now

By 2028, a single scheme could be expected to:

• Meet embodied carbon limits under Part Z.
• Hit Future Homes Standards operational performance targets.
• Provide a WLC statement for planning.
• Satisfy net zero benchmarks for investors or lenders.
• Report Scope 3 emissions across the supply chain.

The Upside of Getting Ahead

Planning for these changes now can make life easier later. It can smooth planning, reduce redesign risk, and open access to ESG-linked funding. It also puts projects in a stronger position for long-term value and marketability.

How We Approach it at TSA Riley

We start early, integrating carbon, cost, and delivery planning from day one:

It’s about making the right decisions early, so compliance with future standards is built in, and not added under pressure at the end.

Where Do You Sit on the Carbon Curve?

If you’re designing now, your project will be subject to the next wave of UK Building Regulations and could already need Whole Life Carbon evidence to secure planning.

If you’re breaking ground in 2026, expect mandatory WLC reporting.

If you’re completing from 2028 onwards, you’ll probably need to meet embodied carbon limits and net zero benchmarks.

Future-Proofing Starts Now

The next 3 years will redefine what ‘good’ looks like in UK construction. The winners will be those who anticipate the changes, not just react to them.

At TSA Riley, we’re already helping clients prepare for this shift – from piloting the UK Net Zero Carbon Buildings Standard, to delivering Whole Life Carbon Assessments across a variety of sectors in the UK and overseas, to running training and CPD (Continuing Professional Development) sessions that build in-house capability. We combine carbon expertise, cost intelligence, and programme delivery so Whole Life Carbon, net zero, and compliance are embedded from day one, not bolted on at the end.

If you’d like to further understand how these upcoming shifts could affect your developments and how a future-ready Whole Life Carbon Assessment can set you up for both compliance and market advantage, please contact Michael Samways, UK ESG Lead.