For the first time, the revised Energy Performance of Buildings Directive (EPBD) introduces EU-wide requirements on the whole-life carbon impact of buildings. While this is a major step forward, questions remain around costs, complexity, and how these measures will work in practice. 

This report examines early experiences with whole-life carbon (WLC) assessments, drawing on evidence from the INDICATE LIFE countries and frontrunner markets. It shows that, in the absence of regulation, uptake is currently driven by voluntary initiatives such as certification schemes and corporate sustainability targets, leading to uneven progress across the sector. 

Importantly, the findings suggest that cost concerns may be overstated. While WLC assessments add some upfront cost, this remains a small share of total project budgets and is expected to decrease over time. Several examples show that low-carbon buildings can already be delivered at comparable, or even lower, cost when considered early in the design process. 

The report also highlights how WLC approaches help identify key sources of emissions and support better decision-making on materials, design, and construction. Beyond reducing carbon, this can deliver wider benefits, including innovation, resilience, and long-term value. 

The report concludes with practical policy recommendations to support the timely, ambitious, and workable implementation of whole-life carbon regulation across Europe. It also lists a selection of case studies and their learnings from the four INDICATE LIFE countries in its Annex.