Roadmap WLC-GWP: phased introduction of CO2 requirements for buildings

The Dutch Ministry of the Interior and Kingdom Relations (BZK) has announced a roadmap for the introduction of WLC-GWP (Whole Life Cycle Global Warming Potential), the new European method for calculating a building's greenhouse gas emissions across its entire life cycle.

What is WLC-GWP?

The European directive on the energy performance of buildings (EPBD IV) introduces WLC-GWP as a method to provide insight into the greenhouse gas emissions of buildings, from the extraction and production of raw materials to demolition and processing of materials. Both the emissions from the building's energy use during the use phase (including any energy fed back into the grid) and the emissions from the material-related greenhouse gas emissions of construction products and installations are taken into account.

Phased introduction

The roadmap will be shared with the House of Representatives this autumn and must be submitted to the European Commission by 1 January 2027 at the latest. It shows how, through requirements and target values, the greenhouse gas emissions of new buildings will be reduced to climate neutral by 2050. This will be followed by amendments to the Environment and Planning Regulation and the Buildings and Living Environment Decree, with an internet consultation starting in early 2027.

From 2028, a calculation obligation will apply, initially covering only new buildings larger than 1,000 m². The results of the calculation must be included on the energy label.

From 2030, the calculation obligation will apply to all new buildings, and limit values will also apply to all new buildings.

Role of Stichting NMD

In October 2025, Stichting NMD published the WLC-GWP Assessment Method version 0.9. This version was not yet final, but was published with the aim of making the method accessible to parties involved in the process for the WLC-GWP Roadmap.

At the end of October 2026, the public consultation is scheduled for an interim version 0.95, which takes into account possible adjustments based on ongoing policy-level decision-making.

Version 1.0 of the WLC-GWP Assessment Method is scheduled for publication at the beginning of November. This version will be designated, through the legislative process, as the version in force for calculating WLC-GWP.

The validation round for calculation tools will start after that. WLC-GWP is, for the time being, an optional calculation method: calculation tool owners are not obliged to implement it in their calculation tool. However, from 2028 a legal requirement will apply to submit a WLC-GWP calculation for permit applications for buildings larger than 1,000 m².

Environmental Performance of Buildings

The current requirement for the Environmental Performance of Buildings (EPB) will remain in force until at least 2030. Nothing changes for EPB calculations.

Validated calculation tools

Following the publication of version 1.0 in November, the calculation tools can proceed with implementation and Stichting NMD will start the validation process for the calculation tools. Once the validation round has been completed, only calculation tools that have successfully completed this process will be permitted to offer calculations in accordance with the WLC-GWP Assessment Method. Validation is not yet possible at this time. A number of calculation tool owners have already, in anticipation of this, developed a calculation tool based on draft version 0.9.

Those who are already calculating are advised to take into account that the results cannot yet be regarded as definitive. Calculations based on the draft version can therefore not yet be used to draw policy-relevant conclusions.