The short answer is no. EPCs focus on predicted energy use, specifically regulated loads like heating and lighting, based on standardised assumptions. They do not reflect how buildings actually perform once occupied, nor do they account for the carbon locked into materials and construction processes. This narrow scope can lead to a misleading sense of sustainability, where a high EPC rating masks a high whole life carbon footprint.

For clients aiming to meet net zero targets, satisfy ESG criteria, or attract green finance, EPCs alone fall short. A building with an EPC A rating could still have significant embodied carbon or operational inefficiencies. As investor expectations evolve and planning policies begin to mandate whole life carbon reporting, the need for a more holistic approach is clear.

So what does a carbon smart strategy look like?

• Combining EPC targets with real-world performance data: Operational energy modelling (a process that predicts real-world energy consumption), and post occupancy evaluations help bridge the gap between design intent and actual energy use. This not only improves accuracy but builds trust with stakeholders.
• Early assessment of embodied carbon: Life Cycle Assessment tools such as One Click LCA or eTool should be used from RIBA Stage 2 onwards to influence key design decisions including structure, façade, finishes, and services. These choices have long term carbon implications and should be made with full visibility.
• Embrace whole life carbon thinking: Rather than optimising operational or embodied carbon in isolation, we need to balance both. For example, adding insulation may reduce energy use but increase material intensity. Trade-offs must be understood and justified.
• Align with stakeholder expectations: Investors, occupiers, and planners increasingly demand transparency and accountability. Frameworks like LETI, RIBA 2030, BREEAM, and UK Net Zero Building Standard provide guidance, but it is up to project teams to deliver meaningful and transparent outcomes.

What does good look like? 

It is not just about ticking the EPC box. A truly high-performing building combines a strong EPC rating with low embodied carbon, backed by a clear whole life carbon strategy. It is designed to be adaptable, resilient, and ready for the future. Delivering environmental value without compromising commercial performance.

From compliance to leadership

EPCs may be the starting point, but they are no longer the destination. Forward thinking clients are embracing carbon smart strategies that go beyond minimum standards. By integrating sustainability, energy, and design expertise early, they are creating buildings that stand out for the right reasons.

The opportunity is now

In today’s shifting regulatory and market landscape, the buildings that thrive will be those defined by transparency, collaboration, and genuine climate ambition. A high-performing building is no longer just about efficiency and compliance, but about delivering long-term value through responsible design, construction and operation. Taking a carbon-smart approach is not only better for the planet, but also a smarter way to build, invest and lead.

Further information

Contact Taby Halliwell

Embodied carbon in infrastructure - the missing link