Sustainable Buildings Amendment
Carbon Reporting: A Guide for
Designers & Developers

Everything you need to know about NSW SEPP embodied carbon reporting requirements — from compliance pathways to how Nezo automates the entire process.

New South Wales, Australia Updated March 2026 Residential & Non-Residential

What is the Sustainable Buildings Environmental Plan (SEPP)?

New South Wales has introduced sustainability requirements for buildings through the Sustainable Buildings State Environmental Planning Policy (SEPP), administered by the NSW Government through the planning system. The policy requires developers, designers and consultants to measure and report the embodied carbon associated with construction materials used in certain new developments.

In Australia, construction activity and building materials contribute up to 24% of national greenhouse gas emissions. Addressing these emissions is essential if the sector is to meet national and global climate targets.

SEPP forms part of Australia's broader climate response and aligns with commitments under the Paris Agreement. By requiring carbon measurement within the planning process, SEPP represents an important step toward data-driven, lower-carbon construction.

Up to 24% of National Emissions Construction activity & building materials contribute significantly to Australia's greenhouse gas output.
Paris Agreement Aligned SEPP supports Australia's commitment to limit global warming to 1.5°C above pre-industrial levels.
Net-Zero by 2050 Pathway SEPP reporting is a critical step in Australia's roadmap to net-zero emissions across the built environment.
A1–A3 Cradle-to-Gate Focus Current reporting covers raw material extraction, manufacturing and transport to the manufacturing facility.

How Does SEPP Carbon Reporting Work?

There are two main compliance pathways under the NSW Sustainable Buildings SEPP, depending on whether a project is residential or non-residential.

NABERS Pathway

Non-Residential Projects

Offices, Retail, Hospitality, Schools, Hospitals & more

Non-residential projects follow the NABERS pathway. Material quantities are quantified and used to calculate embodied carbon for modules A1–A3. The assessment must be completed or verified by a NABERS Assessor, Quantity Surveyor, or suitably qualified design professional.

  1. 1Quantify key construction materials used in the project
  2. 2Measure embodied carbon for A1–A3 (cradle-to-gate)
  3. 3Enter quantities & emission factors into the NABERS Embodied Carbon Calculator
  4. 4Report verified by NABERS Assessor, QS or qualified professional
  5. 5Submit through NSW Planning Portal at DA and CC stages
DA CC CDC OC
BASIX Pathway

Residential Projects

Houses, Apartments, Duplexes, Major Renovations & more

Residential projects follow the simplified BASIX pathway. BASIX uses grouped material categories and standard emissions factors, reducing the amount of detailed reporting required. A compliance certificate is generated and lodged on the NSW Planning Portal.

  1. 1Quantify key structural and envelope materials
  2. 2Apply grouped material categories & standard emission factors
  3. 3Submit results through the BASIX online portal
  4. 4Receive BASIX compliance certificate
  5. 5Lodge certificate on NSW Planning Portal at DA, CC, CDC and OC stages
DA CC CDC OC
Project Thresholds: Embodied carbon reporting applies to non-residential new builds above $5M and major renovations above $10M. For residential projects, all new builds are captured, along with major renovations above $50K.
NABERS Logo Green Star Logo

When, Who & How Does It Impact Construction Design?

Embodied carbon reporting was formally introduced through SEPP in 2024. In March 2026, the NSW Department of Planning released an Embodied Carbon Technical Note, signalling that mandatory reporting is now imminent. Here's how the timeline looks:

2022

SEPP Sustainable Buildings Amendment Enacted

NSW Government introduces the Sustainable Buildings State Environmental Planning Policy, establishing the legislative framework for embodied carbon reporting.

2024

Formal Introduction of Reporting Requirements

Embodied carbon reporting formally introduced through SEPP. Absence of a detailed delivery framework delayed practical implementation within the planning approval process.

March 2026

Embodied Carbon Technical Note Released

NSW Department of Planning, Housing and Infrastructure releases critical guidance on how embodied carbon measurement and reporting will operate within the planning system. The operational framework is now largely in place.

Near Term

Mandatory Reporting Activation

Mandatory reporting requirements are likely to be formally activated for both residential and non-residential new buildings, as well as major building modifications. Submissions must now also identify decisions that demonstrate consideration of lower-carbon materials.

~2028–2029

Potential Introduction of Carbon Caps

With a 3-year review cycle, the policy direction points toward full life-cycle carbon assessment and performance thresholds — potentially introducing carbon caps for new buildings.

The implications are significant across the construction sector. Who will be affected?

Architects
Engineers
Quantity Surveyors
Sustainability Consultants
Developers
Planning Authorities

What Are the Common Reporting Pain Points?

In simple terms, the challenge comes down to Time and Data. Here's where teams experience the most friction when completing embodied carbon reporting:

Time Pressure in Design Teams

Design teams operate under tight deadlines and fee pressures. Introducing carbon reporting means finding time to locate, interpret and apply complex environmental data — often while the programme is already under pressure.

Carbon Data Is Difficult to Use

Carbon data is frequently buried inside EPD PDFs, stored across large databases, presented in inconsistent formats, and disconnected from other design metrics like cost and weight. This fragmentation makes meaningful comparison difficult.

The Early Design Gap

Research suggests 60–80% of a project's carbon and cost outcomes are locked in during early design, yet most carbon reporting workflows are structured for compliance later in the project — measuring rather than influencing outcomes.

Death by Spreadsheet

In practice, the reporting process often becomes highly manual. Teams spend significant time preparing material quantities, matching materials to emission factors, and formatting results into compliance reports — a labour-intensive, error-prone process.

Knowledge Bottleneck

Carbon reporting expertise often becomes concentrated in one or two specialists. Training on current market tools can exceed 50 hours, with continual use needed to maintain knowledge. If that person leaves, internal capability quickly disappears.

What the Industry Needs

The industry needs clean, structured carbon data integrated directly into design workflows — connected with cost and material quantities — so designers understand the consequences of their decisions immediately. Carbon reporting must be democratised.

How Nezo Supports Carbon Compliance Reporting & Better Outcomes

Nezo is built specifically for the design environment, enabling architects and engineers to measure cost, carbon, and material performance directly inside their modelling process. Rather than adding another reporting task, Nezo automates the heavy lifting and turns performance data into a real-time design tool.

Automated Material Quantification

Nezo connects directly to Revit, Archicad and SketchUp, automatically generating detailed schedules of material quantities from your design model. Eliminates delays waiting for manual quantity take-offs — from concept geometry onwards.

Real-Time Performance Insights

Once your design is synchronised, Nezo instantly connects material quantities to verified performance datasets — showing embodied carbon performance, construction cost impacts and material weight implications simultaneously.

Rapid Design Optimisation

Instantly compare material substitutions, evaluate alternative structural or façade strategies, and identify opportunities to reduce cost and carbon simultaneously — all without redesigning the project multiple times.

Automated Compliance Reporting

Nezo automatically generates compliance outputs for NABERS Embodied Carbon and Green Star Carbon Reporting frameworks, drastically reducing the manual burden of preparing documentation for planning approvals.

Frequently Asked Questions

Key questions about SEPP embodied carbon reporting requirements answered.

Embodied carbon reporting applies to:

  • Non-residential new builds above $5M (offices, retail, education, public buildings)
  • Non-residential major renovations above $10M
  • All new residential builds (houses, apartments, duplexes)
  • Residential major renovations above $50K

The current reporting framework focuses on A1–A3 embodied carbon emissions, commonly referred to as "cradle-to-gate" carbon measurement. This covers:

  • Raw material extraction
  • Manufacturing processes
  • Transport of materials to the manufacturing facility

The reporting framework focuses on key structural and envelope materials that typically drive the majority of embodied carbon in buildings, including:

  • Foundations
  • Frame
  • Envelope
  • Floor & Wall Finishes

Embodied carbon reports generally need to be prepared or verified by a qualified professional, such as:

  • NABERS Accredited Assessors
  • Quantity Surveyors
  • Sustainability / ESD Consultants
  • Suitably qualified designers

Yes. The Embodied Carbon Technical Note (March 2026) indicates that submissions should not only report carbon quantities but also identify design or specification decisions that demonstrate consideration of lower-carbon materials or construction methods. This marks an early shift from carbon accounting toward active decarbonisation.

If the required reporting is missing or if the constructed materials significantly differ from the approved submission, planning authorities may require:

  • Design revisions
  • Updated reporting
  • Additional review before approval can proceed

Ready to Simplify Your Carbon Reporting?

Nezo automates material quantification, carbon analysis and compliance reporting — so your team can focus on designing better buildings.