Embodied Carbon Obligations Under the New Sustainable Buildings SEPP

KPMG Origins Asset Impact helps organisations in meeting the new reporting obligations for embodied carbon under the NSW Sustainable Buildings SEPP.

What are the new embodied carbon requirements for projects in NSW?

From 1st October 2023, new development in New South Wales (NSW) is required to measure and report upfront carbon emissions as part of the development application and construction certificate process. With the aim to monitor the embodied carbon emissions of materials used in the construction of buildings, a new NSW Sustainable Buildings SEPP (State Environmental planning Policy) was issued in August 2022. The new SEPP is now in vigour and contains provisions for both residential and non-residential development.

The Embodied Emissions Reporting Technical Note outlines how materials and their embodied emissions will be measured and disclosed for both residential and non-residential development type.

Embodied carbon requirements for residential development

For residential development, the new SEPP requires that embodied emissions are measured and reported as part of the development approval.

Embodied carbon requirements for non-residential development

All non-residential development $5m and over, and refurbishments $10m and over are required to:

  • Describe the use of low-emission construction technologies in the development, such as reuse of materials and recycled content
  • Disclose at DA and update at CC quantities of key materials used and associated embodied emissions
  • Material quantities must be certified by a quantity surveyor, builder, designer or NABERS assessor

How can projects address these requirements?

Two reporting methodologies have been tailored to residential and non-residential development types:

  • For residential development the new BASIX Materials Index is integrated with the BASIX online tool to streamline measurement
  • For non-residential development the NABERS Embodied Emissions Tool will be the required format for reporting when the NABERS framework is released in mid-2024. In the interim, a NABERS Embodied Emissions Materials Form must be completed
KPMG Origins Asset Impact will ensure adherence to the NABERS framework when it is available, making sure that calculations are in line with NABERS requirements.

Where can I find technical guidance and supporting materials?

  • Sustainable Buildings SEPP, Section 3.2(2) – Embodied emissions quantified
  • Schedule 2 (35B) – Emissions reporting at DA
  • Schedule 1 (10A) – Emissions reporting at CC
  • NABERS Embodied Emissions Materials Form – As an interim pathway
  • Embodied Emissions Technical Note – Methodology for assessing the embodied emissions to satisfy Sustainable Buildings SEPP requirements
  • Planning Portal – Defines low emissions technologies including construction, pre fabrication, parametric design, electric construction vehicles.

How can KPMG Origins Asset Impact help meet embodied carbon obligations?

KPMG Origins Asset Impact is a market-led digital tool that enables new build and refurbishment projects to measure, track and report embodied emissions from materials with trust and transparency. 

Asset Impact was piloted in collaboration with the Office of the NSW Building Commissioner and School Infrastructure NSW. It is designed to support builders and developers achieve their net zero targets and embodied carbon obligations under the Sustainable Buildings SEPP.


Reach out to the KPMG Origins team for an Asset Impact demo.

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