New Regulatory Provisions Effective in 2028
For years, we have been working to design buildings that, on the one hand, generate little “gray energy” (CO2 emissions) and, on the other hand, remove CO2 from the atmosphere over the long term. This is the only way the construction industry can make a significant contribution to combating climate change.
1. Clear regulations instead of moral appeals
The assumption that investors would voluntarily prioritize CO₂ sinks over returns is unrealistic. The physical storage of CO₂ in buildings is technically feasible and scalable. Nevertheless, the real estate industry focuses on traditional metrics such as development margin, rental income, exit valuation, and IRR (internal rate of return) over a five- to ten-year period. The amount of stored CO₂ affects neither rent nor cap rates nor exit multiples, but instead entails additional costs and complexity. The typical holding period for real estate is usually shorter than the storage horizon. This is not a moral failure, but a structural problem: as long as stored CO₂ has no monetary value, it is not factored into investment decisions. Change can only be achieved through regulation—for example, through CO₂ pricing, verified storage, adapted building codes, or targeted subsidies.
2. Scientific Evidence: Three Studies, a Clear Picture
Three recent peer-reviewed studies provide the key facts:
The review article “How can carbon be stored in the built environment?” (Kuittinen et al., 2023) and the Nature study “Buildings as a global carbon sink” (Churkina et al., 2020) demonstrate: Biogenic building materials such as wood, straw, hemp, biochar, and carbonated concrete can store 109–300 kg of CO₂ per square meter. (Openly achieves approx. 250 kg per m² of gross floor area) The global potential is enormous and immediately scalable—a genuine alternative to underground storage.
The meta-study “Reviewing the 95 sociotechnical barriers to the decarbonization of buildings” (Heinz et al., Nature Communications 2025) analyzes 95 barriers worldwide. The result: Economic hurdles such as high initial investments, uncertain return on investment, and long payback periods dominate. Long-term co-benefits such as CO₂ storage are systematically ignored due to their short duration and lack of market value.
All three studies emphasize that without regulatory incentives—such as carbon pricing, incentives for verified long-term storage, new building codes, and targeted subsidies—carbon storage will remain a niche solution.
3. New Regulations Effective in 2028
Over the next few years, the EU will consistently implement regulatory measures to promote buildings as carbon sinks—exactly as investor logic dictates: By May 29, 2026, member states must transpose the revised Energy Performance of Buildings Directive (EPBD) into national law; Starting in 2028 (large new buildings) and 2030 (all new buildings), the calculation and disclosure of whole-life carbon emissions (including embodied carbon and CO₂ storage capacity) will be mandatory in energy performance certificates—and will be directly linked to the Carbon Removal Certification Framework (CRCF). Its methodology for “carbon storage in bio-based construction products” (wood, straw, biochar, etc.) is expected in 2026 (Q4) and will, for the first time, give certified long-term storage real market value. Carbon Standard International and Openly AG have been developing a standard for this since 2022 and have implemented it with myclimate (more information here). Live link to the public registry
The CO₂ pricing mechanism for buildings via ETS2 will take effect in 2028. ETS2 is the regulatory tool that, while it does not (yet) directly reward stored CO₂, finally imposes financial penalties on operational emissions from buildings—thereby breaking precisely the short-term return logic we have described. Starting in 2028, CO₂ will no longer be a “nice-to-have” on heating bills, but a hard cash flow factor.
4. Swiss Minergie Net Zero
With its announcement on March 12, 2026, a Swiss organization has for the first time confirmed that “stored carbon” can be factored into the overall carbon footprint of building construction. Since 2024, the amount of stored carbon has been reported for each building product in the KBOB list.
March 19, 2026 Dr. Christoph Neururer
For further reading: An overview of the most important studies (some require a subscription)
How can carbon be stored in the built environment? A review of potential options – Matti Kuittinen et al. (2023)
Buildings as a global carbon sink – Galina Churkina et al. (2020), Nature Sustainability
Reviewing the 95 sociotechnical barriers to the decarbonization of buildings – Erin Heinz, Benjamin K. Sovacool et al. (2025), Nature Communications
Net Zero Whitepaper – MIT Center for Real Estate (2022)
Towards a Zero-Emission and Resilient Real Estate Industry – MIT CRE (2022)
Accelerating Mass Timber in Greater Boston – F. W. Cerny (MIT Thesis 2025)