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The London Plan 2021

The London Plan 2021: Whole Life-Cycle Carbon Assessments (Policy SI 2)

Onye Dike
Written by Onye Dike
Updated on February 14th, 2026

Summary

The London Plan requires referable planning applications (those that must be referred to the Mayor/GLA as “potential strategic importance”) to submit a Whole Life-Cycle Carbon (WLC) Assessment. The assessment quantifies embodied + operational carbon across the building life cycle and explains measures taken to reduce emissions. The detailed “how-to” and submission process is set out in the Mayor’s Whole Life-Cycle Carbon Assessments London Plan Guidance and its Excel template.

Details

Jurisdictions
  • London
Mandatory for

Developers / planning applicants whose schemes are referable to the Mayor (i.e., must be referred to the GLA under the Mayor of London Order 2008 categories).

Deep dive

2 min read
Updated Feb 14, 2026

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Introduction

Policy SI 2F aims to reduce the built environment’s climate impact by requiring major, strategically significant schemes to quantify and manage whole life-cycle carbon emissions—not just regulated operational energy. The Mayor’s Guidance explains the assessment approach, recommended methodologies, and how results should be reported to the GLA using an Excel template.

What the policy asks

For referable developments, companies must prepare and submit a WLC Assessment that:

  • Calculates whole life-cycle carbon emissions (covering embodied + operational emissions and relevant life-cycle modules).

  • Demonstrates actions taken (and planned) to reduce life-cycle emissions.

  • Uses the Mayor’s WLC template and provides key details such as the software used and the type of EPDs used, among other information.

When documentation must be submitted

The Guidance states that, for referable applications, the WLC Assessment should be submitted at these stages:

  • Pre-application (where relevant): applicants are encouraged to carry out early carbon assessment work before the formal planning application, especially for major schemes.

  • Planning application submission (typically RIBA Stage 2/3): applicants submit the appropriate tab of the WLC template as part of the planning application.

  • Post-construction: applicants submit the post-construction tab to the GLA prior to occupation, generally expected around three months after construction, alongside supporting evidence.

Status & Outlook

The London Plan 2021 is in force. Updates to the WLC guidance are being considered to reflect methodological developments (such as newer RICS standards) and to improve clarity and usability of reporting templates. This suggests the policy’s reporting framework will be refined over time as industry standards evolve and data availability improves. In practice, the policy continues to influence building design, material specification, and planning evidence for referable developments in London, and borough planning authorities are also encouraged to secure post-construction WLC submissions through planning conditions or legal agreements where relevant.

Resources


Onye Dike
Added by:
Onye Dike
Sustainability Research Analyst
Onye Dike is a Sustainability Research Analyst at Net Zero Compare, where he contributes to research and analysis on environmental regulations, carbon accounting, and emerging sustainability trends.
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Added on Jan 12, 2026 by Onye Dike · Updated on Feb 14, 2026