Required by contract
National Highways: a PAS 2080-verified system for large and medium suppliers.
A condition of the work.Construction · carbon management
PAS 2080
PAS 2080:2023 is BSI’s specification for managing whole life carbon in buildings and infrastructure, free to download and voluntary.
It sets requirements for asset owners, designers, constructors and suppliers, and it is a management process, not a way of calculating carbon.
It binds a company only when a client asks for it, as National Highways does of its larger suppliers.
What it is
What is PAS 2080?
A publicly available specification for managing whole life carbon, in effect since 31 March 2023.
It covers the provision, operation, use and end of life of new projects and the management and retrofit of existing assets and networks (Clause 1).
| Question | Answer | Source |
|---|---|---|
| Who publishes it? | BSI; commissioned by the Green Construction Board under the Construction Leadership Council | Front matter |
| What does it cost? | Nothing: ICE and the Green Construction Board sponsored it | BSI Knowledge |
| Which edition is current? | PAS 2080:2023; the 2016 edition is withdrawn | BSI |
| Is it a calculation method? | No; it points to existing life-cycle standards | Clause 7.1.3 |
| Is it a British Standard or law? | Neither; it is a specification parties choose or are contracted to follow | BSI |
PAS 2080 calls construction-stage emissions “capital carbon”, which is not the same boundary as RICS’s embodied carbon; the boundaries are on embodied carbon.
Status
Is PAS 2080 mandatory?
No. It binds through contracts and regulators’ expectations, never through law.
Ofwat calls PAS 2080 a voluntary standard (Ofwat), and no UK law requires whole life carbon assessment (HC 1785).
The Construction Playbook’s guidance warns that making accreditation to a particular standard a tender condition “is likely not to be justifiable under the procurement regulations” (¶3.6.3).
That guidance pre-dates the Procurement Act 2023, and whether the Act changes the analysis is not recorded here.
How a client treats PAS 2080
Expected by a regulator
Ofwat “expects” frameworks such as PAS 2080; Ofgem names it as an example.
Expectations, not licence conditions.Given as an example
The Construction Playbook: “whole life carbon assessment tools e.g. PAS 2080”.
Comply or explain, for central government.The four roles
What does PAS 2080 ask of each role?
The asset owner sets the targets; everyone manages, assesses and reports against them.
Every member needs a carbon management policy and strategy with clear roles, and training to fill skills gaps (Clause 5.1).
PAS 2080 sets no numerical target of its own; the targets are the asset owner’s.
Government, regulators and financiers get guidance in Annex C, not requirements (Clause 1).
Value chainExplore
Value chain
Asset owner or manager
Primary responsibility; time-bound targets aligned to net zero, baselines, and published performance against them.
Value chain
Designer
Adopts the owner’s targets as a minimum and applies the hierarchy to options.
Value chain
Product or material supplier
Assesses with a recognised method and shares targets along the chain.
One contractor
What does this mean for one contractor?
A medium-sized contractor working for National Highways needs a verified PAS 2080 system and reports against National Highways’ targets.
It is an illustration, not a real company.
The same contractor building offices for a private client owes nothing under PAS 2080 unless that client asks.
National Highways’ deadline was the end of 2025, and what happened to suppliers who missed it is not recorded here.
- 1
Must it conform?
Only because its client asks: National Highways wants a PAS 2080-verified system from large and medium suppliers (NH 2025 update).
- 2
In which role?
As a constructor, and as a designer too if it designs (Clause 1).
- 3
Whose targets?
National Highways’ as the asset owner, adopted as a minimum and shared down the chain (8.1.1).
- 4
What does it report?
Whole life carbon at each work stage, and progress against the targets (9.1).
- 5
How does it claim it?
Third-party certification, the basis that matches “verified” (12.2.2).
The hierarchy
What is the PAS 2080 carbon reduction hierarchy?
Avoid, switch, improve, applied in that order to capital, operational and user emissions.
PAS 2080 notes that the greatest ability to cut whole life carbon is at the “need” stage, before design begins (Clause 4.3 NOTE 2).
The 2023 edition calls its three steps a simplified version of the 2016 hierarchy; the 2016 wording is not quoted here.
- 1 · Avoid
Test the need
Align the outcome with the net zero transition, and question the basic need for the asset. - 2 · Switch
Choose a lower-carbon solution
Alternative scope, design, materials or technology that cuts whole life emissions. - 3 · Improve
Use resources better
Longer design life, reuse and recycling, circular economy principles.
Claiming it
How does a company claim conformity with PAS 2080?
On one of three bases, in the wording Clause 12 sets, naming the role and the scope.
| Basis | Who assesses | What PAS 2080 says |
|---|---|---|
| Third-party certification | A certification body accredited to certify to the PAS | “Independently verified”; the basis for asset owners seeking it (12.2.2) |
| Other-party validation | A body without accreditation, such as a trade body or a consultant | Permitted, and named as such in the claim (12.2.3) |
| Self-validation | The organisation itself, with supporting documents published | Permitted; stakeholders “might have less confidence” (12.2.4) |
Each claim states its basis, its scope (organisation, programme or project) and the clauses claimed, in a set form such as “… implemented as constructor by … in accordance with PAS 2080, … certified”.
“Aligned with PAS 2080” in a bid is not a claim of conformity.
Your gaps
What is your company still missing?
Pick your role, tick what you have, and the gaps come back in clause order.
The list summarises named clauses; the PAS itself is the text to conform to, and it is free from BSI.
A company in two roles, designer and constructor say, runs the check once for each.
PAS 2080 · what is still missing?
Pick a role. Each value chain member claims conformity in the role it declares.
A working summary of PAS 2080:2023 Clauses 4.3, 5, 7.1.3, 8, 9, 10.1.1 and 12; the PAS itself is a free download from BSI and is the text to conform to.
Nothing you enter leaves your browser.
Methods
How does PAS 2080 relate to EN 15978, EN 17472 and RICS?
PAS 2080 manages the process; those standards do the counting.
PAS 2080 has no normative references: it requires “appropriate GHG assessment methodologies” and names these standards as ones that “could be used” (Clause 7.1.3).
Its bibliography lists BS EN 15978:2011, now withdrawn; conformity does not break, but an assessor would now pick the 2026 edition.
Ofwat’s capital carbon commitments use modules A1–A5 of BS EN 17472 (Severn Trent PC).
The method familyExplore
The method family
BS EN 15978:2026
Buildings; replaced the 2011 edition PAS 2080 lists on 31 July 2026.
The method family
RICS 2nd edition
Embodied carbon includes B1–B5 by definition; PAS 2080’s capital carbon makes maintenance optional.
Order of work
Where should a company start with PAS 2080?
Read the client’s requirement, then build the policy, the method and the reporting before choosing a claim.
A contractor that also sets company-wide targets can align them with the Science Based Targets initiative, which National Highways also asks for.
PAS 2080 is not PAS 2060, the carbon neutrality specification covered on PAS 2060 and ISO 14068.
- 1
Read what the client asks for
Verified, certified, aligned: the words decide the claim basis.
- 2
Download the PAS
Free from BSI; the 2023 edition.
- 3
Set policy, roles and training
Clause 5.1 applies to every role.
- 4
Fix the assessment method
BS EN 15978:2026 or EN 17472, the same for every option.
- 5
Report each work stage, then claim
Choose certification, validation or self-validation.
PAS 2080 is free and voluntary until a client writes it into the contract, and then the claim has to be made in its own words.
- 31 March 2023
PAS 2080:2023 is the current edition, and it is free
Sponsored by ICE and the Green Construction Board. - Four roles
Owners, designers, constructors and suppliers each claim in their own role
The asset owner leads. - Avoid · switch · improve
The hierarchy runs in that order
The earliest decision carries the most carbon. - Three bases
A claim is certified, validated or self-validated, in set words
“Aligned with PAS 2080” is not a claim of conformity. - No UK law
PAS 2080 binds only through contracts and regulators’ expectations
National Highways is the clearest case.
Which clients and regulators point to PAS 2080?
National Highways requires it; Ofwat, Ofgem and the Cabinet Office name it.
The Infrastructure and Projects Authority’s 2021 roadmap, sometimes cited for PAS 2080, does not mention it.
No source found records the Environment Agency requiring PAS 2080 of its suppliers, so it is not listed.
Who points to itExplore
Who points to it
National Highways
Requires a verified system from large and medium suppliers; holds PAS 2080:2023 certification itself.
Who points to it
Ofgem
Embodied carbon reporting aligned with industry standards, PAS 2080 the example.
Who points to it
Cabinet Office
An example of a whole life carbon assessment tool.
Frequently asked
What else do people ask about PAS 2080?
What is PAS 2080?
PAS 2080:2023 is a publicly available specification from BSI for managing whole life carbon in buildings and infrastructure, from new projects to the management and retrofit of existing assets.
It came into effect on 31 March 2023 and replaced the 2016 edition, which covered infrastructure only.
Is PAS 2080 mandatory?
No. It is a voluntary specification, not law.
It becomes a requirement only when a client makes it one: National Highways, for example, asks its large and medium suppliers for a PAS 2080-verified carbon management system.
Is PAS 2080 free?
Yes.
BSI says the Institution of Civil Engineers and the Green Construction Board sponsored it, so it can be downloaded free of charge.
Who does PAS 2080 apply to?
Four value chain roles: asset owners and managers, designers, constructors and product or material suppliers.
Asset owners and managers carry the primary responsibility.
Government, regulators and financiers get guidance in Annex C but no requirements.
What is the PAS 2080 carbon reduction hierarchy?
Avoid, switch, improve, in that order.
Avoid means testing the need for the asset against the net zero transition; switch means adopting lower-carbon alternatives; improve means using resources better, including reuse and recycling.
The 2023 edition calls this a simplified version of the 2016 hierarchy.
How do you get PAS 2080 certification?
Clause 12 allows three bases for a claim: independent third-party certification by an accredited body, validation by another party, or self-validation, each with set wording.
BSI sells a PAS 2080 conformity certification service.
Whether any body holds UKAS accreditation for it is not recorded here.
What is the difference between PAS 2080 and PAS 2060?
PAS 2080 is about managing whole life carbon in buildings and infrastructure.
PAS 2060 was about claims of carbon neutrality.
BSI’s own page puts it the same way.
Does PAS 2080 tell you how to calculate carbon?
No. It has no normative references and requires a recognised life-cycle method, naming BS EN 15978, BS EN 17472 and BS EN 15804 as standards that could be used. It is a management process.
Sources
Where does each figure come from?
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 16 sources fromBSINational HighwaysOfwatOfgemCabinet OfficeRICS
- BSIPAS 2080:2023 Carbon management in buildings and infrastructure (PDF)
Clauses 1, 3, 4.3, 5, 7.1.3, 8, 9, 10.1.1 and 12; effective 31 March 2023.
- BSIPAS 2080:2023 on BSI Knowledge
Sponsored by ICE and the Green Construction Board, so free of charge.
- BSIPAS 2080 publication history
PAS 2080:2023 supersedes and withdraws the 2016 edition.
- BSIPress release: update of PAS 2080 (5 April 2023)
Developed with ICE and the Green Construction Board.
- BSIPAS 2080 Conformity certification
BSI’s own certification service; not described as a Kitemark.
- National HighwaysNet zero highways plan: 2025 update
Large and medium suppliers: a PAS 2080-verified carbon management system by the end of 2025, and SBTi-aligned targets.
- National HighwaysCarbon
National Highways holds PAS 2080 certification itself.
- OfwatFinal Climate Change Principles (February 2026)
Expects frameworks such as PAS 2080; calls it a voluntary standard.
- OfwatPR24 performance commitment: Severn Trent capital carbon
Capital carbon on modules A1–A5 of BS EN 17472:2022.
- OfgemRIIO-3 guidance: Environmental Reporting Guidance
Embodied carbon aligned with industry standards, PAS 2080 the example.
- Cabinet OfficeThe Construction Playbook (September 2022), endnote 15
“Whole life carbon assessment tools e.g. PAS 2080.”
- Cabinet OfficePromoting Net Zero Carbon and Sustainability in Construction: Guidance Note
¶3.6.3: requiring bidders to be accredited to a standard is likely not justifiable.
- BSIBS EN 15978:2026
The building life-cycle method; the 2011 edition PAS 2080 lists was withdrawn on 31 July 2026.
- BSIBS EN 17472:2022
The life-cycle method for civil engineering works.
- RICSWhole life carbon assessment for the built environment, 2nd edition
Embodied carbon by module, which differs from PAS 2080’s capital carbon.
- House of Commons Environmental Audit CommitteeGovernment Response, HC 1785 (March 2026)
No mandate for whole life carbon assessment at this time.
Continue reading
Where to go next
Guide
Embodied carbon
The module boundaries, the methods and who asks for figures.
Guide
PAS 2060 and ISO 14068
Carbon neutrality claims, a different specification.
Guide
Carbon reduction plans (PPN 006)
The company-level plan central government bidders publish.
Guide
Science Based Targets initiative
The targets National Highways also asks its suppliers to set.