Mandatory Life Cycle Assessment (LCA) regulations are now in place across Norway, Sweden, Finland, Denmark, and Iceland. Each country requires LCA at different stages of a building project—either at the design and permit stage or at project completion—and the scope varies from all new buildings to only larger developments. This report gives architects a clear overview of when LCA must be delivered and which building types are covered in each Nordic country.
Norway
Norway has implemented a legal requirement for Life Cycle Assessment (LCA) of greenhouse gas emissions in building projects as part of its building regulations (TEK17). Since July 1, 2022, all new constructions and major renovations of apartment buildings and commercial buildings (termed boligblokk and yrkesbygning in TEK17) must include a climate account (GHG emission calculation) for building materials[1]. This LCA – following the national standard NS 3720:2018 – must be documented for the finished building, typically at project completion[1]. The requirement does not apply to “small houses” (småhus) such as single-family homes and similar dwellings[1]. In practice, developers are encouraged to perform a preliminary LCA early in design, but the mandatory submission is tied to the as-built stage (e.g. as part of final documentation)[2][3]. No minimum floor area threshold is given in the regulation; the trigger is the building type (all multi-unit residential and non-residential buildings require LCA, whereas one- and two-family houses are exempt)[2].
Sweden
In Sweden, an LCA-based climate declaration (klimatdeklaration) is legally required for new buildings under the Act (2021:787) on Climate Declarations. Effective January 1, 2022, any new building that requires a building permit must have a climate declaration submitted to the National Board of Housing (Boverket)[4]. This declaration reports the building’s embodied GHG emissions from the construction stage (modules A1–A5)[5]. The climate declaration is delivered at project completion – it must be submitted before the municipality can grant final occupancy approval under the Planning and Building Act[6]. In other words, a completed climate LCA is a condition for obtaining the final clearance for a new building[7].
Not all projects are covered. Exceptions include: buildings with a gross floor area ≤100 m², temporary buildings (≤2 years use), industrial and workshop buildings, agricultural buildings, buildings for national defense or security, and privately built single-family houses (where the developer is an individual building for personal use)[8]. These categories do not require a climate declaration. For all other permit-requiring new buildings (e.g. multi-family housing, larger single-family developments by a company, commercial and public buildings) the climate declaration is mandatory[9][10]. Notably, renovations or extensions are currently excluded, as the law applies only to new construction[11].
Finland
Finland is in the process of phasing in mandatory LCA requirements via its updated Building Act. A “Climate Declaration” will be required for new buildings in Finland under the new law, with the obligation taking effect for building permit applications filed on or after January 1, 2026[12]. The climate declaration will document the whole-life carbon footprint of the building over a 50-year life cycle, in kg CO₂e per m², using a national calculation method aligned with EN 15978[13][14]. According to the Ministry of the Environment, the process involves two parts: a material inventory submitted at the building permit stage, and the Climate Declaration (LCA results) submitted at the building’s commissioning/final inspection stage[12]. The material list (all permanently installed products) must be provided when applying for the permit, while compliance with the forthcoming carbon limits will be verified by the final climate declaration when the building is completed[12][15].
The Finnish requirement will apply to most new buildings, with certain exemptions. Excluded from the mandate are detached single-family houses (and other small residential buildings termed “pientalo”), vacation cabins, and agricultural buildings, as well as renovation or extension projects[16]. The law specifically targets larger residential and commercial categories – for example, it covers rowhouses (townhouses), apartment blocks, office and educational buildings, retail buildings (shops, malls), healthcare facilities (hospitals, care homes), sports halls, etc., including any heated building over 1000 m²[17][18]. In summary, from 2026 Finland will require LCAs for new construction except for small dwellings and certain special-purpose buildings, with the LCA results (Climate Declaration) delivered at project completion and an upfront materials report at permit application[12][19]. (Binding carbon limit values are expected to be introduced later, around 2027–2028, once baseline data has been gathered[20].)
Denmark
Denmark introduced mandatory LCA requirements in its building code as of January 1, 2023. Under the Building Regulations, all new buildings larger than 50 m² must undergo a life-cycle carbon assessment[21]. This means that for virtually every new construction that requires a permit, the developer must calculate and document the building’s climate impact over a 50-year lifespan[22][23]. The LCA report must be submitted at project completion – Danish law requires that the LCA (termed a climate calculation) be provided to the building authorities before an occupancy permit can be granted for the new building[24][25]. In practice, the LCA is treated like other technical compliance documentation: it is compiled during design/construction and then handed in with the application for use authorization of the finished building[24].
Additionally, Denmark has introduced a carbon intensity limit value for larger projects. New buildings over 1,000 m² must not only perform an LCA but also meet a maximum GWP threshold of 12.0 kg CO₂e/m² per year (averaged over 50 years)[26][27]. (This limit will tighten in coming years and, by 2025, is set to apply to smaller buildings as well[28].) Smaller structures under 50 m² (such as very small sheds or similar minor builds that usually fall outside permitting requirements) are effectively exempt, but no specific building type is excluded otherwise – the rules apply to housing, offices, public buildings, etc., as long as the floor area is above the minimal threshold[21]. Renovation projects are not yet covered by these LCA mandates[29]. In summary, Denmark requires an LCA for all new buildings (with documentation due at the end of construction), and imposes a carbon limit on large buildings[30][25].
Iceland
Iceland is the latest Nordic country to introduce mandatory LCA in building projects. New provisions in the Icelandic building regulation will take effect on September 1, 2025, making LCA reporting compulsory for the majority of new constructions[31][32]. Under these rules, before obtaining a building permit, developers of applicable projects must perform a life-cycle assessment and submit the results through the housing authority’s online portal (HMS LCA portal)[33]. A receipt from this LCA submission is required as part of the building permit application package[34]. Unlike Sweden or Norway, Iceland’s system places the LCA checkpoint at the design/permit stage rather than at completion. (There is no legal obligation in Iceland to update or resubmit the LCA after construction, though it is recommended to revise the analysis with accurate data as the project progresses[35][36].)
The Icelandic LCA requirement will cover most new buildings, with some exclusions for smaller or special-case structures. According to the official announcement, the mandate “does not include small new constructions such as storage facilities, agricultural buildings, summerhouses and extensions to existing structures.”[32] In effect, standard residential, commercial, and public building projects (falling in building size Categories 2 and 3 under Icelandic rules) are subject to LCA, whereas small outbuildings, farm buildings, vacation cottages, and home additions are exempt[32][33]. Iceland’s transition includes a formal trial period in which the industry is encouraged to gain experience with preparing and submitting LCAs ahead of the 2025 enforcement[37][31]. Looking further ahead, Iceland plans to introduce binding carbon limit values by 2027–2028, after an initial data-gathering phase, to cap the emissions of new buildings[20].
Summary Comparison Table
The table below compares the mandatory LCA requirements across Norway, Sweden, Finland, Denmark, and Iceland:
|
Country |
LCA Required by Law? |
Stage for Submission |
Scope / Threshold (Which buildings) |
|
Norway |
Yes (since 2022)[1] |
At completion (“as built” documentation)[1] |
New apartment buildings and commercial buildings (multi-family residential and non-residential). Exempts small houses (single-family or similar dwellings)[1]. |
|
Sweden |
Yes (since 2022)[38] |
At completion (submitted for final occupancy sign-off)[6] |
All new buildings requiring a permit (typically >100 m²). Exempts: GFA ≤100 m², temporary buildings, industrial/workshop, agricultural, defense-related, and private self-built homes[8]. Only new construction (no requirement for renovations/extensions)[11]. |
|
Finland |
Yes (from 2025–2026)[12] |
Permit stage & completion – Materials list at building permit; Climate Declaration at final inspection[12] |
Will apply to most new buildings (when law kicks in 2025–26). Exempts: detached houses and small residential buildings, holiday cabins, farm buildings, and renovations/additions[19]. (Initial threshold covers rowhouses, apartments, offices, retail, public buildings, etc., essentially all larger building types)[17][18]. |
|
Denmark |
Yes (since 2023)[30] |
At completion (LCA must be filed for occupancy permit)[25] |
All new buildings >50 m² GFA[21]. Exempts: only very small structures ≤50 m². Carbon limit in effect: new buildings >1000 m² must keep GHG <12 kg CO₂e/m²/yr[26][27]. (No current LCA requirement for refurbishments.) |
|
Iceland |
Yes (effective Sept 2025)[31] |
At building permit application (design phase submission)[34] |
New buildings (broadly all standard building projects). Exempts: small ancillary buildings (e.g. storage sheds), agricultural buildings, summer houses (holiday homes), and extensions to existing buildings[32]. (No requirement for renovations.) |
Each country’s regulations prioritize mandatory LCA in building projects, but the timing and scope of the requirement vary. Norway and Sweden require the LCA at completion for larger building categories, Denmark at completion for virtually all building sizes (with an added emissions cap for big buildings), Finland’s law (into force by 2026) will require it at permit (materials data) and completion (full LCA) for nearly all but the smallest house projects, and Iceland will require an LCA upfront at permit stage for most new builds, excluding only minor structures. All these measures reflect a growing Nordic regulatory trend to quantify and ultimately reduce the carbon footprint of buildings through mandatory life-cycle assessments[39][30].
Sources:
[1] [2] [3] § 17-1. Klimagassregnskap fra materialer - Direktoratet for byggkvalitet
https://www.dibk.no/regelverk/byggteknisk-forskrift-tek17/17/17-1
[4] [5] [6] [7] [8] [9] [10] [11] [38] Questions and answers about climate declarations - Boverket
https://www.boverket.se/en/start/laws-and-regulations/climate-declaration/questions/
[12] [15] Ilmastoselvitys ja rakennustuoteluettelo luovat uusia edellytyksiä rakennuksen vähähiilisyyden arvioinnille - Ympäristöministeriö
[13] [14] Finnish demonstrations - ACCORD Partners
https://accordproject.eu/finnish-demonstrations/
[16] [17] [18] [19] Ilmastoselvitys
https://www.rakennustieto.fi/tuotetieto/ilmastoselvitys
[20] [33] [34] [35] [36] Spurt og svarað um LCA | Húsnæðis- og mannvirkjastofnun
https://hms.is/lifsferilsgreining/spurt-og-svarad-lca
[21] Denmark: Bygningsreglementet (BR25) and LCA | One Click LCA
https://help.oneclicklca.com/en/articles/367749-denmark-bygningsreglementet-br25-and-lca
[22] [23] [26] [27] [28] New LCA requirements enter into force | KHR Architecture
https://khr.dk/en/new-lca-requirements/
[24] [25] [29] [30] Nye klimakrav til nybyggeri fra 2023: det skal du vide som bygherre - Bygherreforeningen
https://bygherreforeningen.dk/nye-klimakrav-til-nybyggeri-fra-2023-det-skal-du-vide-som-bygherre/
[31] [32] [37] [39] Iceland Introduces New LCA Requirements | Nordic Sustainable Construction
https://www.nordicsustainableconstruction.com/news/2024/april/iceland-lca-requirements
