Circular economy policy in the UK has long been framed as a driver of cost savings, happier tenants, and a greener portfolio. Yet the latest update confirms the Circular Economy Strategy will not be published until 2026. For commercial real estate (CRE) firms, that delay creates uncertainty around waste governance, supplier commitments, and how ESG reporting will align with evolving regulation. This post unpacks what the delay means for asset owners, managers, and ESG leads, and shows how modern data-enabled approaches can help you stay ahead. We will identify the problem, explain the implications for your portfolio, and outline a practical path forward that leverages real time waste data and ESG reporting capabilities. The primary keyword here is circular economy strategy, which anchors our discussion about policy, planning, and performance.
In a sector that increasingly prizes accountable waste management and circular practices, waiting for policy clarity can feel like standing at a red light while the street ahead changes colour. Yet it also creates an opportunity. By building resilient data foundations now, CRE teams can react quickly when the growth plan is consultable, and convert regulatory anticipation into competitive advantage. This post will show how to translate policy uncertainty into actionable steps for budgeting, procurement, and tenant engagement, while keeping your portfolio aligned with CSRD, GRESB and other ESG expectations.
We’ll also point to practical tools that help you collect, validate, and report waste data in real time. For readers already seeking a smarter approach, you will see how [real-time waste data] and [AI-powered ESG reporting] can transform planning and performance even before policy details land.
The Problem: Circular economy strategy delay
The Environment Secretary has confirmed the government’s Circular Economy Strategy, originally due in October, will be delayed until 2026. This means the high level plan and its accompanying consultation timeline are shifting, with Defra referring to it as the Circular Economy Growth Plan. For CRE owners, asset managers and ESG leads, the immediate challenge is not only the uncertainty over what may be required but also the timing of when new targets, procurement rules, or reporting standards will take effect.
This delay does not mean a disengagement from circular aims. Defra has signalled ongoing commitment and the creation of an independent Circular Economy Taskforce to identify mechanisms for England. But for portfolios already juggling waste contracts, tenant expectations, and annual ESG reporting cycles, the absence of a published strategy compresses the window in which decisions can be made with policy-backed certainty. In practice, the delay can slow capital planning, stall new circular procurement pilots, and push some compliance activities into a more reactive mode. Rather than waiting, CRE teams can use this period to close data gaps, test circular business models, and align future requirements with the portfolio’s existing data streams.
Why this matters for CRE portfolios
- Uncertain targets complicate long term budgeting for waste prevention, material reuse, and supplier partnerships.
- Procurement cycles may lag while landlords decide whether to mandate circular features in leases or service contracts.
- ESG reporting timelines could shift, affecting how and when tenants are billed for circular initiatives.
The Implications for CRE and ESG
The delay has significant consequences for how CRE portfolios operate in four key areas:
Compliance and reporting CSRD and GRESB expectations push for robust data on waste generation, recycling rates, and circular procurement. If the policy roadmap shifts, it is easy to fall out of rhythm with reporting cycles. The risk is a misalignment between what you publish and what investors expect, which can impact loan covenants and cost of capital.
Financial planning and tenant valuation Circular practices can unlock operational savings and tenant value, but the return on investment hinges on reliable data and predictable cost streams. Uncertainty around policy can make it harder to justify upfront capex for sorting facilities, on-site reuse, or tenant recharging plans. Without accurate data, you also risk disputes over waste charges and creditor risk if lease accounting assumes circular income that the policy later changes.
Tenant experience and retention Employers and occupiers increasingly demand transparent, responsible waste management. If the policy timeline shifts, tenants may still expect progress. Delivering visible circular outcomes now can help with tenant retention and attract new occupiers who prioritise ESG.
Operational risk and supplier resilience Delays in guidance may leave some supplier commitments on hold. CRE teams should consider dual pathways: a baseline programme that remains useful under current rules, plus an aspirational track that aligns with whatever the Growth Plan eventually requires.
Practical steps you can take now
- Map waste streams and quantify costs across assets so you can demonstrate baseline performance regardless of policy shifts.
- Run pilot circular initiatives in a small number of assets to learn what is scalable when policy clarity arrives.
- Build data dashboards that feed into ESG reporting to show progress and preparedness, not just activity.
- Maintain open dialogue with waste contractors and tenants to set expectations and gather feedback on what circular features would matter most when the policy lands.
For CRE teams seeking to link policy with practice, the answer lies in data. Real time waste data gives you a live view of generation, recycling, and reuse opportunities, enabling smarter chargebacks and better tenant engagement. See how this approach can support ongoing compliance and performance while policy details evolve. [Real-time waste data] can help you quantify current performance and forecast impact as the Growth Plan progresses.
The Solution: Real-time data and planning resilience
The circular economy delay presents a moment to strengthen the data backbone that underpins every ESG programme. A modern CRE operation increasingly relies on integrated platforms that capture waste data, model scenarios, and generate compliant reports without duplicating effort.
A practical solution is to deploy a platform that provides:
- Real-time visibility into waste streams across the portfolio, so you can identify recycling opportunities and reduce residual waste quickly.
- Cost control for charging tenants and for managing waste services, including the ability to demonstrate value in lease negotiations and during investor updates.
- ESG reporting that aligns with evolving standards, enabling you to reconcile actual performance with policy expectations when the Growth Plan lands.
By using a data driven approach, teams can turn policy uncertainty into momentum. A platform like Wastify brings together waste tracking, tenant recharging, and CSRD/GRESB aligned reporting in one place. This supports proactive budgeting, smoother procurement cycles, and clearer communication with tenants and investors. If you are starting to plan ahead, consider mapping the top five circular opportunities in your portfolio and building a lightweight business case around each. Integrate [AI-powered ESG reporting] into your governance process so you can generate reliable disclosures as soon as data is ready. For a practical reading on how real time data informs decision making, explore [real-time waste data] as a starting point.
The solution is not simply adopting new tech. It is about creating a standard approach to waste data that travels with your portfolio, regardless of policy timetable. The best outcomes come from a durable data contract with your facilities teams, tenants, and suppliers. With the right tools, you can demonstrate progress today and stay ready for whatever the Growth Plan requires tomorrow.
How to implement quickly
- Identify a core data set: waste tonnage, diversion rate, and recycling yield across sites.
- Choose a platform with cross asset visibility and tenant billing capability.
- Establish a regular reporting rhythm that feeds into annual ESG disclosures and quarterly board updates.
- Build a fail safe for policy shifts by creating scenario analyses that assume different timelines for strategy publication.
From Guesswork to Actionable Insights
Policy delays should not slow down progress. By investing in real time data and clear governance around waste and circular procurement, CRE portfolios can move ahead with confidence. The goal is to turn uncertainty into a blueprint for action that accelerates value for tenants, investors, and the planet. The right data foundation makes it possible to show tangible improvements in waste performance and ESG outcomes, regardless of how quickly the Growth Plan arrives. Embrace the opportunity to build resilience now, so your assets thrive when policy finally lands.
To explore how Wastify can support your circular economy journey with real time waste data and ESG reporting, visit Wastify AI and discover how our platform can align with your portfolio goals.
