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Circular Economy Strategy Delayed: What CRE Leaders Should Do Now

Policy and market signals shape every property portfolio. The Environment Secretary has confirmed that the Circular Economy Strategy will be delayed until 2026, creating a new layer of uncertainty for CRE owners and ESG leads. This post examines what the delay means for waste management, data requirements, and investment planning. We unpack the problem, outline the business implications for compliance and cost, and explain how modern PropTech can help you stay ahead even as policy unfolds. By exploring practical actions now, portfolio teams can keep circular economy goals on track while awaiting clearer guidance. The focus here is on the circular economy strategy and what it means for asset strategies, tenant services, and ESG reporting.

The piece also looks at how technology can bridge the gap between policy and practice, including examples of how real-time waste data and ESG reporting platforms support decision making even in periods of regulatory uncertainty.

The Problem

The government has signalled a slower path to a formal circular economy framework. The strategy, long awaited and referred to as the Circular Economy Growth Plan in some communications, is now slated for consultation after a substantial delay. For CRE and portfolio teams this creates a twofold problem. First, it postpones the regulatory clarity needed to justify long term waste and resource efficiency investments. Second, it complicates the budgeting and procurement cycles that underpin retrofit programmes, tenant refurbishments, and green leasing. In short, the industry faces planning uncertainty just when higher performance expectations typically begin to bite.

For asset managers surveying a mixed portfolio, the absence of a concrete milestones timetable makes it harder to sequence waste segregation upgrades, circular procurement, and tenant charging models. It also raises questions about how data will be required for future compliance, and which metrics will be prioritised for CSRD, GRI, or GRESB reporting. In this environment, many organisations are choosing to focus on building stronger data foundations now, rather than waiting for policy to arrive before acting. Practical steps include tightening waste data collection, ironising cost models, and running pilots that demonstrate the value of circular practices independent of policy timelines. For further context on how the right data can drive ESG outcomes, see how AI-powered ESG reporting supports transparency and accuracy in waste metrics.

The Implications

The delayed circular economy strategy reverberates across several core CRE and ESG priorities. Below are the key business implications and how they play out in practice.

Regulatory and reporting risk. Without a firm policy roadmap, teams may find it difficult to align with evolving reporting standards. The need to gather verifiable waste data remains, but the required framework for what to measure and how to report can shift. By investing in robust data processes now, portfolios can remain ready for CSRD and other schemes once the framework lands. Readily available data also supports ongoing internal governance and audit readiness. For organisations seeking practical ways to handle data today, consider real-time waste tracking to create an auditable trail of performance.

Cost, pricing and tenant experiences. If rules around waste charging and circular procurement are delayed, tenant billing models may be slow to mature. Teams that run pilots around recycling targets and circular services can hedge against future cost volatility and use interim reporting to demonstrate value to tenants and funders. A data-driven approach helps explain the economics of waste management, from collection frequencies to segregation rates, keeping tenant experiences clear and fair.

Portfolio resilience and investment decisions. Delays can slow retrofit decision making, yet that is precisely when value can be unlocked. Early pilots that improve recycling rates, reduce residual waste and lower disposal costs are valuable proofs of concept. They also create tangible returns that can underpin future refinancing or equity raising even before policy is formalised. Partnerships with technology providers that provide transparent waste data, lifecycle cost modelling, and scenario planning offer resilience during uncertainty. For a practical example of how data tools support investment decisions, see how Wastify helps with portfolio wide waste metrics and ESG reporting by linking data to outcomes like diversion rates and cost per tonne.

Operational risk and tenant engagement. In the absence of a clear policy timetable, engagement with tenants becomes more important. Transparent communication about waste targets, incentives, and progress helps maintain momentum on sustainability, even when the regulatory path is unclear. A platform that consolidates waste data and links it to reporting makes it easier to keep tenants aligned with shared goals while you await formal guidance.

The Solution

The answer is a data-first, action-oriented approach that keeps circular economy goals alive while policy evolves. Modern PropTech can reduce reliance on uncertain timelines by providing accurate, auditable waste data, clear traceability, and adaptable reporting for ESG frameworks.

Adopt real-time waste data management. Real-time tracking gives portfolio teams visibility into what is generated, recycled, and sent to landfill. This data supports clearer conversations with tenants and service partners and forms a solid baseline for any future policy requirements. It also helps optimise waste routes, diversion strategies, and recycling streams across assets.

Invest in scalable reporting and governance. A single source of truth for waste data makes CSRD and GRESB submissions more straightforward. Rather than building bespoke reports after a policy lands, teams can configure dashboards now and adapt them as requirements evolve. This approach also strengthens audit readiness and demonstrates proactive governance to lenders and tenants. For more on how data platforms support ESG reporting, explore AI-powered ESG reporting.

Collaborate with tech partners to accelerate value. Pilot projects, data integrations, and clear performance metrics enable controlled experiments in waste management and circular services. These pilots can demonstrate ROI through reduced disposal costs, improved recycling rates, and enhanced tenant engagement. A platform like Wastify connects real-time waste data to ESG reporting, simplifying portfolio wide analysis and ongoing compliance. See how real-time waste tracking can underpin your strategy while you wait for policy clarity.

From Guesswork to Actionable Insights

The circular economy strategy may be delayed, but that does not mean you must wait to act. By prioritising data, governance, and practical pilots, CRE teams can realise tangible benefits today while staying aligned with future regulatory expectations. Robust waste data informs budgeting, supports fair tenant charges, and strengthens ESG disclosures. In a market where policy signals are evolving, a disciplined, data-led approach gives you the agility to adapt without sacrificing progress.

If you want a partner to help you translate waste data into actionable ESG insights, explore how Wastify AI can support your portfolio with real-time waste data and CSRD-ready reporting. It could be the difference between staying on course and losing momentum as policy timelines shift.

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