Industry observers say the expanded Commercial Building Disclosure (CBD) program to include office tenancies and large hotels will kick off good another bout of energy efficiency gains for the built environment. But they’re keen to see a start date.
The program currently aims to require commercial offices of 1000 square metres or more to declare their NABERS energy rating when offered for sale, lease or sublease. Unless exempt, this affects building owners and lessors, tenants, prospective buyers, real estate agents, banks and investors.
The consultation is being undertaken by the federal Department of Climate Change, Energy, the Environment and Water (DCCEEW), and has been in the works since the release of the CBD Program Expansion Roadmap in October 2025.
Industry players are calling for the program to announce a release date.
Steve Hennessy, sustainability consultant for WT Partnership, said the expansion had been in the works for a while, but the industry was still waiting to see when it would happen.
Hennessy told The Fifth Estate that while he did not originally support making NABERS disclosures mandatory, he changed his mind after seeing the impacts of the program.
“What we’re seeing is the building owners have become very good at reducing their energy [and] we’ve seen a reduction in energy consumption from a base building perspective.
“If you look at the building energy use, the base building energy use has been coming down, but the tenancy energy use hasn’t, whereas many years ago, you have between 65 per cent and 70 per cent of total energy would be base building.
“Now it’s less than 50 per cent in better buildings.”
Hennessy said tenants’ “minds are on other things”, but their energy use is starting to “stick out like a sore thumb”. Expansion of the CBD program to include tenants will encourage them to start thinking about their energy.
“It’s not overly expensive to do (especially) in conjunction with a base building NABERS rating.”
Hennessy explains that the co-assess process allowed tenants to get their own ratings during the assessment of the base building’s ratings at a reduced price.
He said the expansion will catch tenants who don’t necessarily qualify for the AASB 2 accounting climate disclosure framework – targeted at larger companies.
“The government isn’t telling anyone what rating they’ve got to have,” Hennessy said. The pressure comes from their peers seeing “where they sit” relative to each other.
Meanwhile, bigger hotels are already quietly gearing up for the CBD program expansion.
Pro-invest Group, which owns hotels such as Kimpton Margot in Sydney, recently announced a partnership with Buildings Alive headed by Craig Roussac, to optimise its environmental performance and monitor and improve NABERS ratings across its portfolio.
There will be a “flurry” of more activity once the regulation is enacted, Hennessy said.
“The great thing about NABERS is it doesn’t matter what you say you’re going to do; it measures what you’ve done. So the proof is in the pudding.”
“My experience with hotels is that the engineers want to focus on these things, but the money gets invested in the side that the public can see. I think mandatory disclosure is going to shift that focus and probably give a bit more credit to engineers in hotels.”
“When you go to book [a hotel], and the NABERS rating is there, you’re going to have people asking questions – people who’ve never thought about NABERS ratings [before]. A hotel with good ratings is going to try and capitalise on that.”
The consultation survey closes Friday 18 December 2026.
NABERS recently released it FY2026 annual report highlighting the major milestones across Australia’s commercial building and sustainability sector.
See Steve Hennessy’s presentation at Transition Risk, free for TFE members.
