England's circular economy strategy is now expected to be unveiled in 2026, a delay from autumn 2025. The shift to a Circular Economy Growth Plan signals political momentum but creates uncertainty for commercial real estate (CRE) portfolios planning waste management, refurbishment, and tenant services. This post examines what the delay means for asset owners, facility managers, and ESG teams. You will learn why timing matters for budgets and reporting, how to translate policy ambitions into realistic actions today, and which data and tools help you stay ahead regardless of a shifting timetable. By focusing on real world waste data and practical workflows, you can strengthen tenant relations, protect asset value, and accelerate progress toward circularity even while government roadmaps are being finalised.

The Problem

The delay in publishing the Circular Economy Growth Plan means detailed roadmaps for reforming material use and supply chains have not yet landed. The Circular Economy Taskforce has highlighted five priority sectors where circular principles could deliver the greatest environmental and economic gains: textiles, transport, construction, agri‑food, chemicals and plastics. For CRE, the implications are concrete. Construction and refurbishment waste, circular fit-out decisions, and the reuse of building materials hinge on policy signals and funding. Without firm timing, capital programmes and tenant engagement plans can stall. Businesses may face higher waste disposal costs, fragmented supplier practices, and uncertainty about future recycling standards. Organisations that move from waiting to measuring are better placed to capture value from circularity, regardless of the timetable.

The Implications

Policy uncertainty translates into several business risks for CRE and ESG teams. Budgets and project timelines can slip as decision makers wait for clearer guidance. Refurbishment strategies that optimise material reuse and waste diversion may be delayed, increasing carrying costs and complicating lifecycle planning. For tenants, inconsistent standards and unclear targets can undermine buy‑in for shared waste services and circular tenancy models. On the reporting side, data collection and verification become harder when policy milestones are uncertain, potentially affecting CSRD and GRESB readiness. At the same time, the impending Growth Plan creates an opportunity to shift to more flexible, data‑driven waste strategies that align with the taskforce’s roadmaps.

Here are practical steps CRE teams can take now:

• Map current waste streams across assets, from construction and fit-out waste to tenants' general waste and recyclables.
• Build pilot programmes that test circular practices in a controlled environment, such as material reuse on refurbishments or de‑construction-ready planning.
• Align procurement and supply chains with circularity goals, seeking partners who can provide recyclability data and verified collateral for reporting.
• Develop transparent communication with tenants about waste targets, charging models, and the benefits of a shared circular economy approach.

This proactive stance helps anchor value in your portfolio by reducing waste costs, improving resilience, and providing credible data for ESG disclosures.

The Solution

Even with policy delays, CRE can accelerate circularity by concentrating on data and execution. Real‑time waste data provides visibility into where waste arises, what can be diverted, and where materials can be reused or recycled. Robust ESG reporting then translates that data into credible progress against targets, approvals, and investor requirements. The outcome is clearer governance, safer cash flows, and stronger tenant engagement.

A portfolio approach works best. Start by baselining waste across multiple sites, then identify hotspots where the greatest circular gains can be achieved. Set practical targets, document the required interventions, and track progress over time. When you couple this with a clear tenant engagement plan, you create a shared path to circularity rather than a top‑down mandate.

This is where Wastify can make a difference. The platform provides real‑time waste data and AI‑driven ESG reporting to support reporting needs and operational decisions. For example, you can link your site level data to the broader corporate narrative, helping you demonstrate progress even as policy timelines continue to shift. Learn more about real‑time waste data and how it feeds ESG reporting at real-time waste data and AI-powered ESG reporting.

In addition, Wastify AI supports portfolio level insights that help asset managers prioritise interventions across the estate. By integrating data from multiple sites, you can compare performance, identify outliers, and scale successful pilots across the book of business. This data‑driven approach is exactly what buyers and lenders expect when circularity has become a core risk and opportunity driver. For further context on the platform's capabilities, explore how AI powered reporting can streamline governance and disclosures with AI-powered ESG reporting.

The key takeaway is simple: policy momentum may be delayed, but the drive toward circularity remains. By adopting a data‑first approach, CRE teams can future‑proof portfolios, reduce waste costs, and deliver tangible environmental and financial gains.

From Guesswork to Actionable Insights

The Circular Economy Growth Plan may be years away, but the actions that create value are immediate. Establish baselines, run pilots, collaborate with tenants and suppliers, and use a capable data platform to turn insights into action. In this way, you are not waiting for policy to dictate progress; you are building momentum that will align with the eventual Growth Plan and beyond. A disciplined, data‑driven approach protects asset value, enhances ESG credentials, and supports long‑term financial performance for your portfolio.

Learn how Wastify AI can help your portfolio turn circular economy ambitions into measurable waste data today: Learn how Wastify can help your portfolio turn circular economy ambitions into measurable waste data today.