Most infrastructure firms have a sustainability commitment at the group level. Far fewer have a consistent, auditable approach to carbon at the project level. 

The FIDIC Carbon Management Framework (CMF), published in beta in September 2025 by a working group (Arcadis, Arup, Mott MacDonald, Ramboll, WSP, and the University of Cambridge), provides the structure. But structure alone does not close that gap. What makes progression through the CMF real is the quality of the carbon data underpinning each decision. Calibrated, auditable, project-specific carbon quantification is what turns a framework component into a defensible decarbonisation option: one that an engineer can present to a client, a procurement team can embed in a contract, and an auditor can verify.

This is the context in which tools like ORIS operate: as the measurement layer that gives each of its 7 components operational substance. This article walks through the CMF component by component, with that lens in mind.

Before the framework starts: Carbon Awareness

The CMF defines a foundational layer: Carbon Awareness. It must exist before any of the seven components can be applied meaningfully. This means the project team understands what whole-life carbon is, how embodied and operational carbon differ, why the biggest opportunities for reduction occur at the earliest project stages, and how carbon reduction and cost efficiency are often the same thing.

The CMF is direct on one point: the largest lever for reducing a project's carbon footprint is the decision about whether to build at all, and what to build. Once scope and design direction are set, a significant proportion of carbon is already locked in. Teams that begin carbon management at the detailed design or construction stage are working with a fraction of the available opportunity.

The seven components

1. Leadership and Accountability

The CMF's first component asks who owns carbon on a project: who is accountable for reducing it. At the entry level, carbon sits with the sustainability team and rarely reaches engineering decisions. At the highest maturity level, the project executive carries direct accountability, with measurable consequences if targets are missed.

The practical implication is straightforward: carbon management without executive accountability produces more reporting than reductions. The CMF describes the progression from a sustainability champion with no mandate, through to a Project Executive with delegated authority over low-carbon decisions, through to a government-level sponsor with system-wide carbon targets and real penalties for missing them.

Ask yourself: If carbon reduction on your current project required a design decision that added 3% to capex, who has the authority and the mandate to approve it?

2. Whole Life Carbon Assessment

Assessment is how a team moves from awareness to action. The CMF frames carbon assessment not as a deliverable but as a continual process that starts approximately and becomes more granular as the project progresses.

Early-stage assessments will use estimated quantities and generic emission factors. That is expected at lower maturity levels. What distinguishes higher-maturity teams is not precision for its own sake, but the use of assessment to drive decisions: identifying hotspots early enough to act on them, updating the model when the design changes, and expanding the scope of assessment as more data becomes available.

The CMF explicitly notes that accuracy matters less than consistency and usefulness. An assessment that is 80% accurate but actively used in design reviews delivers more carbon reduction than a precise model that arrives too late to influence anything.

At higher maturity levels, assessment is dynamic. Quantities flow from BIM models. Emission factors are supplier-specific. The carbon model updates when the design updates. The functional unit shifts from capital carbon alone to whole-life - embodied, operational, user, and end-of-life - assessed at every project stage.

Ask yourself: When did your last carbon assessment influence a design decision, and at what project stage was that decision made?

3. Baseline and Targets

A carbon baseline is the reference point against which everything else is measured. The CMF defines it as the expected carbon footprint of a project if no interventions are made. Typically, a conventional design uses standard materials and processes. Without a baseline, it is not possible to demonstrate reduction, benchmark performance, or make the business case for low-carbon alternatives.

Targets follow from baselines. The CMF describes a progression from informal "shadow" targets based on comparable projects, through to formal client-set targets aligned with PAS 2080, through to system-level carbon budgets aligned with national or international climate commitments.

Two principles stand out:

• First, targets set late in the project lifecycle have less impact than targets set at conception, because more carbon has already been fixed by design decisions.

• Second, a baseline with transparent assumptions is more useful than a precise one with opaque methodology. When the design changes, the baseline needs to change with it; that requires the assumptions to be visible and challengeable.

Ask yourself: Does your current project have a carbon baseline, and if it does, was it set early enough to inform optioneering?

4. Driving Carbon Reductions

The CMF's fourth component is where measurement becomes action. It addresses how carbon reduction gets embedded in project decision-making alongside cost, time, quality, and safety as a live input to every significant design or delivery decision.

At lower maturity levels, carbon hotspots are identified but rarely acted on. The CMF names the blockers explicitly: asset standards that preclude lower-carbon alternatives, programme pressure, high perceived cost, and clients who are not engaged. At Level 2, the project team understands the blockers even when it cannot yet overcome them. At Level 3, carbon is systematically considered in all design and delivery challenge sessions. At Level 4, failing to meet the system carbon target is a project-stopper: no decision moves forward if the project's whole-life carbon impact does not meet the absolute target.

The framework offers a useful practical heuristic for teams at any level: before reaching for a low-carbon technology, ask first whether the scope of the project can be reduced, whether an existing asset can be reused, and whether the design can be made more resource-efficient. The best low-carbon solution, in the CMF's own words, is often not to build new assets at all.

Ask yourself: In the last three design reviews on your active projects, how many agenda items directly addressed carbon reduction opportunities?

5. Collaboration

Carbon reduction at the project level requires the full value chain. A designer who specifies a low-carbon material without engaging the contractor who will source it has not solved the problem. A client who sets ambitious targets but does not involve suppliers until the tender stage will not achieve them.

The CMF describes collaboration as the mechanism through which opportunities become visible across the project lifecycle. At the entry level, carbon is mentioned in meetings, but the project team is not supported to act on it. At Level 2, the client actively promotes collaboration among designers, contractors, and suppliers. At Level 3, stakeholders outside the project boundary (planners, investors, regulators) are engaged to investigate opportunities that exceed what the project team can deliver alone. At Level 4, collaboration is cross-sector: shared data, shared benchmarks, shared R&D, feeding into industry-wide improvement.

One observation the CMF makes that is worth dwelling on: the firms that will deliver the deepest reductions are those that treat low-carbon construction knowledge as a commercial advantage rather than a trade secret. Sharing what works with the supply chain and the industry accelerates decarbonisation faster than any individual firm can achieve alone.

Ask yourself: Does your project team's carbon methodology get shared with your supply chain, or does it stop at the design boundary?

6. Procurement

Procurement is the point at which carbon ambition either gets built into the supply chain or disappears. The CMF is unambiguous: procurement can incentivise low-carbon behaviour, reward suppliers who deliver low-cost, low-carbon solutions, and create the contractual conditions for carbon data to flow through the value chain.

At the entry level, contracts include no carbon requirements beyond organisational ESG commitments, which are organisational-level targets, not project-level ones. At Level 2, carbon reduction requirements appear in procurement but without the specificity needed to drive action: no defined assessment methodology, no project-specific targets, no data requirements. At Level 3, procurement strategy includes a carbon management plan, methodology requirements, and supplier data obligations. At Level 4, the procurement process focuses on long-term supplier partnerships oriented toward shared carbon-reduction goals.

FIDIC published a separate Carbon Management Guide in December 2025, providing specific contractual mechanisms for projects delivered under FIDIC contract forms. The CMF and the Carbon Management Guide address different layers: the CMF is the project-level framework whilethe Guide addresses the contractual architecture.

Ask yourself: Does your last tender document specify a carbon assessment methodology, project-specific targets, or data requirements for suppliers, or does it reference your organisation's net-zero commitment and leave it there?

7. Continual Improvement

The CMF's final component addresses learning. It covers how data, benchmarks, and low-carbon solutions from one project improve the next and ultimately feed into sector-wide improvement.

At the entry level, a team starts building the basis for future projects: basic carbon benchmarks, initial low-carbon solutions registers, and lessons captured for internal use. At Level 3, lessons are shared with the wider industry, not just retained internally. At Level 4, continual improvement is owned at the sector level and coordinated across asset owners, with established feedback loops that the whole industry contributes to and draws on.

The CMF makes a practical point about benchmarking: even without a formal baseline, a team can improve by comparing successive iterations of their own design. Progress does not require an external reference point to be real.

Ask yourself: when a project closes, what carbon data - benchmarks, material performance, hotspot analysis - gets captured in a form that the next project team can actually use?

The four maturity levels

Each component is described at four levels. A project can be at different levels across different components: that variation is where the most actionable improvements typically lie.

Level 1 - Acknowledging: Carbon awareness exists, but accountability is informal. Assessment is basic and covers at least the capital carbon. No formal baseline or targets. Carbon is discussed, but rarely drives decisions. The team is building a carbon reduction mindset.

Level 2 - Intervening: Engineering teams actively identify better solutions. Some targets exist, though not always client-mandated. Carbon is integrated into project risk registers. The blockers to implementation are understood even when not yet resolved.

Level 3 - Achieving: Carbon management is embedded in standard processes alongside cost, time, and quality. Client-set targets aligned with PAS 2080 or equivalent. Whole-life carbon assessment at every project stage. Procurement actively enables carbon management. Lessons shared with the wider industry.

Level 4 - Pioneering: Projects influence systems beyond their own boundary. Carbon is the primary decision criterion. Accountability reaches the government level. Collaboration is cross-sectoral. Continual improvement is managed at the sector scale.

The CMF is explicit: Level 4 represents a systemic shift that most project teams cannot create alone. It requires political and financial structures that extend beyond what a consultant or contractor can control. Levels 2 and 3 are where the majority of infrastructure firms can make the most impact... and where the gap between current practice and what is operationally achievable is smallest.

What the CMF reveals about current practice

The CMF was not written to describe best practice in isolation. It was written because the working group - comprising some of the largest infrastructure consultancies in the world - observed a consistent pattern: group-level sustainability commitments that do not translate into consistent project-level practice.

The seven components, read together, describe a system that most infrastructure firms have only partially built.

• Leadership accountability tends to stop below the project executive level.

• Assessment tends to happen too late in the project lifecycle to influence optioneering.

• Baselines are set after the design direction is already fixed.

• Carbon reduction opportunities are identified but not implemented.

• Supply chains are not engaged until tender. Lessons are not systematically captured.

None of this is a criticism of individual firms. It reflects the structural reality of how infrastructure projects are delivered: fragmented value chains, short procurement cycles, competing priorities, and clients who are only beginning to ask for carbon evidence in tenders.

The CMF's value is that it makes the gap visible, names it at each level, and provides a pathway to close it — component by component, project by project.

The FIDIC Carbon Management Framework is currently in global beta testing. The full document is available at fidic.org.

ORIS Materials Intelligence is piloting CMF alignment on infrastructure projects.

All framework descriptions in this article reflect the FIDIC CMF Beta Document (September 2025) directly.