Revised Scope 3 standard and new rules for reporting investments (category 15)

Transition from the original Corporate Value Chain (Scope 3) standard from 2011 to its revised version, whose final publication is scheduled for March 2026, represents a fundamental breakthrough in corporate greenhouse gas reporting methodology.

1. Strategic context of the Scope 3 standard revision

This revision is not just a technical update, but a strategic shift towards full interoperability with international financial standards and scientific integrity. The aim is to ensure that emissions data in the value chain is robust enough to serve as a relevant input for investors and regulators in the context of mandatory sustainability disclosures.

The main objectives of the revision are structured into three pillars that increase transparency and comparability:

  • Series A (Data Quality): It introduces mandatory disaggregation of emissions and stricter data specificity requirements, allowing for more accurate tracking of progress on decarbonisation.
  • Series B (Inventory Boundaries): It defines exact quantitative limits for the inclusion of emissions, replacing previous subjective criteria with a scientifically based framework.
  • Series C (Investments): It deepens the methodology for the financial sector, aligning the reporting of financed issues with the reality of economic exposure.

A key element of this transformation is the strategic partnership between the GHG Protocol and the International Organization for Standardization (ISO). This collaboration aims to harmonize global standards for greenhouse gas accounting at both the organizational and product levels. The authenticity and urgency of the process is underlined by the fact that experts from the ISO technical community will join the working groups (TWGs) already in first quarter (Q1) 2026, to finalize revisions before publication. This global consensus provides a framework for rigorous technical requirements for establishing inventory boundaries.

2. Quantitative Boundary Determination: Rule 95 % Inclusions (Series B)

Precise boundary setting is essential to ensure completeness of the inventory and to eliminate the risk of selective reporting. The revised standard replaces the previous subjective and qualitative reasoning with precise numerical basis for inclusion and exclusion of emissions.

New requirement for 95 % emissions coverage (Revision B1)

Companies are now required to report at least 95 % total mandatory emissions Scope 3. This approach introduces a strict quantitative threshold, with permitted exclusions limited to a maximum of 5 %.

Emission category Reporting requirement Definition and limits
Mandatory emissions (Required) Mandatory At least 95 % of the total volume according to categories 1-15.
Optional emissions (Optional) Optional For example, facilitated activities in the new category 16.
Allowed exclusions Limit 5 % A maximum of 5 % mandatory emissions may be excluded (must be justified).

Quantification process and Hotspot analysis (Revision B2, B3)

In order for a company to legitimately exclude any portion of its emissions, it must first quantify 100 % of its mandatory Scope 3 emissions. The following is used to identify significant sources: Hotspot analysis, which is defined as a high-level quantification (using, for example, industry averages or spend-based data). This process is more scientifically rigorous than previous methods because it requires exact proof that the cumulative impact of exclusions does not exceed the 5 % threshold.

Definition of „De minimis“ emissions (Revision B5)

Concept de minimis indicates emissions that are reasonably considered to be insignificant or negligible. The standard gives a specific example: paper clips and staples. Although these items do not need to be quantified in detail, their estimated volume is mandatorily included in the total 5 % limit for permitted exclusions.

These strict quantitative limits (95 %) are infeasible in practice without a parallel improvement in data quality, which is addressed by the requirements in Series A.

3. Data quality and disaggregation requirements (Series A)

The strategic goal is to move from spend-based rough estimates to primary data obtained directly from the supply chain. Data accuracy is a prerequisite for verifiable claims about emission reductions.

Disaggregation of emissions by data type (Revision A1)

The revised standard introduces mandatory disaggregation of emissions into levels (tiers) according to the type of underlying data. It is important to note that specific classification rules for individual tiers are currently being finalized (4 to 5 levels are considered). The aim is to transparently separate emissions calculated based on specific factors from non-specific (average) estimates.

Mandatory Disclosure of Verification (Revision A2)

Increasing the credibility of reports requires clear marking of the third-party verification status. Companies are required to use the following precise markings:

  • Verified: The entire inventory or category has passed a successful audit.
  • Partially verified: Verification was carried out only for selected activities.
  • Not verified: The data has not been subject to external independent verification.

Recommendations for emission factors and targets (Revision A5, A6, A7)

Companies should prioritize using emission factors with a high degree of completeness (limit of exclusions max. 5 %). It is also recommended to set measurable goals to improve data specificity, for example, the percentage of primary data in the portfolio.

The long-term accuracy of reporting is also affected by limiting data allocation at the corporate level to only homogeneous suppliers (Revision A8). For diversified suppliers, where emissions intensity varies significantly between different product lines, allocation based on company-wide emissions is no longer permissible.

4. Methodology for Category 15: Investments and Funded Issues (Series C)

Category 15 is critical for financial institutions because the revision narrows its scope exclusively to investment activities, known as financed emissions (Financed Emissions).

Proportionality Calculation: Inclusion of Debt (Revision C10)

A fundamental change in the methodology for calculating an investor's share of an entity's emissions is the adjustment of the denominator. Now, the calculation must include not only equity, but also debt (Equity + Debt). This approach is fully consistent with PCAF standards, ensuring interoperability and an equal distribution of responsibility between shareholders and bondholders.

New investee boundaries (Revision C6)

There is a significant expansion of the boundaries compared to the 2011 standard. Financial institutions are now mandatory to include Scope 1, 2 and now also Scope 3 issues of investee entities. This represents a fundamental technical challenge, but it is essential to obtain a complete picture of the portfolio's climate exposure.

Classification of financial instruments in Category 15

The following table specifies the instruments belonging to category 15 (according to Revision C2 and Annex B):

Tool group They belong to Category 15 (Mandatory) Examples of tools
Equity investments Yes Common stock, private equity.
Debt instruments Yes Corporate bonds, commercial loans.
Project financing Yes Financing specific industrial assets.
Consumer financing Yes Mortgages, car loans.

Investment issues are subject to the same 5 % threshold for exclusions as other categories (Revision C8), forcing institutions to rigorously assess the entire portfolio.

5. Facilitated activities and the new Category 16

The creation of category 16 is a response to the need to capture the influence of institutions where they do not directly own assets, but generate income from them. This is the so-called. facilitated emissions (Facilitated Emissions).

Definition and scope of Category 16

Category 16 includes intermediation activities where the reporting firm does not own, buy or sell the activity (Revisions C3, C4, B11). These include:

  • Insurance and reinsurance (Insurance-associated activities).
  • Underwriting and issuance of securities.
  • Licensing.
  • Brokerage services.

Strategic difference and consistency

While reporting in category 15 (investments) is mandatory, category 16 remains optional for most entities. optional. An exception is made for oil and gas distributors, for whom certain facilitated activities are mandatory. The revised standard in Revision B12 explicitly refers to external industry frameworks, in particular PCAF, to ensure methodological consistency in reporting facilitated issuance across the financial sector.

This new methodology is not just an administrative burden, but a tool to gain an accurate picture of climate risks. Separating net investments (Cat. 15) from other financial services (Cat. 16) allows institutions to better allocate capital in line with decarbonisation objectives. JRi&CO2AI 

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