GHG Protocol Scope 3 Update: What You Need to Know

Scope 3 has long been the hardest part of carbon accounting, not only because of its inherent complexity, but because regulations have allowed for a certain level of variance in how emissions are calculated, reported, and disclosed.

With the recent proposed updates to the Greenhouse Gas Protocol, that is starting to change. These updates signal a shift towards more complete, transparent, and structured Scope 3 reporting, and while these changes are still in draft form, the direction is clear: Scope 3 is moving from approximate measurement towards defensible, decision-ready accounting.

This article breaks down key developments and what they mean in practice:

• The proposed 95% coverage threshold

• New data quality disclosure requirements

• A multi-statement reporting framework for emissions, actions, and impact

• A new Scope 3 category to encapsulate “other value chain activities”

‍Scope 3 Is Moving Toward Full Coverage

‍One of the most significant proposed changes is a requirement for companies to report at least 95% of total Scope 3 emissions to remain compliant.

Today, the standard requires companies to account for all Scope 3 emissions and justify exclusions, but it does not define a threshold, which has led to variability. Some companies focus on a handful of categories, while others attempt broader coverage.

The proposed 95% threshold introduces a clear expectation: near-complete visibility across the value chain. This is not just a reporting tweak. It changes how Scope 3 programs are built.

‍Companies will now need to:

• Move beyond partial category coverage

• Address long-tail suppliers and lower-visibility categories

• Ensure consistency across methodologies

‍Achieving 95% coverage requires systems and processes that can scale across the supply chain, including:

• Structured data collection across categories

• Repeatable methodologies

• The ability to continuously close data gaps

In other words, Scope 3 coverage becomes an ongoing operational capability rather than a one-time exercise.

‍Data Quality Is Becoming Visible (and Comparable)

‍Another proposed shift is the requirement to disaggregate emissions by data quality tiers. Instead of reporting a single blended number, companies would need to show how their emissions are calculated, including:

• Supplier-specific (primary) data

• Industry averages (secondary)

• Spend-based estimates

‍The goal is not to eliminate estimation, but to make it transparent and introduce a new level of comparability.

‍Stakeholders will be able to see:

• How much of a company’s footprint is based on real supplier data

• How much relies on proxies or assumptions

To keep up, companies will need to:

• Track data sources at a granular level

• Improve primary data coverage over time

• Engage suppliers directly, rather than relying solely on modeled estimates

‍Carbon Accounting Is Expanding Beyond the Inventory

‍Historically, carbon accounting has centered on a single number: total emissions. But that number often blends together:

• Actual emissions from operations and supply chains

• Actions taken to reduce emissions

• Claims about avoided emissions or offsets

‍This makes it difficult to interpret what is really happening.

‍A new draft framework introduces a more structured approach, separating different types of information into distinct statements:

• Physical GHG inventory: what emissions are attributable to the company

• Market-based inventory: use of contractual instruments (e.g. PPAs, RECs)

• GHG impact statement: the impact of mitigation actions (e.g. avoided emissions, credits)

• Non-GHG indicators: additional metrics such as low-carbon procurement

Separating these elements helps prevent:

• Double counting

• Inflated reduction claims

• Confusion between emissions and impact

It also enables more transparent communication with stakeholders, and a tighter linking of actions to outcomes.

A New Scope 3 Category for “Other Value Chain Activities”

‍A new category is being proposed to capture "other value chain activities" that do not fit neatly into the fifteen existing Scope 3 categories.

Its most notable addition is facilitated emissions: emissions generated by third-party activities from which a company earns direct, transactional income but never buys, sells, or owns.

‍Category 16 is designed to modernize the Scope 3 boundary for current and emerging business models. Activities in licensing, financial facilitation, franchising, and platform-based services sit in a gray zone under today's framework, neither clearly inside nor outside a company's inventory.

‍As proposed, the category includes a dedicated subcategory for licensing, giving licensors a structured way to report the Scope 1, 2, and 3 emissions of the activities their licensing facilitates. To preserve feasibility, most subcategories would be optional, letting companies adopt the framework as their data matures.

What This Means for Procurement and Supply Chains

‍As requirements become stricter, it is no longer sufficient to estimate emissions annually. Companies need to actively manage and reduce them, and move from measurement to momentum.

‍Procurement becomes central

‍Many of the levers that influence Scope 3 sit within procurement:

• Supplier selection

• Contract terms

• Renewable energy sourcing

• Category strategies

‍Supplier engagement becomes non-negotiable

‍Improving data quality and driving reductions both depend on supplier participation. Companies will need to:

• Collect primary data from suppliers

• Support suppliers in improving their own emissions performance

• Track progress over time

‍What to Do Now

‍Take these steps to prepare your organization for updates to the Greenhouse Gas Protocol:

1. Assess your Scope 3 coverage. Understand how close you are to full coverage: Which categories are included? Where do gaps remain?

2. Map your data quality. Break down emissions by data type to create a baseline for improvement.

3. Build a supplier engagement plan. Identify which suppliers to prioritize, what data to request, and how to incentivize participation.

4. Start tracking actions, not just emissions. Track renewable energy adoption, supplier transitions, and product or material changes to lay the groundwork for future impact reporting.

‍The Next Phase of Scope 3

‍While these changes are still in draft, it is fair to say that Scope 3 reporting is moving towards a more rigorous phase. If these changes go into effect in 2027, coverage expectations will increase, data quality will become more visible, and companies will be asked not just to measure emissions, but to demonstrate credible action and impact.

‍These changes do not fundamentally alter the challenge of Scope 3, but they make it harder to defer.

‍The companies that succeed will be those that treat carbon accounting as an operational discipline, embedded in procurement and supplier relationships, rather than a standalone reporting exercise.

‍Measurement remains essential. But increasingly, it is only the starting point.