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Promoting sustainability is increasingly becoming vital for corporates because of a changing regulatory environment and interest from investors, partners and customers. Yet even as companies are embracing a broad range of sustainability initiatives, they’ve been lagging when it comes to indirect emissions, or Scope 3, reporting.
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computing technology
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92%
3x
20%
of S&P 500 companies published sustainability reports in 2020
as many companies have adopted net-zero goals post pandemic than did in 2019
Scope 3 emissions comprise of a broad spectrum of indirect emissions from a company’s upstream and downstream activities, including purchased goods and services and logistics.
75%
on average of a company’s greenhouse gas emissions are Scope 3 emissions
In some industries Scope 3 far exceed scope 1 and scope 2 combined.
Scope 3
S1
S2
Scope 1, 2 and 3 emissions:
What is the difference?
Upstream activities
Reporting company
Downstream activities
Scope 1
emissions are a company’s direct emissions, such as those from its trucking fleet.
Scope 2
emissions result from the generation of the energy a company purchases.
Scope 3
Scope 3 emissions for the tech sector and financial services sector
emissions result from a company’s upstream and downstream activities.
92%
of Apple’s emissions are Scope 3
84%
700x
of Google’s were Scope 3 in 2021
Why companies are lagging in Scope 3 reporting?
A food and beverage company will have to obtain Scope 3 data from all of its ingredient suppliers and packaging partners, and end-of-lifecycle data from its customers.
A bank that lends to a transportation company will need to account for that company’s emissions.
Lack of data from
value chain partners
New entrants in the reporting field have a limited focus
Even if a company wants to report Scope 3 emissions, it can be hampered by the fact that its value chain partners don’t collect the necessary information.
There are several reasons why such reporting service providers have limited focus areas, including the difficulty of obtaining information and the fact that the heterogeneity of the Scope 3 subcategories makes it hard for them to amass expertise. But whatever the reasons, the effect is to normalize partial Scope 3 reporting.
The tightening of the Scope 3 regulatory landscape
The regulatory landscape is starting to change in a way that could compel companies to take Scope 3 reporting more seriously.
MENA
LAC
APAC
China
Japan
India
USA
EU
UK
With regulation increasing in many regions, public and private organizations of all sizes will need to be more proactive in their ESG reporting, to the point of taking on Scope 3 reporting. In addition, companies that don’t embrace ESG, including Scope 3 reporting, could face reputational risk and pushback from customers and employees. Public companies will have to answer to their investors, as well.
UK
In the UK (where ESG reporting has been mandatory for large businesses since 2022), the Streamlined Energy and Carbon Reporting and Financial Conduct Authority regulations encourage climate disclosure and Scope 3 emissions reporting.
How should companies prepare for this new reality?
1
2
3
Ensure a close partnership between CEO, CFO and chief sustainability officer.
Choose the right solutions provider.
Prepare for systems
integration.
Such a partnership will become vital as carbon accounting becomes more fundamental to company decision-making processes — something that informs and even drives them, rather than a nice-to-have that’s ultimately adjacent to them.
A CFO may well factor emissions data directly into decisions about capital expenditure and M&A, to give just two examples.
C02
Ensure a close partnership between CEO, CFO and Chief Sustainability Officer.
We increasingly see ESG reporting following a maturity similar to that of financial reporting. Consistent with that, new providers of emission management and reporting services will need to be integrated into company financial reporting systems just as financial reporting service providers were.
Now is the time for companies to prepare their tech stacks for this integration.
In searching for reporting solutions providers, companies should examine how effective they are in collating data from sources both external — vendors and other partners, customers and so on — and internal.
They should also determine how easy it will be to integrate a certain provider’s solutions into their tech stack. Flexibility is key.
Choose the right solutions provider.
Prepare for systems
integration.
Emerging technology frameworks to consider
AI models
AI models
Certain startups in the ESG reporting space are striving to make up for the informational deficiencies that hamper Scope 3 reporting by incorporating third-party data into the models they create for their client companies.
It’s a promising direction, but since their work is case-by-case, it’s not scalable. AI could make it so, and Bloomberg is on the job. It has developed an AI-powered model that includes a bottoms-up estimation and top-down estimation to forecast Scope 3 emissions in cases where data is limited.
Open data
Blockchain
Open data
The open banking framework allows financial services and other providers to utilize transaction and other data from banks to create novel products. Using an open data construct, multiple companies in the same value chain or industry can, in a permissioned manner, provide their emissions data to other companies and third-party data aggregators who will use them to model data for Scope 3 reporting purposes. The rise of an open data framework for Scope 3 reporting and the emergence of new data aggregators will promote data interoperability.
Blockchain
One way to ensure accurate Scope 3 data is to store it on the blockchain.
A blockchain ledger can function as an immutable source of ESG/Scope 3 information, holding companies accountable even as it makes data easy to access.
Open data
Blockchain
AI models
Even as governments and companies embrace sustainability, Scope 3 reporting has remained a blind spot, for a variety of reasons. But it may not be for much longer as the regulatory environment changes and as consciousness of how Scope 3 reporting can help in reaching net-zero goals spreads.
Happily, there are a number of steps that companies can take to put themselves in a better position to handle Scope 3 reporting challenges and prepare for a greener, more sustainable future.
Mastercard has a broad ESG portfolio, including its Consumer Carbon Calculator powered by fintech Doconomy, the Priceless Planet Coalition, the Data and Services ESG offering and its Sustainability Lab.
Mastercard's Start Path program also invests in ESG startups such as Carbon Neutral Club. It enables employees to calculate, offset and reduce their personal carbon footprints through employer-driven engagements.
Leveraging the reach of a large network and broad merchant base, Mastercard could play a role in Scope 3 reporting by providing centralized and secure data and deploying a network that enables its easy distribution.
Lack of data from
value chain partners
Lack of mandatory
reporting regulations
New entrants in the reporting field have a limited focus
In most jurisdictions around the world, reporting has been at least strongly encouraged and sometimes mandatory in cases where Scope 3 emissions were material. But interpreting what constitutes “materiality” is a subjective exercise, so companies have largely been able to navigate the regulatory waters in a way that makes their own reporting easier.
The DAX 40 index measures the performance of 40 of the largest companies on the German stock market. Only half of those 40 companies have reported on more than 4 out of the 16 categories of indirect emissions that Scope 3 comprehends. Eighteen percent of these companies have not reported Scope 3 emissions at all and another 15% have reported on fewer than 2 of the 16 categories.
A market for Scope 3 reporting services is emerging as part of the booming carbon management market and is projected to nearly double in value by the end of the 2020-2026 period. But the companies populating this market tend not to offer comprehensive services. They focus instead on niche Scope 3 sub-categories: some on supply-side/upstream activities, some on downstream activities, some on business travel emissions.
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Purchased goods
and services
Capital goods
Fuel and energy related activities
Transportation and distribution
Waste generated in operations
Business travel
Employee commuting
Leased assets
Company
Facilities
Processing of sold products
Use of sold
products
End-of-life treatment of sold products
Leased assets
Franchises
Investments
Company vehicles
Scope 1
DIRECT
Scope 3
INDIRECT
Scope 2
INDIRECT
Scope 2
INDIRECT
Scope 3
INDIRECT
C02
CH4
CH4
HFCs
PFCs
SF6
Lack of mandatory
reporting regulations
European Union
In May 2022, the European Financial Reporting Advisory Group released a draft of the European Sustainability Reporting Standards, which require companies to report all material emissions, including Scope 3 emissions, in metric tons or their CO2 equivalents. This draft should evolve into new EU regulations that will apply to large public companies starting in 2024 and to SMEs starting in 2026.
USA
The U.S. Securities and Exchange Commission released a proposal in March 2022 that would require all publicly traded companies to quantify and control all emissions, including Scope 3 emissions.
India
Scope 3 reporting remains optional. But an August 2022 government proposal outlines India’s commitment to cutting the country’s emissions intensity by 45% by 2030 and to a long-term goal of achieving net zero by 2070.
Japan
Japan’s Financial Services Agency (FSA) aims to make climate disclosures mandatory for a major fraction of public companies from April 2023. The FSA will require companies to disclose emissions aligned to the Task Force on Climate-related Financial Disclosures framework, which is largely prescriptive, providing leeway for companies to decide the extent and granularity of emission disclosure.
China
Most Chinese environmental disclosure regulations combine mandatory and voluntary measures as established by the Chinese Securities Regulatory Commission and the Ministry of Ecology and Environment (MEE). Recent updates to the disclosures that the MEE released in February 2022 confirm that a basic mandatory disclosure system is to be implemented in the next five years.
Asia-Pacific (APAC)
While traction is picking up in the Asia-Pacific region on emissions transparency and reduction, compared to other developed economies there is a significant ambition gap in meeting Paris Agreement goals. A recent CDP report confirmed that only 23% of approximately 4,000 companies surveyed in APAC reported in the most relevant Scope 3 emission categories and only 8% of these companies had net-zero targets in place by 2021. The APAC regulatory landscape is in the early stages of its evolution.
Latin American and the Caribbean (LAC)
Brazil and Mexico have developed national emissions programs based on the Greenhouse Gas Protocol. The programs provide guidance on holistic emissions and climate disclosures. Seventy companies in Brazil have opted into this program, participation in which is largely voluntary.
Middle East and North Africa (MENA)
Climate disclosure regulations have yet to gain traction in the MENA region. While some MENA governments have committed to net-zero goals, commitments from the corporate sector remain low. The number of companies providing climate-related disclosures to the CDP has increased over the last decade, but there remains significant scope for coverage growth, with less than 1% of MENA companies disclosing to the CDP. Given MENA’s prominent energy sector, which accounts for 75% to 95% of the region’s total emissions, Scope 3 reporting is vital.
Click on sections for more detail
Example
Example
3
11
Getting ready for new reporting regimes
Getting ready for new reporting regimes
In some industries Scope 3 emissions far exceed Scope 1 and Scope 2 combined.
Scope 3
S1
S2
Of a company’s greenhouse gas emissions are Scope 3 emissions, on average
75%
Sources:
1. Governance & Accountability Institute 2021 Sustainability Report
2. Bloomberg
3. CDP Estimate
4. Apple 2022 Environmental Report
5. Google 2022 Environmental Report
6. CDP Estimate
7. The number of companies committing to net zero goals has tripled from 2019 to 2022. In aggregate, these companies contribute about $11 trillion to the global economy.
8. Ibid
9. SEC press release
10. CDP report: "Rising to the challenge: How companies in Asia Pacific are preparing for the net-zero economy"
11. European Sustainability Reporting Standards
12. India GHG Program
13. PIB Government
12
13
1
2
8
7
UK
EU
USA
India
Japan
China
LAC
MENA
92%
84%
700x
Financial services' Scope 3 emissions are ~700 times greater than their direct emissions
6
Percentage of 13,000 companies that disclosed Scope 3 data in 2020
Scope 3 emissions are both underreported and significant in size and impact. Quantifying and reporting them would represent a step forward in the burgeoning movement toward a net-zero corporate sector. And yet relatively few companies seem to be motivated to do so.
4
5
9
10
Why companies
need to take
indirect emissions reporting seriously
— and how they can do it
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