Key Takeaways

• Carbon accounting is a regulatory and strategic necessity, with policies like the European Union’s Corporate Sustainability Reporting Directive (CSRD) and California’s SB 253 requiring emissions tracking. 
• Many companies track emissions inconsistently, underscoring the need for structured, repeatable carbon accounting to ensure accuracy and impact.
• Accurate carbon data drives efficiency and risk management, helping organizations reduce costs, streamline supply chains, and comply with climate regulations.
• Scope 2 emissions are increasingly challenging to quantify, especially for data centers and power-intensive operations. Grid-average emissions factors mask location-specific and time-specific variations that drive real procurement and siting decisions. Precise scope 2 accounting requires understanding which generators actually serve the load, when, and under what grid conditions.
• Scope 3 emissions have historically been a complex challenge, requiring better supplier engagement, standardized reporting, and expert guidance to support accuracy.

Carbon Accounting: More Than Compliance, a Strategic Advantage

Companies increasingly recognize the business value of reporting carbon emissions: it reduces regulatory risks, attracts sustainability-focused investors, enhances market competitiveness, and drives cost savings through efficiency. Transparent emissions reporting strengthens brand trust and aligns companies with global sustainability standards, ultimately turning climate accountability into a strategic advantage.

Yet, many companies struggle with incomplete and inconsistent tracking. According to the State of Corporate Climate Commitment, 80% of corporate professionals surveyed have tracked emissions at least once, but only 52% do so annually. Without a structured process and reliable data, businesses face compliance risks, financial penalties, and missed cost-saving opportunities. 

This guide provides a clear roadmap to effective carbon accounting, equipping businesses with the knowledge to navigate regulations, enhance data accuracy, and implement effective strategies for compliance and operational success.

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What Are the Benefits of Effective Carbon Accounting?

By embedding annual carbon accounting into operations, organizations can enhance sustainability efforts while achieving financial and strategic benefits. Key benefits include:

Enhancing Transparency and Accountability

By providing accurate and verifiable emissions data, companies can showcase corporate responsibility and build a foundation of transparency. Aligning with recognized standards like the GHG Protocol strengthens confidence among investors and regulators. As climate disclosure laws tighten globally, ensuring credible emissions reporting reduces regulatory risks and enhances stakeholder trust. This commitment to authenticity minimizes the risk of greenwashing and strengthens brand reputation.

Guiding Regulatory Compliance and Risk Mitigation

Businesses navigating evolving environmental regulations must proactively align with policies to avoid financial and legal risks. Mandated emissions reporting, under policies like the European Union’s Corporate Sustainability Reporting Directive (CSRD) and Carbon Border Adjustment Mechanism (CBAM) as well as California’s SB 253, ensures compliance and enhances corporate accountability. Staying ahead of these evolving requirements prepares businesses for future policy shifts and safeguards their long-term resilience.

Improving Operational Efficiency and Reducing Costs

By analyzing energy consumption patterns, organizations can identify operational inefficiencies, optimize supply chains, and implement cost-saving measures while reducing carbon emissions. For example, evo, an outdoor experiences company, collaborated with Relae (formerly Carbon Direct) to assess its carbon footprint. This analysis revealed opportunities to reduce emissions across facilities, products, and shipping. By promoting sustainable practices throughout their supply chain, evo enhanced both environmental performance and operational efficiency.

Building a Competitive Advantage in a Low-Carbon Economy

Building a competitive advantage in a low-carbon economy requires prioritizing emissions transparency and sustainability. Companies that integrate emissions transparency into their operations build stronger relationships with supply chain partners and meet consumer demand for responsible brands. Aligning corporate values with sustainability fosters long-term customer loyalty and enhances market positioning.

Driving Strategic Planning and Net-Zero Alignment

Setting and tracking net-zero commitments requires structured, data-driven carbon reduction roadmaps. Businesses that measure emissions annually are more likely to set public sustainability goals and take action. Carbon accounting supports clean energy transitions, fosters supply chain collaboration, and integrates carbon removal strategies to address residual emissions. By embedding emissions measurement into long-term planning, organizations facilitate resilience and profitability in an evolving business landscape.

Carbon emissions measurement correlates to climate action: 61% of companies that calculate their footprint annually have both set a public goal and begun working toward it.

What Is Carbon Accounting? The Basics You Need to Know

Carbon accounting is the systematic measurement, analysis, and reporting of an organization's greenhouse gas (GHG) emissions. Using standardized metrics like carbon dioxide equivalent (CO₂e), companies can assess emissions across operations and supply chains, identify high-impact areas, and set and track progress toward emissions reduction targets. When conducted annually, carbon accounting supports regulatory compliance, risk management, and decarbonization strategies essential for long-term sustainability.

The GHG Protocol is the most widely used framework for carbon accounting, setting the baseline for how organizations measure and report their emissions. It classifies emissions into three scopes: 

Keep in mind that scope 2 emissions are increasingly difficult to quantify using traditional methods, which fail to account for real-time grid fluctuations and locational energy variations. Cutting-edge, advanced carbon accounting methodologies now provide more precise tracking, particularly benefiting large power consumers like enterprise data centers and hyperscalers. 

Scope 3 emissions also continue to pose a great challenge, requiring extensive data collection and supplier coordination, complexities that are difficult to navigate without expert guidance.

The Corporate Carbon Accounting Process: A Step-by-Step Guide

The carbon accounting process involves systematically measuring, analyzing, and managing an organization’s greenhouse gas emissions across its operations, supply chain, or product life cycle. 

1. Collect emissions data across all three scopes (scope 1, scope 2, and scope 3).
2. Categorize and quantify emissions from each source to estimate the total impact. 
3. Verify data and report findings to promote compliance, accuracy, and transparency.
4. Develop and implement reduction strategies based on insights from the data.

Activity Data Versus Spend Data

Carbon measurement primarily relies on two data types: activity data and spend data.

• Activity data includes direct measurements reflecting the physical amount of an emitting source, such as fuel consumption (in liters or gallons) or travel distance (in kilometers or miles). It accurately represents emissions from a particular operational emission source and allows for measurable decarbonization strategies.
• Spend data serves as an alternative when activity data is unavailable. It estimates emissions based on financial expenditures related to goods, services, or travel. While less precise, it is useful for approximating scope 3 emissions, where direct measurement is often challenging.

Tips for Accurate Data Collection

Effective carbon accounting relies on seamless collaboration across departments, suppliers, and external data sources. Key strategies include:

• Stakeholder engagement: Finance, operations, procurement, and sustainability teams must coordinate to track and validate emissions data. Engaging suppliers is essential for capturing and reducing scope 3 emissions.
• Addressing data gaps: When data is unavailable, proxy data can be used to estimate emissions, but it should be a temporary solution while organizations work toward obtaining accurate, real-world data.
• Standardization and verification: Implementing consistent methodologies and third-party audits enhances the credibility of carbon reporting, building stakeholder trust.

By leveraging precise data, understanding emission scopes, and adopting structured data collection methods, organizations can create a transparent, science-based approach to carbon accounting and lay the foundation for meaningful climate action. 

Climate Standards Businesses Need to Know

Global standards and regulations define carbon accounting methodologies by establishing guidelines for how organizations set boundaries, measure, and disclose emissions. Several key frameworks and policies guide both the international and regulatory levels.

Guidance frameworks

GHG Protocol: The Foundation of Carbon Accounting

• The GHG Protocol is the most widely adopted framework for measuring and managing emissions across organizations globally.
• Developed by the World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD), it provides common standards for businesses, governments, and supply chains.
• Sector-specific guidance has been developed for industries such as energy, finance, manufacturing, and agriculture, which face stricter reporting requirements than service-based sectors.
• The GHG Protocol is currently undergoing its first major revision since its launch. Partnering with the International Organization for Standardization (ISO) to co-develop a consolidated corporate standard that merges the Corporate Standard, Scope 2 Guidance, Scope 3 Standard, and Actions and Market Instruments standard with ISO 14064-1. As of mid-2026, the effort is in active technical development, with a draft opening for public consultation targeted for mid-2027 and a final published standard expected by the end of 2028. Current standards stay in effect until that replacement is finalized, so nothing changes for reporting yet.

ISO 14064: Standardized Emissions Quantification and Reporting

• The ISO 14064 series, created by the International Organization for Standardization (ISO), offers detailed methodologies for greenhouse gas accounting.
• It includes guidelines for organization-level emissions quantification, reporting, and reduction projects.
• ISO 14064 serves as the foundation for independent verification and compliance with voluntary carbon markets, enhancing the credibility of emissions reduction projects.

Policies

EU CSRD: Expanding Mandatory Climate Disclosure

• The Corporate Sustainability Reporting Directive (CSRD) enforces detailed sustainability reporting requirements for companies operating in the EU.
• Following the EU's 2025 to 2026 Omnibus simplification package, CSRD's scope narrowed sharply. It now applies to roughly 5,000 large companies, with new thresholds of more than 1,000 employees and more than 450 million euros in net turnover (up from the original 250 employees and 50 million euros)
• In scope companies must still report scope 1, 2, and 3 emissions data aligned with the EU Taxonomy and European Sustainability Reporting Standards (ESRS).

California SB 253: State-Level Mandatory Emissions Disclosures

• California’s SB 253 Climate Corporate Data Accountability Act sets strict emissions reporting mandates within the US.
• It applies to companies with over US$1 billion in revenue doing business in California, requiring scope 1 and 2 emissions reporting by November 2026..
• CARB has said scope 3 reporting and third-party assurance requirements will be addressed in a subsequent rulemaking covering 2027 and beyond.

EU CBAM: Preventing Carbon Leakage and Promoting Decarbonization 

• The Carbon Border Adjustment Mechanism Requirements (CBAM) requires importers of specific carbon-intensive goods to disclose embedded emissions to prevent carbon leakage and promote global decarbonization by ensuring that domestic and foreign producers face comparable carbon costs. 
• During the transitional phase (2023–2025), importers were required to submit quarterly reports on embedded emissions. 
• As of 2026, they must purchase CBAM certificates to compensate for the carbon footprint of imported goods.

Although carbon accounting requirements vary across regions and industries, they are all fundamentally rooted in the principles established by the GHG Protocol and ISO 14064. As global regulations like the EU CSRD and state-level legislation evolve, organizations must proactively align with these stricter standards to mitigate regulatory risks and support compliance with emerging sustainability expectations.

What Are the Industry-Specific Challenges of Carbon Accounting?

Carbon accounting presents unique challenges across industries due to varying operational structures, emissions sources, and reporting requirements. While the challenges outlined below focus on financial services, data centers, and philanthropies, similar complexities exist across manufacturing, transportation, healthcare, and other sectors. Tailored strategies are essential to effectively addressing these complexities. 

Data Centers: Measuring and Reducing Scope 2 and 3 Emissions

Data center operators consume vast amounts of electricity making scope 2 emissions a major concern. In addition, data center developers and owners face significant scope 3 emissions from embodied carbon from the building materials and the IT hardware required to develop these assets. Effective strategies to reduce data center emissions include:

• Optimizing computing needs and power usage: Use real-time metering and AI-powered analytics to optimize electricity usage across time and locations.
• Procuring low-carbon electricity: Secure long-term access to compliant low-carbon electricity through power purchase agreements (PPAs) or high-impact renewable energy credits (RECs).
• Tracking life cycle emissions: To provide a comprehensive emissions assessment, account for embodied carbon in server manufacturing and end-of-life disposal.

Financial Services: Assessing Emissions From Investments and Portfolios

Financial institutions face significant challenges in evaluating scope 3 financed emissions from investments, loans, and asset portfolios. Key strategies to address these challenges include:

• Adopting industry standards: Frameworks like the Partnership for Carbon Accounting Financials (PCAF) can be used to standardize emissions calculations.
• Understanding asset level data: To accurately report on financed emissions, investors need visibility of emissions data, ideally at the company level.
• Prioritizing green investment strategies: Shift toward sustainable finance by integrating sustainability criteria and emphasizing green bonds or low-carbon funds or investments.
• Ensuring regulatory compliance: To enhance transparency, align with global disclosure frameworks like the International Sustainability Standards Board's (ISSB) IFRS S2 climate-related disclosure standard.

Philanthropies: Managing Emissions From Private Financing

Philanthropic organizations face challenges in tracking emissions across diverse funding activities, operational footprints, and investment portfolios. Effective strategies include:

• Assessing grantmaking impact: Many philanthropies support climate initiatives but may not track the carbon impact of grantees or funded projects. Establishing emissions metrics for grants can enhance transparency and effectiveness.
• Measuring operational emissions: While some philanthropies have relatively low direct emissions, travel, events, and office space still contribute to their carbon footprint. Implementing sustainable operations policies can help reduce emissions.
• Decarbonizing investment portfolios: Endowments and investment funds often hold assets with varying GHG emissions. Aligning investments with sustainability goals and engaging with asset managers on emissions reduction can drive impact.

Organizations across these sectors can enhance emissions transparency, improve sustainability efforts, and align with global climate goals by implementing industry-specific carbon accounting methods. 

Navigating Evolving Standards and Scope 2 Complexity

Carbon accounting standards are actively evolving. In October 2025, the GHG Protocol released two proposals for scope 2 accounting revisions, with final standards expected by 2027. The proposals shift toward hourly and regional renewable energy matching, moving away from today's annual, region-agnostic approach. They also introduce consequential methodology that calculates actual emissions displaced by renewable projects, which varies significantly by region.

For organizations with 2030 climate targets, timing matters. Existing long-term contracts are expected to be grandfathered in under new rules. Meanwhile, new renewable projects face interconnection delays of 3 to 5 years, and the US power grid is experiencing sustained demand growth driven largely by data centers. These pressures converge: power demand is rising while new clean electricity supply is constrained.

Navigating these changes requires understanding emerging methodologies and their strategic implications. See our companion pieces on Navigating Scope 2 Accounting Changes and Scope 2 Emissions Explained for detailed context.

Frequently Asked Questions

How long does carbon accounting implementation take?

Initial measurement typically takes 3 to 6 months, depending on data availability and organizational coordination. Starting with data you already have (utility bills, fuel records) accelerates the process. Scope 2 and scope 3 require more extensive work than scope 1, so actual timelines vary based on which scopes are your focus.

What are the biggest obstacles to getting accurate emissions data?
Data siloes across departments (finance, operations, procurement track separately). For scope 2, grid-average factors mask location- and time-specific variations that actually drive emissions. For scope 3, extensive data collection and supplier coordination are required. Seamless collaboration across departments is essential.

Do we need to measure all three scopes to start?
Yes. Organizations should measure all three scopes. Start where your business is most materially affected, but eventually measure all three for compliance and complete visibility into your emissions sources.

Key Takeaways

• Scope 3.1 emissions, purchased goods and services, can account for up to 67% of a company’s total carbon footprint, making them a critical category for measurement and action.
• Companies can reduce risk, meet stakeholder demands, and strengthen supply chain resilience by proactively managing scope 3.1 emissions.
• Relae empowers organizations to take meaningful action on scope 3.1 through science-based measurement, practical emissions management strategies, and deep supplier engagement.

What Are Scope 3 Emissions and Why Do They Matter?

Scope 3 emissions include all indirect greenhouse gas (GHG) emissions that occur across a company’s value chain. While scope 1 emissions are from directly owned or controlled activities, and scope 2 are indirect emissions from the generation of purchased electricity, heat, or steam, scope 3 emissions encompass upstream and downstream activities throughout the value chain. 

Within scope 3, there are 15 categories, including activities such as raw material extraction, purchased services, shipping, business travel, product use, and end-of-life treatment. Critically, scope 3 emissions usually make up the majority of a company's total carbon footprint. Across sectors, CDP finds supply chain emissions average 26 times a company's operational emissions, and in supply-chain-heavy sectors like apparel, the share exceeds 95%. 

Category 3.1 (purchased goods and services) is often the largest contributor. For many organizations, it can be as much as 67% of their total corporate footprint. Despite being outside a company’s direct operational control, scope 3 emissions are increasingly scrutinized by regulators, investors, and customers alike, making them essential to measure, manage, and reduce. 

What Is Included in Scope 3.1 Emissions?

Scope 3.1 emissions capture all cradle-to-gate emissions associated with products and services procured by an organization. These include emissions from the extraction of raw materials, energy usage, manufacturing processes, waste, and transport and travel up to the point of delivery to the reporting company. As such, the types of activities within this category are quite extensive and disparate. 

Examples of scope 3.1 items include:

• Raw materials (e.g., limestone, copper ore, lumber)
• Intermediate products (e.g., steel, electronic components, platform chemicals)
• Packaging materials
• Office supplies and equipment
• Professional services 
• Cloud computing and software services

The size of scope 3.1 emissions varies widely by industry. For example, a consumer goods manufacturer sourcing large volumes of physical products may see a larger share of emissions in this category than the supplier providing the raw materials. For data centers that run on very low-carbon electricity, equipment and construction can account for 40% of lifetime emissions. For many organizations that are service-based or contract out manufacturing, scope 3.1 can be the most significant emissions category.

What Is the Strategic Value of Scope 3.1?

While scope 3.1 emissions fall outside a company’s direct operational control, they are not beyond its influence. Addressing emissions from purchased goods and services may open up a range of strategic benefits:

• Innovation opportunities through lower-carbon materials and production processes.
• Enhanced supplier relationships and engagement on shared sustainability goals.
• Improved resilience and risk mitigation across supply chains.

By assessing and acting on scope 3.1 emissions, companies can drive meaningful reductions and catalyze change throughout the entire supply chain.

What Are the Methods for Calculating Scope 3.1 Emissions?

There are four methods to calculate scope 3.1 emissions based on the data collected. Each offers a different balance of speed, accuracy, and scalability.

1. The Spend-Based Method

This approach multiplies the amount of money spent on a good or service by an economic emissions factor (e.g., kg CO₂e per dollar spent). Most companies use this approach as a starting point but transition to more accurate methods as they advance in their sustainability journey.

Advantages

• Fast and scalable across categories
• Useful for initial hotspot identification
• Helps fill data gaps when activity data is unavailable

Limitations

• Lower accuracy, especially during periods of inflation or economic volatility
• Cannot reflect actual emissions reductions by suppliers
• Misalignment between price and emissions (e.g., high-cost items may not be high-emission)

2. The Average Data Method

This method uses average emissions factors for goods or services, based on industry datasets. For instance, industry life cycle assessments (LCAs) might be used to estimate the emissions associated with a kilogram of steel purchased.

Advantages

• More accurate than spend-based
• Suitable for companies refining emissions data to enable targeted reductions 

Limitations

• Lack of raw data granularity
• Geographic variation limited

3. The Supplier-Specific Method

The supplier-specific method is the most accurate approach and involves collecting actual emissions data directly from suppliers. This includes LCAs, environmental product disclosures (EPDs), product carbon footprints (PCFs), supplier emissions reports, or Environmental, Social, and Governance (ESG) reports.

Advantages

• High accuracy and granularity
• Builds engagement with suppliers
• Enables tracking of supplier improvements over time

Limitations

• Challenging to scale across many suppliers
• Data may be confidential, inconsistent, or incomplete
• Requires continuous updating of supplier information

4. The Hybrid Approach

Adopting a hybrid approach allows many companies to maximize their data collection efforts by applying the supplier-specific method for high-impact purchases and using average or spend-based methods elsewhere. This tiered approach enables efficient use of resources while maintaining data quality for critical emission sources.

Where Can You Find Scope 3.1 Data?

Data for scope 3.1 emissions typically resides in procurement and finance functions. Purchase orders, invoices, and supplier contracts often contain critical information such as volume, product category, and spend. However, collecting, organizing, and analyzing this data can be resource-intensive, especially for companies with complex and global supply chains. Data type and availability play a key role in determining the method used for calculating emissions, impacting the accuracy and ability to reduce emissions.

What Are the Challenges in Measuring Scope 3.1 Emissions?

As most organizations will attest, measuring scope 3.1 has many challenges, from resource constraints to data availability. As organizations intensify their climate commitments, they are increasingly confronted with a range of technical, logistical, and strategic barriers that make accurate measurement and consistent reporting difficult. Understanding these roadblocks is critical to developing more resilient and impactful scope 3.1 measurement practices. 

• Data availability and quality: Collecting high-quality data is often a bottleneck, with many organizations lacking the systems to track product-level or supplier-specific emissions. Without the proper tracking in place, emissions calculations rely on less accurate methods, making it difficult to reflect or meet reduction efforts.
• Supplier inconsistencies and allocation complexities: Even when suppliers share emissions data, the methodologies, boundaries, and underlying assumptions across them will vary widely. This adds an extra layer of difficulty to data aggregation. Additionally, the allocation of supplier emissions may vary based on the supplier’s chosen method, such as economic (based on spend and supplier revenue/emissions) or service-level (based on units purchased and supplier output/emissions). These inconsistencies can significantly affect reported totals, making it challenging to compare suppliers.
• Complex, multi-tiered supply chains: Upstream emissions can span multiple suppliers across different geographies and industries. Visibility often becomes cloudier beyond Tier 1 suppliers, making it difficult to account for emissions generated deeper in the value chain.
• Timing and synchronization: Aligning procurement, emissions calculation, and reporting cycles can be challenging. Delays in supplier disclosures or emissions factor updates can create reporting lags and misalignment.

Top Five Strategies to Reduce Scope 3.1 Emissions

Reducing scope 3.1 emissions requires balancing precise measurement with targeted action. This means identifying high-impact categories, collaborating with key suppliers, and harnessing available emissions data to improve accuracy and accountability. Here are five strategies organizations can use to start driving impact:

1. Prioritize key categories and suppliers: Not all purchases contribute equally to emissions. Conduct a hotspot analysis to identify the highest-emitting goods or services and prioritize the top suppliers for engagement. Consider prioritizing the share of emissions, the share of procurement spend, and the current methodology type. 
2. Engage suppliers and set expectations: Encourage suppliers to measure and disclose their emissions, invest in LCAs or PCFs, and set their own science-based targets. Collaborative initiatives, such as supplier engagement programs, can support progress.
3. Leverage readily available supplier reports: Many electronic companies, cloud providers, and industrial products provide detailed emissions data through EPDs, LCAs, and specific service emissions reports. For example, AWS and Google offer detailed emissions reports for data hosting and services. Leveraging these can help reduce uncertainty and improve accounting accuracy in software-heavy organizations. However, they should be utilized with caution, as some providers have faced scrutiny in 2026 for reporting efficiency gains without disclosing cloud-specific energy use or the growth in embodied hardware emissions behind it.
4. Identify opportunities for low-carbon inputs: The same reports that help improve reporting accuracy can also provide more detail on the material inputs of purchased goods. This level of information can enable organizations to pursue opportunities for lower-carbon inputs to reduce emissions.
5. Invest in centralized data systems: A centralized platform for carbon accounting data management can streamline emissions tracking, improve visibility, and enable scenario modeling. Several of the other strategies cannot be as effective without the right tools in place to manage this key information. 

Turning Complexity Into Opportunity

Tackling scope 3.1 emissions may feel daunting, but it’s also where some of the biggest climate opportunities lie. By investing in better data, fostering supplier collaboration, and integrating sustainability into procurement practices, companies can unlock innovation, resilience, and long-term value. Organizations that lead on scope 3.1 will not only meet emerging disclosure standards but will shape the low-carbon supply chains of the future.

Frequently Asked Questions

What are scope 3 emissions, and why do they matter?

Scope 3 emissions are all the indirect greenhouse gas emissions in a company's value chain, everything from raw material extraction and purchased services to product use and disposal. They matter because they're usually the majority of a company's footprint. They also fall outside a company’s direct control, which makes them the hardest to measure and the most scrutinized by regulators and investors.

What is included in scope 3.1 emissions?

Scope 3.1 covers the cradle-to-gate emissions of everything a company buys, i.e. all emissions generated up to the point of delivery. That includes raw materials, intermediate goods like steel and electronic components, packaging, office equipment, professional services, and cloud computing. It captures the supplier's extraction, energy use, manufacturing, waste, and transport. It does not include emissions from using or disposing of your own products, which sit in other scope 3 categories.

What are the methods for calculating scope 3.1 emissions?

There are four. The spend-based method multiplies spend by an emissions factor per dollar, which is fast, scalable, and the usual starting point. The average-data method applies industry emissions factors to physical quantities, like kilograms of steel. The supplier-specific method uses actual supplier data such as LCAs, EPDs, or product carbon footprints, and is the most accurate. Most companies land on a hybrid, the final method, which takes supplier-specific data for high-impact purchases and uses estimates elsewhere.

How can companies reduce scope 3.1 emissions?

Start with a hotspot analysis to identify where emissions are coming from. This will usually show that a small share of suppliers and categories drives most of the footprint. From there, engage those suppliers on measurement and targets, use supplier reports and EPDs to replace estimates with real data, and use that detail to identify lower-carbon inputs. Centralized carbon accounting data makes each of these repeatable rather than a one-off exercise.

Do AI data centers' hardware purchases count as scope 3.1 emissions?

Yes, for a data center operator, servers and chips are purchased goods, and therefore count in scope 3.1. 

Key Takeaways

• The GHG Protocol Corporate Standard and life cycle assessment (LCA) offer distinct frameworks for measuring electricity-related emissions, one for annual corporate reporting and one for detailed cradle-to-grave analysis, leading to different emissions results.
• Renewable energy certificates (RECs) are accepted under the GHG Protocol's market-based approach to reduce reported scope 2 and scope 3: category 3 emissions, but are not explicitly addressed in ISO LCA standards, where transparent disclosure is essential.
• Using both the GHG Protocol and LCA together, while recognizing their different scopes, boundaries, and purposes, can give organizations a more complete and strategic view of electricity-related emissions and decarbonization opportunities.

Electricity-Related Emissions: Why Measurement Methods Matter

In the era of AI-driven power demand, scrutiny over electricity-related emissions is intensifying. With this increased attention comes growing confusion around how to measure and report these emissions. The GHG Protocol Corporate Standard and life cycle assessment (LCA) are two widely used methods for measuring and reporting electricity-related emissions, but each follows its own complex and often incompatible, set of rules.

This piece will examine the differences between these approaches and answer common questions such as:

• What are the differences between the GHG Protocol Corporate Standard and LCA?
• Why do they result in different emissions for the same type and amount of electricity?
• Can renewable energy contracts reduce electricity-related emissions under both methods?
• When should you use each approach?

Both the GHG Protocol Corporate Standard and LCA are powerful tools that, if used in complementary ways, can help organizations identify emissions hotspots and develop more effective pathways for decarbonization.

What Is the GHG Protocol Corporate Standard?

The GHG Protocol Corporate Standard is a globally recognized framework for corporate entities to publicly report GHG emissions throughout their value chain. It divides emissions into three scopes:

• Scope 1: Direct emissions from owned or controlled sources, such as company-owned vehicles, on-site fuel consumption, or industrial processes.,
• Scope 2: Indirect emissions from the generation of purchased electricity, heat, steam, or cooling. These emissions are generated off-site, but result from an organization's energy consumption.
• Scope 3: Indirect emissions across an organization's value chain. Scope 3 is divided into 15 categories, including a company's supply chain activities, business travel, employee commuting, investments, and product life cycle emissions.

This piece focuses on emissions associated with electricity consumed by a reporting entity. These electricity-related emissions primarily fall under scope 2 and scope 3: category 3 (fuel- and energy-related activities, or FERA).

Scope 2: Electricity Generation Emissions

Scope 2 emissions account for the generation of electricity a company purchases or uses. Hypothetically, if a company were powered by a single solar project, it would report zero scope 2 emissions. In reality, a company is powered by a combination of power generation assets and must report them under scope 2 emissions. These emissions can be reported using two methods:

• Location-based method: Reflects the average emissions intensity of the local electricity grid where the consumption occurs. This approach is mandatory under various reporting frameworks and does not take into account a company's procurement choices.
• Market-based method: Reflects an organization's actual procurement decisions and energy-sourcing strategies. It accounts for specific contracts, such as power purchase agreements (PPAs), renewable energy certificates (RECs), and green tariffs, which allow businesses to claim lower emissions from their purchased electricity.

Scope 3: Category 3 FERA

Scope 3: category 3 FERA reports on non-generation electricity emissions associated with:

• Upstream emissions: Emissions associated with the production and transportation of fuels needed for electricity generation
• Transmission and distribution losses: Emissions associated with the loss of electricity while delivering it from the generator to the consumer.

The GHG Protocol Corporate Standard does not include emissions associated with the manufacturing, construction, and end-of-life phases of electricity generation equipment; however, some datasets used for reporting may include manufacturing emissions. While scope 3: category 3 guidance may not require these emissions to be included, if possible, companies reporting on their electricity-related emissions should include these additional sources of emissions  in order to more completely represent their total emissions impact. The GHG Protocol Scope 2 Guidance allows for the reduction of some of the reported scope 3 FERA emissions by contracting renewable energy (see Appendix B).

What is an LCA?

An LCA is a systematic method used to quantify the environmental impacts of a process, product, or project throughout its full life cycle. A life cycle includes everything from raw material extraction ("cradle") to manufacturing/production ("gate") through disposal ("grave").

LCAs primarily follow a standard published by the ISO organization (ISO 14040/14044). The ISO standards establish industry-wide rules for which processes are included and how to assign environmental burdens to products.

An LCA can be used for any product, process, or project, and can estimate multiple different environmental impacts (i.e., climate change, human health, ecotoxicity, eutrophication, ozone depletion).

Electricity-Related Emissions Can Be Different Using the GHG Protocol and an LCA

The GHG Protocol Corporate Standard and an LCA (as per ISO standards) generally include different life cycle stages of electricity use when estimating GHG emissions. Therefore, the approaches can result in different reported emissions.

Key Differences in Reporting Electricity-Related Emissions

The GHG Protocol Corporate Standard includes emissions in the following phases:

• Generation (scope 2)
• Transmission and distribution losses (scope 3: category 3)
• Fuel, if applicable (scope 3: category 3)

A “cradle-to-grave” LCA considers emissions from all activities associated with power generation, including:

• Manufacturing
• Construction
• Generation
• Fuel, if applicable
• Use-phase, if applicable
• End-of-life

Use-phase electricity-related emissions are emissions generated by electricity-consuming equipment used or sold by the reporting company (representing additional scope 1 or scope 3 emissions, respectively). Examples include sulfur hexafluoride (SF6) emissions from electrical transformers or refrigerant leakage from air conditioners with high global warming potential. Please note that both the ISO and GHG Protocol Corporate Standard provide guidelines for reporting these emissions. However, due to the equipment-specific nature of these emissions, they are excluded from the following table. The table compares electricity-related emissions associated with different electricity sources using the GHG Protocol Corporate Standard approach and the LCA approach.

Reporting Electricity-Related Emissions

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* US average transportation and distribution loss rate (4.2%) times US average grid carbon intensity (410 gCO₂e/kWh). Note: gCO₂e/kWh = grams of carbon dioxide equivalent per kilowatt-hour. Source: GREET 2024 (US grid average. 10% fuel- and energy-related activities; 1% construction, facilities, maintenance, and end-of-life; 89% fuel combustion).

Reducing Electricity Emissions with Renewable Energy

Renewable Energy Mechanisms Under the GHG Protocol

The GHG Protocol Corporate Standard allows companies to contract for renewable electricity as a mechanism to reduce reported emissions. The GHG Protocol Corporate Standard defines allowable energy contracts that can be used to reduce emissions associated with electricity consumption (market-based reporting).

In North America, one of these allowable contracts is RECs, each of which represent one megawatt-hour of renewable generation. Analogous instruments used in other locations, such as Guarantees of Origin in Europe and green electricity certificates in China, are also permissible under the GHG Protocol Corporate Standard.

RECs were developed as a contractual mechanism for renewable electricity in response to the fundamental structure of "a power grid." In a power grid, it is impossible to link a single generator to a single load. Power is injected at a point in the grid and withdrawn at a different point in the grid; there is no traceable pathway.

RECs were created to track the attributes of electricity generation entering into a power grid for the entity that consumes the power at a different point. The GHG Protocol Corporate Standard allows buyers to claim exclusive use of renewable electricity with RECs even if they are actually consuming a mixture of electricity from the grid.

Renewable Energy Mechanisms Under the LCA ISO Standard

The ISO 14040 standard does not address the use of renewable electricity contracts. However, the ISO 14044 standard provides the following guidance:

"When determining the elementary flows associated with production, the actual production mix should be used whenever possible, in order to reflect the various types of resources that are consumed. As an example, for the production and delivery of electricity, account shall be taken of the electricity mix, the efficiencies of fuel combustion, conversion, transmission and distribution losses."

It does not explicitly define whether RECs can or cannot be used in the determination of the "actual production mix." In the event an organization does procure a renewable energy contract to reduce the emissions reported within the LCA, it should disclose that clearly in order to communicate the impact of the contract on the carbon intensity of the LCA with and without the use of RECs.

Powerful Tools for Different Use Cases

The GHG Protocol Corporate Standard and LCAs following the ISO Standard are both powerful tools that can provide insight into emissions associated with electricity use. The GHG Protocol Corporate Standard allows companies to use a standardized framework to report emissions associated with electricity use and interventions on an annual basis. The LCA ISO standard is a detail-driven analysis that allows a deep dive into specific processes, projects, or products. This detailed analysis allows for deeper insights into areas where a company may have more ability to address specific interventions for emission hot spots. Using these tools together, while understanding the boundaries of each, can provide companies with a more effective and impactful approach to decarbonization.

Frequently Asked Questions

What are the differences between the GHG Protocol Corporate Standard and LCA? 

The GHG Protocol is an annual corporate reporting framework covering scope 2 (generation) and scope 3: category 3 (transmission and distribution losses, fuel), while a cradle-to-grave LCA is a detailed analysis governed by ISO 14040/14044 standards that also includes manufacturing, construction, use-phase, and end-of-life emissions. LCA can also be applied to any product or process and multiple environmental impacts, not just greenhouse gas emissions.

Why do they result in different emissions for the same type and amount of electricity? 

They include different life cycle stages. The GHG Protocol excludes manufacturing, construction, and end-of-life emissions of generation equipment, while an LCA includes them.

Can renewable energy contracts reduce reported electricity-related emissions under both methods? 

Under the GHG Protocol, renewable energy contracts (e.g., RECs, PPAs) are explicitly allowed to report zero market-based scope 2 emissions, though scope 3 FERA emissions remain. Under ISO LCA standards, these contracts aren't explicitly addressed. Organizations may choose to apply them, but should transparently disclose LCA results both with and without the contract's impact.

When should you use the GHG Protocol vs an LCA? 

Use the GHG Protocol for standardized, annual corporate-wide emissions reporting and tracking procurement interventions; use an LCA for a detailed, process- or product-specific deep dive to identify specific emissions hotspots. Relae recommends using both together for a more complete, strategic view of electricity-related emissions.

Key Takeaways

• Scope 2 emissions (indirect emissions from energy use) are increasingly critical to address. With surging electricity demand, especially from data centers, scope 2 is a growing share of corporate emissions and a priority for decarbonization.
• Approaches to scope 2 accounting are evolving—and formal changes are now on the table. Both location-based and market-based methods remain accepted under the Greenhouse Gas Protocol. Still, the Protocol's recently closed public consultation proposes more granular approaches, including 24/7 power and carbon matching, that would better reflect the realities of modern power markets.
• Proven decarbonization levers, such as reducing energy use, entering power purchase agreements, procuring green tariffs, and buying high-quality renewable energy certificates, are already available and impactful. Decarbonization, not just measurement, must be the goal. Companies don’t need to wait to decarbonize. 

Accounting for Indirect Emissions From Energy Use

As businesses and organizations strive to reduce their environmental impact, carbon accounting has become an essential tool for tracking and managing greenhouse gas (GHG) emissions. Carbon accounting helps organizations measure, report, and mitigate their emissions across various activities. A key framework for categorizing these emissions is the Greenhouse Gas Protocol (GHG Protocol), which classifies emissions into three scopes:

Each scope presents unique challenges and opportunities for reduction. Among them, scope 2 emissions are particularly significant because they stem from purchased energy, which is often generated using fossil fuels. However, numerous reduction mechanisms exist today to help organizations eliminate these emissions, such as improving energy efficiency in order to use less energy, and transitioning to renewable energy sources through market-based mechanisms. Understanding scope 2 emissions is crucial for businesses looking to contribute meaningfully to the global energy transition and achieve sustainability goals.

What Are Scope 2 Emissions?

Scope 2 emissions refer to indirect GHG emissions associated with the consumption of purchased energy. Unlike scope 1 emissions, which result from direct fuel combustion, scope 2 emissions arise from the generation of electricity, steam, heat, or cooling that a company procures from external sources.

The primary sources of scope 2 emissions include:

Purchased electricity: When businesses buy electricity from a utility provider, the emissions from power plants that generate this electricity are classified under scope 2.

Purchased heat, steam, and cooling: Some companies purchase heat, steam, or cooling services instead of generating them on-site. These services often come from centralized facilities that may rely on fossil fuels, thereby contributing to scope 2 emissions.

What sets scope 2 emissions apart from other scopes is the presence of market-based mechanisms that offer multiple pathways for organizations to reduce their carbon footprint. Unlike scope 1, where emissions reductions often require technological shifts or operational changes, scope 2 reductions can be achieved through strategic procurement decisions. The transition to renewable energy sources is an essential component of sustainability strategies, setting the stage for a broader energy transition across industries and economies.

How Are Scope 2 Emissions Measured Today?

The GHG Protocol currently outlines two primary approaches for calculating scope 2 emissions: the location-based method and the market-based method.

Location-Based Method

The location-based method calculates emissions for electricity consumption based on the average emissions intensity of the grid where the energy consumption occurs. This approach is mandatory under various reporting frameworks and does not take into account a company’s procurement choices.

• Relies on grid averages: Emissions are calculated based on regional grid emissions factors rather than specific energy purchases.
• Time-delayed data: Since grid emissions factors are typically updated annually, this method may not reflect real-time energy sourcing changes.
• Limited control: Companies using this method have less direct influence over their reported emissions, as they depend on the overall energy mix of their region.

Market-Based Method

The market-based method, on the other hand, reflects an organization’s actual procurement decisions and energy-sourcing strategies. It accounts for specific contracts, such as power purchase agreements (PPAs), renewable energy credits (RECs), and green tariffs, which allow businesses to claim lower emissions from their purchased electricity.

• Reflects company choices: Emissions calculations take into account contractual agreements for renewable energy purchases.
• Mechanism for electricity transition: Encourages organizations to invest in low-carbon electricity options and actively support the transition to renewables.
• Multiple reduction options: Companies can reduce their scope 2 emissions through a portfolio of mechanisms like PPAs, RECs, and green tariffs, making this method a flexible and strategic tool for decarbonization.

While market-based mechanisms provide flexibility in reducing scope 2 emissions, they also highlight the need for more precise and updated carbon accounting methodologies. For example, some decarbonization strategies, such as time-shifting energy consumption to better match renewable generation, are not accounted for under these methods. This and other limitations mean that the traditional methods outlined in the GHG Protocol are increasingly seen as outdated in an era of rapid changes in energy generation and grid dynamics. As a result, the market is shifting toward more advanced power emission accounting methodologies that provide a more accurate reflection of emissions associated with electricity use.

Proposed Changes to the GHG Protocol Scope 2 Guidance

The current GHG Protocol Scope 2 Guidance provides a market-based instrument methodology, originally designed in the early 2000s, that allows US-based companies to procure renewable energy at any point within a year from anywhere in North America and apply it to any of its annual electricity consumption within that same year. This methodology, as written, allows for a potentially significant mismatch of “emissions caused” (by consuming electricity) versus “emissions avoided” (by generating renewable electricity) in that it does not account for any of the realities of electric grids and generators, which vary significantly over different regions, seasons, and time of day. 

In response to this, the GHG Protocol Scope 2 Guidance is currently undergoing a revision process, which will include how emissions associated with electricity consumption are calculated. A focus of the revision process is on how to better account for the real emissions associated with a corporate’s electricity consumption, and more impactful ways of mitigating them through market-based instruments and other approaches. Advanced power emission accounting methodologies, such as 24/7 power matching and carbon matching, are being explored as ways to better represent the GHG emissions associated with electricity consumption. 

• 24/7 power matching emphasizes matching electricity consumption with an equivalent amount of renewable energy production on an hourly basis.
• Carbon matching emphasizes measuring the emissions impact of incremental electricity consumption or production at a specific time.

These emerging methodologies propose a shift toward more granular temporal and region-specific matching, which could require companies to rethink their emissions reporting approach and explore more advanced tracking tools. They may also introduce new strategies beyond market-based instruments for reducing scope 2 emissions, such as time-shifting energy consumption.

As power grids continue to decarbonize and new digital tools emerge, businesses will need to adapt to these evolving methodologies to remain compliant, enhance sustainability strategies, and achieve meaningful reductions in emissions. Companies that proactively integrate advanced power emission tracking into their carbon accounting strategies will be better positioned to lead in the transition to a low-carbon economy.

How to Reduce Scope 2 Emissions

The GHG Protocol provides multiple mechanisms for reducing scope 2 emissions, allowing organizations to shift their energy consumption toward lower-carbon alternatives. These include:

• Reducing energy consumption: Improving energy efficiency in operations can significantly lower electricity use. In some cases, this involves capital investments in more energy-efficient equipment, but in other cases, it can be based on operational changes such as reducing unnecessary lighting, HVAC, and other services during non-working hours. (Electrification efforts, such as shifting from fossil fuel-powered systems to electric alternatives, may actually increase scope 2 emissions, but this can ultimately reduce overall emissions by correspondingly decreasing scope 1 emissions and allowing for renewable energy procurement.) 
• RECs: Companies can purchase unbundled RECs (emissions “attributes” separated from the actual electricity product) to offset emissions associated with purchased electricity. While there has been criticism of RECs due to their significant range in quality, high-quality RECs are available, which may include ensuring regional matching, financial additionality, on-line date additionality, or tighter temporal generation to consumption matching. The use of high-quality unbundled RECs is the most accessible and realistic option for most smaller-scale companies to address scope 2 emissions. 
• On-site generation and co-location: Installing on-site renewable energy generation, such as solar panels, allows companies to directly offset their electricity consumption from the grid. In some commercial settings, such as companies using leased real estate or co-located data centers, partnering with facilities that prioritize renewable energy procurement can help reduce scope 2 emissions for the facility owner while the facility occupant reduces scope 3 emissions. 
• PPAs: Entering into long-term contracts with renewable energy providers ensures companies receive electricity from clean energy sources while supporting the expansion of renewable generation capacity. PPAs are available with standardized contract terms, and some service providers will aggregate demand from multiple smaller companies to reach the minimum required amount for typical PPA contracts. Hedging products are also available to reduce market risks.
• Green tariffs: Many utilities offer green tariffs that enable businesses to purchase renewable energy directly through their electricity provider, often at a premium but with lower emissions impact. For many smaller companies, this is a more viable approach than a PPA with a single renewable generator.

By adopting a combination of these strategies, businesses can significantly lower their scope 2 emissions while aligning with broader sustainability goals and regulatory requirements. The path to decarbonization requires proactive investment in cleaner energy sources, efficient consumption practices, and leveraging market-based instruments to drive the transition toward a low-carbon future.

Why Does Reducing Scope 2 Emissions Matter?

Reducing scope 2 emissions is the underpinning of decarbonizing the power sector and enabling the global energy transition. In 2025, S&P reported that corporate buyers added 15.2 GW of renewable capacity in the US, up from 9.1 GW in 2024, illustrating the growing impact of the corporate sector on the electricity grid. Cleaner grids translate to lower emissions for all energy users. Organizations that actively reduce their scope 2 emissions can contribute to decreasing demand for fossil fuel-based electricity and accelerate the deployment of renewable energy infrastructure.

For companies that own and operate data centers, this transition is especially important. AI data centers consume large amounts of electricity, and their reliance on purchased power makes them a significant source of scope 2 emissions. Since many businesses rely on third-party data center services, reducing emissions from these facilities also helps lower scope 3 emissions across industries. Corporates can influence data centers by requiring that they have a clear and explicit low-emission power strategy in place before procurement.

Beyond direct corporate benefits, reducing scope 2 emissions has a tangible long-term impact on power grids. Increased investment in renewable energy procurement sends a strong market signal, encouraging utilities and developers to expand clean energy projects. As more companies commit to sourcing renewable energy, the overall mix of grid power shifts, making low-carbon electricity more accessible and reducing reliance on fossil fuel-based generation. Ultimately, widespread corporate action in scope 2 emissions reduction supports the broader decarbonization of power markets and strengthens global climate commitments.

Frequently Asked Questions

Will RECs (renewable energy certificates) still count toward scope 2 reductions under the GHG Protocol's proposed changes?

Under the current Scope 2 Guidance, yes—RECs remain a valid market-based instrument. The proposals from the GHG Protocol's recent consultation range from retaining market-based accounting with stricter quality criteria to restructuring how instrument-based claims are reported altogether, and nothing is final until the revised standard is published. What's clear is that scrutiny is rising, particularly for unbundled RECs with weak temporal or geographic connection to a company's actual consumption, so prioritizing high-quality RECs now is the best way to future-proof a procurement strategy.

How would the proposed hourly and regional matching requirements affect companies that rely on unbundled RECs today?

Hourly (24/7) and regional matching would require renewable generation claims to line up much more closely with when and where a company actually consumes electricity. Companies relying on annually matched, unbundled RECs sourced from distant grids would likely see their reported market-based emissions rise under such requirements. The practical preparation is to start collecting more granular (ideally hourly) consumption data and shift toward RECs and contracts with tighter regional and temporal matching.

What's the practical difference between location-based and market-based scope 2 accounting, and will that distinction survive the GHG Protocol's revision?

The location-based method calculates emissions using the average emissions intensity of the local grid, regardless of procurement choices, while the market-based method reflects a company's actual contracts, such as PPAs, RECs, and green tariffs. The consultation explored options from strengthening the criteria for market-based claims to reporting emissions and market instruments in separate, complementary statements. Both concepts will exist in some form, but companies should expect the requirements behind market-based claims to tighten.

When is the new Scope 2 Guidance expected to take effect, and what should companies do now to prepare?

Per the GHG Protocol's July 2026 development plan, a draft of the revised consolidated Corporate Standard is expected for public consultation in 2027, with a final published standard currently estimated for late 2028, and adoption timelines will follow publication. Companies should take action now. Energy efficiency, PPAs, green tariffs, and high-quality RECs reduce real emissions under any accounting regime. Building hourly consumption tracking and auditing the quality of existing REC portfolios now will make any future transition smoother.

Key Takeaways

• The GHG Protocol's Actions and Market Instruments (AMI) proposal introduces a four-statement reporting framework that will give companies an official place to report carbon dioxide removal (CDR), book-and-claim environmental attribute certificates (EACs), and financed reductions, actions that cannot currently count toward scope 1, 2, or 3 emissions reporting.
• The AMI proposal’s four-statement framework will put current emissions and mitigation efforts side by side in the same report, in the same units, giving sustainability teams a clear, defensible way to make a business case for every major decarbonization investment.
• A full draft standard is expected in 2027/2028. Companies that audit their portfolios against emerging quality criteria and engage now will have time to identify gaps and be best positioned when the standard takes effect.

What Problem Does the AMI Proposal Solve? 

Companies that have purchased carbon dioxide removal (CDR) credits, invested in book-and-claim environmental attribute certificates (EACs) for low-carbon materials, or funded a carbon capture and storage (CCS) project outside of their value chain have probably heard some version of the same question from their board, employees, or investors: "Where does this show up in our GHG Protocol Scopes?" Until now, the answer has been: it doesn’t.  

The current GHG Protocol Corporate Standard was built around a single organization’s emissions inventory. It has no recognized home for CDR, EACs for materials, or financed reductions that occur outside of a company’s operational boundaries (they must be “reported separately”). Companies making real climate investments, therefore, have had no standard way to show it within the Corporate Standard.

The GHG Protocol's Actions and Market Instruments (AMI) proposal aims to fundamentally change that.

What Is the AMI Proposal's Four-Statement Framework?

The GHG Protocol's AMI proposal will replace the single corporate inventory with four distinct Statements, all housed within a single GHG Report:

• Statement 1: A company’s traditional GHG inventory, including operational emissions across scope 1, scope 2 (location-based only), and scope 3.
• Statement 2: Market-based emissions accounting across scopes 1, 2, and 3 using EACs for energy, materials, and other purchased goods. While this is well established for electricity, it will be the first time that similar book-and-claim arrangements for low-carbon steel, concrete, sustainable aviation fuel (SAF), and renewable natural gas can be directly recognized.
• Statement 3: Beyond-value-chain mitigation and CDR. This is the reporting home for CDR credits, superpollutant credits, and financed reductions that mitigate emissions outside a company’s value chain.
• Statement 4: Co-benefits and additional climate impacts, capturing non-GHG benefits arising from corporate action and value that do not fit neatly into emissions accounting.

This change is more than just a rearrangement of reporting - it’s a fundamental expansion of scope. The introduction of Statements 2 and 3 will allow companies to report their mitigation activities in tonnes of CO₂e - the same unit as their emissions. For the first time, a company will be able to show its emissions and its climate investments side by side, in the same language, in the same report.

Why Does This Matter Now?

Today, companies investing in CDR, book-and-claim EACs (other than electricity), and financed emissions reductions face a persistent credibility gap. The investments are real. The climate impact is real. However, since no recognized reporting framework captures them, they are functionally invisible within corporate disclosures. This makes it harder to justify the spend internally and harder to communicate the value externally.

The AMI framework will remove that barrier across every major decarbonization category:

• A company purchasing a book-and-claim EAC for the low-carbon attribute of low-carbon concrete or steel would report the carbon intensity benefit in Statement 2 under scope 3.1. Statement 2 is the appropriate reporting location, rather than Statement 1, because the physical low-carbon concrete/steel product is not actually used by the company.
• An airline or corporate traveler using SAF via a book-and-claim arrangement could report the emissions benefit in Statement 2. Similarly, the airline could now report biogenic emissions from SAF if applicable in Statement 2, scope 1. Corporate travelers would report improvements in Statement 2, scope 3, category 6. Since the SAF does not physically enter the airline’s planes, the benefit is reportable only in everyone’s Statement 2 reports. If the airline can prove physical delivery of SAF onto its airplanes, then the benefits are shifted into everyone’s Statement 1 reports.
• A technology company funding a third-party carbon capture and storage project that receives verified reduction credits would report them in Statement 3, because the CCS project is outside of the technology company’s value chain and the technology company is not buying any goods or services from the CCS project. The third party that operates the CCS project would report lower scope 1 emissions in Statement 1 than they did pre-CCS, since the project impacts their direct emissions.
• A company buying CDR credits from CDR projects outside of their own value chain would report the removals in Statement 3, directly alongside the company’s Statement 1 and 2 emissions. This differs from the previous example because the company is not funding a project; it is buying a service - a CDR credit.

The practical effect will be significant. When clients ask whether a given investment "counts" under the GHG Protocol, the answer will shift from "probably not" to "yes, and here is which statement it belongs in."

What Does This Mean for Hard-to-Abate Sectors?

For sectors like cement, steel, chemicals, shipping, and aviation—where full decarbonization will be extremely challenging—the AMI proposal’s framework offers something that has not previously existed: a multi-faceted reporting strategy.

Companies in these sectors will be able to combine Statement 2 (EAC-based carbon intensity swaps for purchased goods) with Statement 3 (financed reduction credits) to demonstrate near-term progress, while long-term abatement technology matures. A cement buyer, for example, would procure low-carbon cement EACs under a book-and-claim arrangement and report the emissions benefit in Statement 2, while simultaneously funding a CCS project and reporting the resulting reduction credits in Statement 3.

For data centers and large power consumers, the framework adds a new layer to existing scope 2 electricity strategies: the ability to report the embodied carbon benefits of low-carbon materials used in construction and infrastructure, via Statement 2. Lower-carbon natural gas for power procured with EACs would also now be reportable in Statement 2.

For financial institutions and asset managers, the new statements create a richer disclosure environment for both internal reporting and structuring sustainability-linked financial products tied to Statement 2 and 3 performance.

How to Prepare Now

A full draft standard is expected in 2027/2028. Between now and then, the GHG Protocol will define the eligibility and quality guardrails that determine what activities qualify for Statements 2 and 3. Those criteria will matter enormously: they will shape which CDR credits, EAC programs, and financed reduction projects meet the bar for official reporting recognition.

Companies should not wait for final rules to begin preparing. Here are the most important steps to take now:

• Review existing portfolios against the emerging quality criteria for Statements 2 and 3. Not every credit or EAC program will qualify, and identifying the gaps early creates time to act.
• Map current decarbonization investments to the four statements. This exercise alone will reveal reporting opportunities and gaps that are not visible under the current single-inventory framework.

Frequently Asked Questions

What is the AMI proposal, and how does it work? 

The GHG Protocol’s Actions and Market Instruments (AMI) proposal would allow organizations to report: their emissions (statement 1); their market-based emissions across all scopes (statement 2); GHG emissions reductions, avoidance, and removals resulting from their actions (statement 3); and other relevant metrics (statement 4). 

How does AMI compare to the TCAT and/or AIM framework? 

The AMI proposal is very similar to the Task Force for Corporate Action Transparency (TCAT) Mitigation Action Accounting and Reporting Guidance and the Advanced and Indirect Mitigation (AIM) Standard & Guidance. The AMI standard is not finalized, but many concepts from TCAT and AIM (including sector association tests) could be included in the final standard.

Can any climate action really count for the AMI proposal? 

As of September 2026, the AMI standard is not finalized. However, if the final standard adopts the proposed structure, then any verified, high-quality climate action is reportable. Look for guidance from the GHG Protocol to determine verification and quality requirements.

Key Takeaways

• Larger power users are securing behind-the-meter (BTM) power to bypass grid constraints, pairing data centers with third-party-owned generation assets that deliver electricity through a private line rather than the grid.
• BTM power arrangements can create confusion about electricity emissions classification: the power users neither own the generating asset nor purchase electricity from the grid, leading some to misclassify those emissions as scope 3 in their corporate GHG inventories. But the GHG Protocol's Corporate Standard is clear: BTM electricity emissions belong in scope 2.
• Misclassifying BTM emissions can create reputational and regulatory risk. Relae can help organizations get this right before the contract closes.

Why Large Power Users Are Turning to Behind-the-Meter Power

Large power users are consuming more electricity due to data center growth and are looking to add capacity faster than the grid can support, which is having a direct impact on corporate emissions. For example, between 2020 and 2024, Microsoft’s location-based scope 2 emissions rose 130%, and Google’s rose 92%, driven almost entirely by soaring electricity demand from AI infrastructure. 

To bypass grid congestion and long interconnection queues, many are turning to behind-the-meter (BTM) power. It’s a pragmatic solution to a real supply problem, but it’s opening an urgent carbon accounting question: when the BTM asset is owned and operated by a third party, where should we account for those emissions?

There has been some confusion that has resulted in companies pursuing an interpretation that would place those emissions in scope 3. The GHG Protocol’s Corporate Standard says otherwise, and the stakes of getting this wrong are high.

What Is Behind-the-Meter Power Generation?

Behind-the-meter refers to electricity generated on the power consumer’s side of the utility meter, bypassing the grid, and typically located on or near the site where the power is consumed. 

In most BTM arrangements for a data center, a third-party developer builds and operates a generation asset, such as natural gas, geothermal, or renewable energy, and delivers electricity directly to the facility through a private transmission line. There is no utility meter, no grid connection, and no standard energy invoice. 

This structure allows companies to access large, reliable blocks of power without waiting years for grid interconnection approvals. Since the company does not own or operate the generation asset and is not purchasing electricity through a conventional utility relationship, this arrangement has created some uncertainty around how to account for the associated emissions. 

Can BTM Electricity Emissions Be Classified As Scope 3?

In this scenario, no. The GHG Protocol's Corporate Standard is unambiguous: BTM electricity emissions belong in scope 2, not scope 3. Yet, some companies have been confused about this classification.

There is broad agreement that since the power users do not own or operate the generating asset, those emissions do not belong in scope 1. Divergence starts when we consider that the company is purchasing BTM power, i.e., not from the grid. Since no electricity is acquired from the grid, some argue that rather than accounting for these emissions in scope 2, they are better placed in scope 3, category 8: emissions from leased assets. 

The appeal is obvious for BTM power consumers. Scope 3 emissions face less scrutiny from investors, auditors, and regulators who focus most of their attention on scopes 1 and 2. Classifying BTM emissions as scope 3 would reduce near-term pressure to act. However, the GHG Protocol is unambiguous in its stance.

What the GHG Protocol Actually Says

The GHG Protocol’s Scope 2 Guidance states that “organizations must quantify emissions from the generation of acquired and consumed electricity, steam, heat, or cooling (collectively referred to as ‘electricity’).” The method of delivery, whether grid or BTM, does not change the classification. 

If a company consumes electricity from a BTM source, the emissions from generating that electricity belong in scope 2. Section 5.4 of the Scope 2 Guidance addresses BTM power generation directly: “the company with operational or financial control of the energy generation facility reports those emissions in scope 1, following the operational control approach, while the consumer of the energy reports the emissions in scope 2.”

This resolves the question completely. The emissions sit in scope 1 if the company has operational or financial control of the asset, or in scope 2 if a third party controls it.

The GHG Protocol’s Corporate Value Chain (Scope 3) Accounting and Reporting Standard reinforces this conclusion. “Category 8 includes emissions from the operation of assets that are leased by the reporting company in the reporting year and not already included in the reporting company’s scope 1 or scope 2 inventories.”

Because BTM electricity emissions are captured by the Scope 2 Guidance, the scope 3 category 8 does not apply.

Get the Accounting Right Before the Contract Closes

The GHG Protocol is unambiguous: behind-the-meter electricity emissions belong in scope 2 for companies that consume, but do not control the generating asset. This means that BTM contract terms are crucial to determining how the emissions will be classified, since the GHG Protocol assigns scope based on who holds operational or financial control of the generating asset. 

Companies that move fast on BTM capacity without understanding this distinction risk locking in a scope 1 or scope 2 obligation they didn't anticipate or building a reporting strategy around a scope 3 interpretation the GHG Protocol doesn't support. This can become a reputational or even a regulatory liability that is far harder to address after the contract is signed.

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