Climate change duties - draft statutory guidance for public bodies: consultation

Closes 23 May 2025

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Reporting of scope 3 emissions

Chapter 8, Reporting, provides an overview of reporting, with a particular focus on the mandatory reporting required under The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015, as amended (the public bodies climate change duties reporting).

Previous guidance mandated reporting of relevant scope 1 and 2 emissions, while reporting of scope 3 emissions was recommended on a voluntary basis (Public Sector Leadership on the Global Climate Emergency (2021), chapter 7).

This new guidance proposes a reporting baseline for selected scope 3 emissions, which all public bodies would be expected to include in their inventory (see section 8.3.5.1), specifically the emissions associated with:

  • consumption of mains water
  • waste and waste water treatment
  • business travel
  • staff commuting and homeworking
  • student travel (for colleges and universities)
  • fuel and energy-related activities not included in scopes 1 and 2

You may find it useful to refer to the consultation paper while responding to these questions.

What are scope 1, 2 and 3 emissions?

The Greenhouse Gas Protocol splits corporate, or organisational, emissions into three scopes for carbon accounting and reporting purposes.

Scope 1 emissions are direct emissions generated by assets owned or controlled by the reporting organisation. For Scottish public bodies, scope 1 emissions commonly include emissions generated by using petrol and diesel in fleet vehicles, and from gas used for heating and cooking.  

Scope 2 emissions are indirect emissions associated with the generation of acquired and consumed electricity, heat, steam or cooling. For public bodies, scope 2 emissions are typically those associated with the generation of purchased grid electricity or heat purchased from a district heating network.

Scope 3 emissions are indirect emissions from the wider value chain that are not already accounted for under scopes 1 and 2. They include the emissions associated with purchased goods and services, the construction of new buildings and infrastructure, staff commuting, business travel and investments. Scope 3 emissions lie outside the direct control of the reporting organisation.

12. To what extent do you agree or disagree with the proposed baseline reporting of the scope 3 emission categories outlined in section 8.3.5.1 of the guidance and in the drop down section below?

Baseline reporting of scope 3 emissions – further information

The rationale for including water, waste, business travel, commuting and student travel is that these are areas where public bodies have more influence, and they offer opportunities to engage staff, visitors and service users. Emissions from these areas can be more easily influenced and managed through policy and operational processes. They are also areas where data should be more readily available to the organisation, or can be more easily and accurately estimated.

Reporting on fuel and energy-related activities provides a fuller picture of the carbon impact of using, say, natural gas as it includes the upstream emissions associated with extracting, refining and transporting the fuel. As such, it can assist in the development of robust business cases and impact assessments that support the transition to low or zero carbon alternatives.

If all public bodies include these categories of emissions, it will provide a consistent baseline across the public sector, allow more accurate analysis, and facilitate sectoral comparisons and benchmarking.

13. Do you think that any other categories of scope 3 emissions should be included in the recommended baseline for reporting, where these are relevant and applicable? Please tick all that apply.