Call for evidence on Scope 3 reporting

The Government's anticipated call for evidence has now been issued, seeking views on the costs, benefits and practicalities of Scope 3 greenhouse gas emissions reporting in the UK, to help inform the government’s decision on whether to endorse the ISSB standards in the UK. It also investigates the current SECR framework to inform a Post-Implementation Review of the policy.

The call for evidence, issued by the Department for Energy Security and Net Zero (DESNZ), closes on 14th December and is available here: UK greenhouse gas emissions reporting: Scope 3 emissions - GOV.UK (

Members may wish to submit their own evidence, the questions include:

  • What are, or do you anticipate being, the greatest barriers to producing consistent Scope 3 data?
  • How are you approaching the issues around data availability in relation to Scope 3 reporting? Are you aware of any useful data sources, reporting tools, or resources (such as emissions factors) to help UK organisations report their Scope 3 emissions, and how are you tackling them?
  • If you currently voluntarily report your Scope 3 emissions (including through non Governmental frameworks such as CDP and SBTi), what effect has this had on your relationships with businesses in your supply chain?
  • SECR reporting is currently required within a company’s annual report. Would it be more appropriate to report on SECR in another document or format?
  • How can the government streamline current energy and emissions reporting requirements for organisations in scope of SECR while still meeting the SECR objectives?
  • Under the existing SECR framework, there are different reporting requirements for quoted companies and unquoted companies/LLPs. Are these differing requirements appropriate? If not, what reforms would you suggest? 
  • What is your view on the approach to Scope 3 reporting contained within IFRS S2? Please consider the ISSB’s approach to materiality in your answer.
  • What is your view on the use of the GHG Protocol for the purposes of Scope 3 reporting within IFRS S2? Will this lead to comparable and consistent reporting that is useful for investors and users of accounts?
  • Would using the ISSB’s approach to Scope 3 reporting have knock-on consequences for your organisation that the Government should be aware of? For instance, you may wish to consider the interaction between IFRS S2 and any EU regulations, or other energy/emissions reporting requirements that your organisation may be impacted by.
  • Is there any additional emissions or energy-consumption related data that is not required within IFRS S2 that you believe is valuable for investors, users of accounts and other stakeholders?  
  • What further guidance and support might be needed for your organisation, and organisations in your value chain, to report Scope 3 information in accordance with IFRS S2?
  • If your organisation does not already prepare Scope 3 information, how long would you need to build the capacity and capability to do so?

Published 25 October, 2023