Society submits evidence on Scope 3 emissions reporting

This IR Society response draws on the findings from recent member research on Scope 3 and SECR reporting.

The Society's response to the Government's recent call for evidence on scope 3 and SECR reporting summarised our findings (on pages 2-5) and appended the detailed findings (on pages 14-24), and is available to members here: Sustainability - Investor Relations Society ( (please click on the top link and then scroll down to access the response).


Our member IRO respondents indicated:

  • A willingness among corporates to report Scope 3, especially among the largest companies, with over three-quarters of corporates already reporting it and a slim majority (52%) supporting making it mandatory;
  • However, there is a clear challenge around reliability/measurement given:
    • well over half of companies are not using any direct measurement, instead relying on estimates and/or third party providers; and
    • there is a divergence in methodologies of measurement, with the largest companies more likely to be using direct measurements and have SBTi-approved targets;
  • The vast majority of respondents currently reporting scope 3 cited ‘difficulty in obtaining data or estimates’ as a challenge or disincentive, with nearly 70% citing ‘lack of confidence in ability to measure accurately’;
  • SECR reporting is not viewed as terribly onerous from a resource or cost perspective, perhaps because larger UK companies have been subject to SECR reporting requirements for several years so are likely to have well established processes in place, although there was a significant minority finding it as a lot of work/significant;
  • Levels of interest in SECR reporting among investors or other stakeholders is perceived by our respondents as modest (especially for smaller companies);
  • Mandatory reporting of scopes 1, 2 and 3 GHG emissions would require significantly more work for 40% of respondents;
  • General support of the FCA’s proposed timetable for reporting Scope 3, although:
  • a minority viewed it as unrealistic and several commented that the reliability of the data would be compromised if the timetable is too tight;
  • given Scope 3 reporting will involve significant levels of estimation for some time to come, stipulation of estimation bases would improve reliability/comparability of reporting;
  • there was a suggestion that companies should be given at least a year after publication of new reporting requirements to collect data in order to reduce reliance on extrapolation/estimation that could otherwise limit the value in the disclosure;
  • the limitations (for example, estimates and judgements) would need to be fully understood by any user.
  • More harmonisation is needed with EU standards, with better clarity on the interactions and potential inconsistencies between IFRS S2 and CSRD, and sector specific guidance would help companies and investors track performance over time; and
  • The vast majority of respondents expect to be required to report scope 3 in future anyway.

(The survey was conducted from 23rd November to 7th December 2023 among IR Society Members who are Investor Relations Officers. There were 37 respondents, though not every respondent answered each question.)

Published 5 January, 2024

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