Low Carbon Transition Ratings

Align your portfolio to a net-zero pathway

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Mandatory climate-related financial disclosure is becoming a universal reality, with more governments around the world adopting the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) and other leading expert groups. In parallel, companies are setting targets and developing strategies to do their part in meeting the global objective of minimizing global warming to 1.5°C by 2050.

Morningstar Sustainalytics’ Low Carbon Transition Ratings provide investors with a forward-looking assessment of a company’s current alignment to a net-zero pathway.

Leveraging our Low Carbon Transition Ratings, investors can respond to regulatory initiatives, implement net-zero strategies, fulfill client net-zero mandates, and obtain transparency into company actions by integrating climate research into their investment decision-making processes.

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Mandatory Scope 3 Emissions Reporting in the U.S. and Canada: Most Companies Are Unprepared

Jul 31, 2023, 15:02 PM by Melissa Chase
Learn just how prepared U.S. and Canadian companies are for the proposed scope 3 emissions disclosure rules and how investors can leverage engagement to help companies meet the various challenges of GHG emissions reporting.

As mandatory climate-related reporting continues to advance around the world, companies headquartered in the United States and Canada are subject to pending disclosure rules from securities regulators. This article focuses on the proposed scope 3 emissions disclosure rules in North America, providing insights into companies’ levels of preparedness to respond, and the challenges and solutions being discussed through engagement strategies with high or severe risk companies in the Morningstar Sustainalytics Ratings universe.1

Examining the SEC and CSA Proposals for Scope 3 Emissions Disclosure

In recent years, both the Securities and Exchange Commission (SEC) in the U.S. and the Canadian Securities Administrators (CSA) have proposed rules to enhance corporate climate disclosures. Of particular interest are the provisions related to scope 3 emissions. 

Compared to scope 1 and 2 emissions, which refer to the direct emissions from owned or controlled sources and indirect emissions from the generation of purchased energy respectively, scope 3 emissions are all other indirect emissions that derive from an organization’s value chain. It is critically important for companies to account for their scope 3 emissions as they are estimated to take up more than 70% of a business’ total carbon emissions on average.The share of scope 3 emissions can be as high as 99.84% in financial services and 80.85% for oil and gas.3 

Under the SEC proposal, issuers would be required to disclose their scope 3 emissions if they are material or if the issuer has set targets for them.4 In Canada, the CSA is considering mandating a comply-or-explain approach to all three emission scopes or to scope 2 and 3 emissions only.5 

While the comment period for both proposals has ended, the regulatory agencies have yet to finalize the rules. The CSA announced in October 2022 that it was considering the international consensus on the topic.6 Meanwhile in the U.S., there are indications that the SEC may delay launching the rules until fall 2023.7 Legal challenges against the rules are also expected once they are finalized, which could complicate adoption.

Challenges With Scope 3 Emissions Reporting

In anticipation of the finalized rules, North American companies are struggling to understand, calculate and disclose their scope 3 emissions. Only 36% of the companies included in Sustainalytics’ Ratings universe disclose all three types of emissions in line with the Greenhouse Gas (GHG) Protocol (see Figure 1 below). 

Of the companies targeted by Sustainalytics Material Risk Engagement — those companies assessed as having high or severe risk based on Sustainalytics ESG Risk Ratings — only 27% disclosed all three emission scopes. Overall, more than half of the companies in both groups are either not disclosing GHG emissions at all or have only reported on one or two scopes.

Figure1. Scope of GHG Reporting for Issuers Headquartered in the U.S. and Canada

Chart - Issuer Emissions Scope Reporting for Material Risk Engagement group vs ESG Ratings Univers

Source: Morningstar Sustainalytics. The data for this analysis was retrieved on June 1, 2023, from Sustainalytics' Ratings Universe. For informational purposes only.

The GHG Protocol Corporate Standard divides scope 3 emissions into upstream and downstream emissions and then classifies them into 15 distinct categories.8 So, to achieve full disclosure of emissions data, a company’s scope 3 emissions inventory should be disclosed by category. But for many companies, this is no easy task.

Common challenges with scope 3 reporting are often discussed during conversations with companies through Sustainalytics’ Material Risk Engagement program. These companies regularly cite issues with data quality and calculations; lack of accounting or estimation methodologies; and conglomerate, decentralized or geographically diverse organizational structures that hinder data collection and assimilation. However, even without mandatory reporting rules from the SEC and CSA, the need for consistent, comparable scope 3 emissions data will continue to increase, irrespective of the challenges companies are facing. 

Why Companies Should Act Now to Improve Their Scope 3 Disclosures

Although it may take some time before the scope 3 emissions disclosure rules take effect in North America, companies can benefit from understanding and gradually working towards reporting their scope 3 emissions now. Such an exercise can offer deeper insight into a business’ carbon footprint across its value chain and identify decarbonization opportunities.

Other developments within different jurisdictions and standard setting organizations are also driving companies towards enhanced transparency. For example, the U.S. federal government proposed in 2022 that major federal contractors (US$50 million in annual contract obligation) must report on their scope 3 emissions; California and New York introduced bills similar to the SEC’s proposal; scope 3 disclosures will be required under the European Union’s Corporate Sustainability Reporting Directive, which comes into force January 2024 and will likely impact more than 3,000 U.S. and 1,300 Canadian companies.9 The International Sustainability Standards Board has also issued its inaugural climate-related disclosure standard that includes scope 3 emissions in June 2023. Companies need to be prepared for the ever-growing demand for emissions data.

Investor Engagement Strategies to Improve Corporate Scope 3 Disclosure

Engagement can help investors assess a company’s preparedness for the proposed disclosure rules, understand challenges they are facing, and help to implement solutions. By first discussing the potential benefits of enhanced transparency around scope 3 emissions, investors can then inspire companies to take steps to improve disclosure. 

Companies wrestling with data quality and calculation uncertainty can be directed to the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard and its supplemental document, Technical Guidance for Calculating Scope 3 Emissions. These documents provide guidance on calculation methods, data sources, and examples of calculating scope 3 emissions as well as several cross-sector and sector-specific calculation tools. 

But understanding scope 3 emissions standards isn’t necessarily enough. A company often needs to invest in resources dedicated to performing the calculations and managing the emissions inventory once it is established. Carbon accounting software can help with automated data processes, measurement conversions, calculations, and forecasts. These systems will also come in handy for internal audit and external verification.

In the absence of data, estimation is an accepted first step in the development of a scope 3 emissions inventory. According to the GHG Protocol, a company needing to collect a large quantity of data for a particular scope 3 category may find it impractical or impossible to collect the data from each activity in the category. In such cases, companies may use appropriate sampling techniques to extrapolate data from a representative sample of activities within the category.10 

In addition, some sectors are developing their own scope 3 estimation methodologies based on guidance from the GHG Protocol. As an example, oil and gas companies can look to the International Petroleum Industry Environmental Conservation Association for methodologies to inform scope 3 GHG emissions estimation and approaches. Financial institutions endeavoring to disclose against their financed emissions (scope 3, category 15) can refer to the Global GHG Accounting and Reporting Standard by the Partnership for Carbon Accounting Financials.11, 12 Whichever way an estimate is calculated, the company should disclose the methodology used.

Performing and disclosing these calculations can also be done in phases. A company can be encouraged to focus efforts on its most material scope 3 category first and disclose the reasons why it is not reporting against the remaining categories. Finally, market leaders should be expected to demonstrate support and guidance with their suppliers’ capacity to calculate carbon emissions, which in turn could enable multiple companies to move from estimated to actual scope 3 data. 

Developing a scope 3 emissions inventory is complex and built on cumbersome processes that many North American companies are struggling with. Even though the task can be daunting, solutions are available and flexibility in disclosure remains on the table, for now. There are obvious environmental and financial benefits to understanding and reporting value chain emissions. Investors and market leading companies should continue to encourage voluntary corporate transparency with a solutions mindset, so that companies are prepared to respond to evolving global market requirements and more importantly, truly understand and address the impact of their carbon footprint.  

To learn more about opportunities to engage with companies on their GHG emissions and disclosures, visit our Engagement Services web page or contact us

 

References

  1. The Morningstar Sustainalytics Ratings universe comprises approximately 5,000 large and medium market cap investable issuers in developed and emerging markets.
  2. Global Compact Network UK. n.d. “Scope 3 Emissions.” https://www.unglobalcompact.org.uk/scope-3-emissions/
  3. CDP. n.d. “CDP Technical Note: Relevance of Scope 3 Categories by Sector.” https://cdn.cdp.net/cdp-production/cms/guidance_docs/pdfs/000/003/504/original/CDP-technical-note-scope-3-relevance-by-sector.pdf.  
  4. Securities and Exchange Commission. 2022. “The Enhancement and Standardization of Climate-Related Disclosures for Investors.” https://www.federalregister.gov/documents/2022/04/11/2022-06342/the-enhancement-and-standardization-of-climate-related-disclosures-for-investors#h-20.  
  5. Keyes, S. and Lanz, D. 2022. “A Comparative Analysis of U.S. (SEC) and Canadian (CSA) Climate Disclosure Proposals.” ESG Global Advisors. https://www.esgglobaladvisors.com/news-views/a-comparative-analysis-of-u-s-sec-and-canadian-csa-climate-disclosure-proposals/
  6. Canadian Securities Administrators. 2022. “Canadian securities regulators consider impact of international developments on proposed climate-related disclosure rule”. Official CSA press release, October 12, 2022 https://www.securities-administrators.ca/news/canadian-securities-regulators-consider-impact-of-international-developments-on-proposed-climate-related-disclosure-rule/
  7. Rives, K. 2023. “SEC climate disclosure rule delayed until fall, former commissioner says.” S&P Global Market Intelligence, April 28, 2023. https://www.spglobal.com/marketintelligence/en/news-insights/latest-news-headlines/sec-climate-disclosure-rule-delayed-until-fall-former-commissioner-says-75479173
  8. Greenhouse Gas Protocol. 2011. “Corporate Value Chain (Scope 3) Accounting and Reporting Standard.” https://ghgprotocol.org/sites/default/files/standards/Corporate-Value-Chain-Accounting-Reporing-Standard_041613_2.pdf
  9. Worland, J. 2023. “Why U.S. Companies Should Pay Attention to Europe’s New Climate Rules.” Time, May 25, 2023. https://time.com/6282880/why-eu-climate-corporate-disclosure-rules-matter/
  10. Greenhouse Gas Protocol. 2022. “Technical Guidance for Calculating Scope 3 Emissions, Appendix A: Sampling”. https://ghgprotocol.org/sites/default/files/2022-12/AppendixA.pdf
  11. International Petroleum Industry Environmental Conservation Association. 2016. “Estimating petroleum industry value chain (Scope 3) greenhouse gas emissions. Overview of methodologies.” https://www.ipieca.org/resources/estimating-petroleum-industry-value-chain-scope-3-greenhouse-gas-emissions-overview-of-methodologies
  12. Partnership for Carbon Accounting Financials. 2022. “The Global GHG Accounting and Reporting Standard Part A: Financed Emissions. Second Edition.” https://carbonaccountingfinancials.com/files/downloads/PCAF-Global-GHG-Standard.pdf.
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Overview of Sustainalytics’ Low Carbon Transition Ratings

Our comprehensive framework measures the degree to which a company’s projected greenhouse gas (GHG) emissions differ from a net-zero pathway between now and the year 2050. The ratings leverage a two-dimensional framework that measures an issuer's exposure from their expected emissions, while also accounting for management actions. They assess the company's progress toward their stated net-zero commitments by evaluating the quality and ambition of their GHG reduction targets, as well as any demonstrated short-term investment plans, policies and programs.

Expected Emissions Projections Chart
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Comprehensive Measure of Low Carbon Transition Alignment

Analyze low carbon transition exposure and management preparedness across a business’s value chain for each scope of emissions. Our assessment delivers more than just an Implied Temperature Rise rating. It goes beyond looking at a company’s ambitions and targets. Investors can identify areas where each issuer is performing well and opportunities for improvement. 

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Analyze Expected Issuer Emissions Against the 1.5°C Required Policy Scenario*

Our Low Carbon Transition Ratings are driven by a bottom-up scenario analysis, evaluating companies’ emission trajectories against expected regional policy and technology pathways required to meet the Paris Agreement and net-zero ambitions by the year 2050. Additional scenarios for further analysis are in development. 

*The 1.5°C Required Policy Scenario (RPS) is from the UN PRI commissioned Inevitable Policy Response (IPR).

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Support Investor TCFD Reporting and Assess Issuer Disclosure

Paired with our Physical Climate Risk Metrics and Carbon Emissions Data solutions, our Low Carbon Transition Ratings enable investors to meet most TCFD recommendations. Additionally, investors receive a detailed assessment of issuer TCFD disclosure with respect to their quality of management across each thematic area of the TCFD. 

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Access our Transparent Methodology and Granular Data

Our Low Carbon Transition Ratings are underpinned by a transparent methodology, multiple levels of data and clear indicator guidance, which allows for validation and customization of the weighted data points to generate unique insights that align to investors’ objectives.  

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Holistic Integration of Management Preparedness

With more than 85 general and subindustry-specific management indicators - weighted by a company’s distribution of GHG emissions across Scopes 1, 2, 3 upstream, and 3 downstream across the full business value chain – investors can integrate granular climate insights into their company assessments and valuation models.

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Ratings Expressed as Implied Temperature Rise

The top-level ratings are expressed as a simple contextualized signal, estimating the Implied Temperature Rise of issuers’ current low carbon transition performance. This expresses what global temperatures could rise to if the whole economy had the same percentage of misaligned emissions between now and the year 2050. This output enables investors to seamlessly categorize and compare different levels of performance across issuers.

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Dedicated TCFD Module to Assess Issuer Disclosure with TCFD

A TCFD module is included in the rating to assess and track the comprehensiveness of issuer disclosure and translate our assessment of issuers’ managerial preparedness across the four thematic areas recommended by the TCFD (governance, strategy, risk management, and metrics and targets).

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Five Categories of Alignment

The Low Carbon Transition Ratings are categorized across 5 levels of net-zero alignment: Aligned (0°C -1.5°C), Moderately Misaligned (1.5°C - 2°C), Significantly Misaligned (2°C -3°C), Highly Misaligned (3°C -4°C), and Severely Misaligned (4°C +).

Material ESG issues

5,000+ Companies Covered

Sustainalytics' Low Carbon Transition Ratings span more than 5,000 companies and encompass most major global indices. Future expansion of the company database will align with the coverage of our ESG Risk Ratings.

Accessibility

Flexible Accessibility

The Low Carbon Transition Ratings are available through Global Access with screening and reporting tools, data-feeds, and application programming interface (API). They will be made available for several third-party distribution platforms in the future.

Learn more about our Low Carbon Transition Ratings

To learn more about our Low Carbon Transition Ratings, view the video message from our Senior Vice President of Climate Solutions, Azadeh Sabour.

About Our Framework

We start with a baseline projection, which is based on corporate reporting and estimation modelling across all 3 scopes of emissions, including both the upstream and downstream segments of scope 3.

Next, we consider how the quality of the company's policies and programs, strategy, governance, and financial position affect the baseline emissions.

This emissions projection is based on a company's baseline emissions in combination with their managed emissions.

This is the company's sector- and region-specific budget required to align to a net-zero emissions pathway by 2050.

The expected emissions gap reflects the emissions that are not managed and indicates the severity of misaligned emissions.

The Expected Emissions Gap reflects the emissions that are not managed and indicates the severity of misaligned emissions.

Decomposition chart
LCTR---Emissions-Projections-Chart-2

Expected Emissions Gap Calculation

 Cumulative Emissions to 2050 (CO2)
Expected Emissions765 Mt
Net-Zero Budget211 Mt
Expected Emissions Gap553 Mt (+261%)
Implied Temperature Rise Score 2.4ºC
Implied Temperature Rise Category Significantly Misaligned

Use Cases 

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Climate Research Integration

  • Measure alignment of companies against a 1.5°C scenario
  • Deepen insights into transition risk and opportunities for portfolio management
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Implement Net-Zero Strategies

  • Assess forward-looking carbon emissions of companies, portfolios, funds, and benchmarks with net-zero pathways.
  • Meet commitments of global alliances and member groups such as the Net Zero Asset Manager Initiative and the Institutional Investors Group on Climate Change (IIGCC).
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Screening and Benchmarking

  • Set decarbonization targets and monitor performance.
  • Screen investable universe based on company exposure to, and/or management of, transition risks.
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Reporting & Client Communication

  • Support TCFD-aligned regulatory reporting.
  • Report to clients on how portfolios are aligned with global climate goals.
  • Respond to client net-zero mandates.
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Engagement and Voting

  • Evaluate company management of transition risks and opportunities.
  • Obtain transparency on corporate’s disclosure sufficiency to current TCFD recommendations.
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Thematic Investing

  • Create climate-aware investment products.

Report Insights

A company’s top-level rating is expressed as an Implied Temperature Rise signifying the expected level of global warming if the global economy had the same proportion of emissions misaligned to the net-zero budget. The absolute emissions gap across each scope of the company’s business activity are summarized through time series graphs, with the underlying components of the assessment illustrated in decomposition charts.

ESG Risk ratings report showcasing company rating

The degree of overall alignment to the net-zero budget is summarized for each scope of emissions across an issuer’s value-chain, providing transparency into how much each scope of emissions is contributing to the overall rating. A separate value-chain analysis for each of the exposure and management components is also provided.

ESG Risk ratings report showcasing value chain analysis

The issuer’s rating is analyzed in context of their peers in global public equity and bond markets, as well as industry and sub-industry specific peers. The issuer’s top peers by market capitalization are summarized with a view of their overall rating, Exposure and Management scores.

ESG Risk ratings report showcasing Peer Analysis

An overall management score out of 100 is provided, as well as an analysis identifying where action may be needed across the issuer's business activities. This is communicated through a breakdown of their management scores and contribution of key management indicators for each scope of emissions across the issuer’s value chain.

ESG Risk ratings report showcasing Management Score and Analysis​

An overall score of the comprehensiveness of issuers’ climate related disclosures, and a detailed analysis across the key TCFD thematic areas of governance, strategy, risk management and metrics & targets provides transparency into quality of their management.

ESG Risk ratings report showcasing Assessment of Issuer TCFD Reporting
ESG Risk ratings report showcasing company rating

Why Sustainalytics?

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A Single Market Standard

Consistent approach to ESG assessments across the investment spectrum.

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Award-Winning Research and Data

Firm recognized as Best ESG Research and Data Provider by Environmental Finance and Investment Week.

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End-to-End ESG Solutions

ESG products and services that serve the entire investment value chain.

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30 Years of ESG Expertise

800+ ESG research analysts across our global offices.

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A Leading SPO Provider

As recognized by Environmental Finance and the Climate Bonds Initiative.

Related Products

Carbon Emissions

Carbon Emissions Data ​

Evaluate and analyze companies’ GHG emissions across scope 1, 2, and 3 emissions.

Learn More
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Net Zero Transition Engagement Programme

Establish an effective climate-focused dialogue with high-emitting companies on their journey to net zero carbon emissions.

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Physical Climate Risk Metrics

Physical Climate Risk Metrics

Assess and disclose the direct and indirect physical climate risks of climate change related exposure.

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Related Insights and Resources

Mandatory Scope 3 Emissions Reporting in the U.S. and Canada: Most Companies Are Unprepared

Jul 31, 2023, 15:02 PM by Melissa Chase
Learn just how prepared U.S. and Canadian companies are for the proposed scope 3 emissions disclosure rules and how investors can leverage engagement to help companies meet the various challenges of GHG emissions reporting.

As mandatory climate-related reporting continues to advance around the world, companies headquartered in the United States and Canada are subject to pending disclosure rules from securities regulators. This article focuses on the proposed scope 3 emissions disclosure rules in North America, providing insights into companies’ levels of preparedness to respond, and the challenges and solutions being discussed through engagement strategies with high or severe risk companies in the Morningstar Sustainalytics Ratings universe.1

Examining the SEC and CSA Proposals for Scope 3 Emissions Disclosure

In recent years, both the Securities and Exchange Commission (SEC) in the U.S. and the Canadian Securities Administrators (CSA) have proposed rules to enhance corporate climate disclosures. Of particular interest are the provisions related to scope 3 emissions. 

Compared to scope 1 and 2 emissions, which refer to the direct emissions from owned or controlled sources and indirect emissions from the generation of purchased energy respectively, scope 3 emissions are all other indirect emissions that derive from an organization’s value chain. It is critically important for companies to account for their scope 3 emissions as they are estimated to take up more than 70% of a business’ total carbon emissions on average.The share of scope 3 emissions can be as high as 99.84% in financial services and 80.85% for oil and gas.3 

Under the SEC proposal, issuers would be required to disclose their scope 3 emissions if they are material or if the issuer has set targets for them.4 In Canada, the CSA is considering mandating a comply-or-explain approach to all three emission scopes or to scope 2 and 3 emissions only.5 

While the comment period for both proposals has ended, the regulatory agencies have yet to finalize the rules. The CSA announced in October 2022 that it was considering the international consensus on the topic.6 Meanwhile in the U.S., there are indications that the SEC may delay launching the rules until fall 2023.7 Legal challenges against the rules are also expected once they are finalized, which could complicate adoption.

Challenges With Scope 3 Emissions Reporting

In anticipation of the finalized rules, North American companies are struggling to understand, calculate and disclose their scope 3 emissions. Only 36% of the companies included in Sustainalytics’ Ratings universe disclose all three types of emissions in line with the Greenhouse Gas (GHG) Protocol (see Figure 1 below). 

Of the companies targeted by Sustainalytics Material Risk Engagement — those companies assessed as having high or severe risk based on Sustainalytics ESG Risk Ratings — only 27% disclosed all three emission scopes. Overall, more than half of the companies in both groups are either not disclosing GHG emissions at all or have only reported on one or two scopes.

Figure1. Scope of GHG Reporting for Issuers Headquartered in the U.S. and Canada

Chart - Issuer Emissions Scope Reporting for Material Risk Engagement group vs ESG Ratings Univers

Source: Morningstar Sustainalytics. The data for this analysis was retrieved on June 1, 2023, from Sustainalytics' Ratings Universe. For informational purposes only.

The GHG Protocol Corporate Standard divides scope 3 emissions into upstream and downstream emissions and then classifies them into 15 distinct categories.8 So, to achieve full disclosure of emissions data, a company’s scope 3 emissions inventory should be disclosed by category. But for many companies, this is no easy task.

Common challenges with scope 3 reporting are often discussed during conversations with companies through Sustainalytics’ Material Risk Engagement program. These companies regularly cite issues with data quality and calculations; lack of accounting or estimation methodologies; and conglomerate, decentralized or geographically diverse organizational structures that hinder data collection and assimilation. However, even without mandatory reporting rules from the SEC and CSA, the need for consistent, comparable scope 3 emissions data will continue to increase, irrespective of the challenges companies are facing. 

Why Companies Should Act Now to Improve Their Scope 3 Disclosures

Although it may take some time before the scope 3 emissions disclosure rules take effect in North America, companies can benefit from understanding and gradually working towards reporting their scope 3 emissions now. Such an exercise can offer deeper insight into a business’ carbon footprint across its value chain and identify decarbonization opportunities.

Other developments within different jurisdictions and standard setting organizations are also driving companies towards enhanced transparency. For example, the U.S. federal government proposed in 2022 that major federal contractors (US$50 million in annual contract obligation) must report on their scope 3 emissions; California and New York introduced bills similar to the SEC’s proposal; scope 3 disclosures will be required under the European Union’s Corporate Sustainability Reporting Directive, which comes into force January 2024 and will likely impact more than 3,000 U.S. and 1,300 Canadian companies.9 The International Sustainability Standards Board has also issued its inaugural climate-related disclosure standard that includes scope 3 emissions in June 2023. Companies need to be prepared for the ever-growing demand for emissions data.

Investor Engagement Strategies to Improve Corporate Scope 3 Disclosure

Engagement can help investors assess a company’s preparedness for the proposed disclosure rules, understand challenges they are facing, and help to implement solutions. By first discussing the potential benefits of enhanced transparency around scope 3 emissions, investors can then inspire companies to take steps to improve disclosure. 

Companies wrestling with data quality and calculation uncertainty can be directed to the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard and its supplemental document, Technical Guidance for Calculating Scope 3 Emissions. These documents provide guidance on calculation methods, data sources, and examples of calculating scope 3 emissions as well as several cross-sector and sector-specific calculation tools. 

But understanding scope 3 emissions standards isn’t necessarily enough. A company often needs to invest in resources dedicated to performing the calculations and managing the emissions inventory once it is established. Carbon accounting software can help with automated data processes, measurement conversions, calculations, and forecasts. These systems will also come in handy for internal audit and external verification.

In the absence of data, estimation is an accepted first step in the development of a scope 3 emissions inventory. According to the GHG Protocol, a company needing to collect a large quantity of data for a particular scope 3 category may find it impractical or impossible to collect the data from each activity in the category. In such cases, companies may use appropriate sampling techniques to extrapolate data from a representative sample of activities within the category.10 

In addition, some sectors are developing their own scope 3 estimation methodologies based on guidance from the GHG Protocol. As an example, oil and gas companies can look to the International Petroleum Industry Environmental Conservation Association for methodologies to inform scope 3 GHG emissions estimation and approaches. Financial institutions endeavoring to disclose against their financed emissions (scope 3, category 15) can refer to the Global GHG Accounting and Reporting Standard by the Partnership for Carbon Accounting Financials.11, 12 Whichever way an estimate is calculated, the company should disclose the methodology used.

Performing and disclosing these calculations can also be done in phases. A company can be encouraged to focus efforts on its most material scope 3 category first and disclose the reasons why it is not reporting against the remaining categories. Finally, market leaders should be expected to demonstrate support and guidance with their suppliers’ capacity to calculate carbon emissions, which in turn could enable multiple companies to move from estimated to actual scope 3 data. 

Developing a scope 3 emissions inventory is complex and built on cumbersome processes that many North American companies are struggling with. Even though the task can be daunting, solutions are available and flexibility in disclosure remains on the table, for now. There are obvious environmental and financial benefits to understanding and reporting value chain emissions. Investors and market leading companies should continue to encourage voluntary corporate transparency with a solutions mindset, so that companies are prepared to respond to evolving global market requirements and more importantly, truly understand and address the impact of their carbon footprint.  

To learn more about opportunities to engage with companies on their GHG emissions and disclosures, visit our Engagement Services web page or contact us

 

References

  1. The Morningstar Sustainalytics Ratings universe comprises approximately 5,000 large and medium market cap investable issuers in developed and emerging markets.
  2. Global Compact Network UK. n.d. “Scope 3 Emissions.” https://www.unglobalcompact.org.uk/scope-3-emissions/
  3. CDP. n.d. “CDP Technical Note: Relevance of Scope 3 Categories by Sector.” https://cdn.cdp.net/cdp-production/cms/guidance_docs/pdfs/000/003/504/original/CDP-technical-note-scope-3-relevance-by-sector.pdf.  
  4. Securities and Exchange Commission. 2022. “The Enhancement and Standardization of Climate-Related Disclosures for Investors.” https://www.federalregister.gov/documents/2022/04/11/2022-06342/the-enhancement-and-standardization-of-climate-related-disclosures-for-investors#h-20.  
  5. Keyes, S. and Lanz, D. 2022. “A Comparative Analysis of U.S. (SEC) and Canadian (CSA) Climate Disclosure Proposals.” ESG Global Advisors. https://www.esgglobaladvisors.com/news-views/a-comparative-analysis-of-u-s-sec-and-canadian-csa-climate-disclosure-proposals/
  6. Canadian Securities Administrators. 2022. “Canadian securities regulators consider impact of international developments on proposed climate-related disclosure rule”. Official CSA press release, October 12, 2022 https://www.securities-administrators.ca/news/canadian-securities-regulators-consider-impact-of-international-developments-on-proposed-climate-related-disclosure-rule/
  7. Rives, K. 2023. “SEC climate disclosure rule delayed until fall, former commissioner says.” S&P Global Market Intelligence, April 28, 2023. https://www.spglobal.com/marketintelligence/en/news-insights/latest-news-headlines/sec-climate-disclosure-rule-delayed-until-fall-former-commissioner-says-75479173
  8. Greenhouse Gas Protocol. 2011. “Corporate Value Chain (Scope 3) Accounting and Reporting Standard.” https://ghgprotocol.org/sites/default/files/standards/Corporate-Value-Chain-Accounting-Reporing-Standard_041613_2.pdf
  9. Worland, J. 2023. “Why U.S. Companies Should Pay Attention to Europe’s New Climate Rules.” Time, May 25, 2023. https://time.com/6282880/why-eu-climate-corporate-disclosure-rules-matter/
  10. Greenhouse Gas Protocol. 2022. “Technical Guidance for Calculating Scope 3 Emissions, Appendix A: Sampling”. https://ghgprotocol.org/sites/default/files/2022-12/AppendixA.pdf
  11. International Petroleum Industry Environmental Conservation Association. 2016. “Estimating petroleum industry value chain (Scope 3) greenhouse gas emissions. Overview of methodologies.” https://www.ipieca.org/resources/estimating-petroleum-industry-value-chain-scope-3-greenhouse-gas-emissions-overview-of-methodologies
  12. Partnership for Carbon Accounting Financials. 2022. “The Global GHG Accounting and Reporting Standard Part A: Financed Emissions. Second Edition.” https://carbonaccountingfinancials.com/files/downloads/PCAF-Global-GHG-Standard.pdf.
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