The GHG Protocol's March 2026 "Scope 3 Standard Revisions: Phase 1 Progress Update" signals the most consequential proposed overhaul of Scope 3 accounting since the standard was first issued in 2011. The document is not yet a final standard and is not open for formal consultation, but it gives a clear indication of where the requirements are heading — and companies that wait for the final version before preparing are likely to face a difficult transition.
At the centre of the proposed changes is a new minimum boundary rule: companies reporting in conformance with the standard would need to account for at least 95% of total required Scope 3 emissions. This would replace the current less prescriptive approach, which requires companies to account for Scope 3 emissions and justify exclusions but does not set a quantified threshold. In practice the proposal is designed to improve comparability and reduce the scope for omitting material emissions sources. Companies that have historically excluded high-emitting categories on the grounds of data difficulty will need to revisit those decisions.
A second major theme is data transparency and quality. The draft revisions would require Scope 3 inventories to be disaggregated by data type, making it explicit how much of a company's inventory relies on primary supplier data, activity-based modelling, or estimated figures. The update also proposes clearer verification disclosures — labels such as "fully verified," "partially verified," or "not verified" — alongside stronger guidance on emission-factor completeness, data-specificity goals, and year-on-year data quality improvement targets. Collectively these changes would make Scope 3 inventories more useful to investors, auditors, regulators, and internal management teams trying to track progress against reduction commitments.
The revisions also modernise the Scope 3 boundary itself. Most notably, the GHG Protocol proposes a new Category 16 for "other value chain activities," covering facilitated emissions and licensing-related activities not clearly captured in the existing 15-category structure. This is especially relevant for companies with platform, franchise, software, logistics, and intermediary business models, where value-chain influence exists without direct ownership of the emitting activity. For these organisations the current standard has always been an imperfect fit; Category 16 would give them a defined home for emissions that are currently either omitted or shoe-horned into categories that do not quite apply.
Finally, the proposals strengthen investment emissions reporting under Category 15. The draft indicates that all investments in scope would be required to be included, that investee Scope 1, 2, and 3 emissions would all fall within the reporting boundary, and that some financial activities such as insurance and underwriting may shift into the new optional Category 16. For companies already preparing for climate disclosure under ISSB, CSRD, or national climate-reporting regimes, the direction is consistent with what those frameworks are also pushing toward: greater completeness, stronger evidence, and less flexibility in what can be left out. The practical implication is that Scope 3 data collection, verification, and governance processes need to start improving now, well ahead of any final standard.
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