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Scope 3 Emissions · Value Chain Disclosures

Scope 3 reporting under UK SRS: value chain emissions disclosure

UK SRS S2 requires an entity to consider all 15 GHG Protocol Scope 3 categories and to disclose which are included in its Scope 3 figure.

Under the FCA’s final rules (PS26/19, 30 September 2026), listed companies in scope report Scope 3 on a comply-or-explain basis from accounting periods beginning 1 January 2027, with a one-year relief from disclosure — finalising CP26/5.

Overview

Scope 3 in UK SRS S2: the obligation, in two steps

Scope 3 reporting under UK SRS — indirect emissions across an entity’s value chain — is the most technically challenging part of UK SRS S2 implementation.

UK SRS S2 paragraph 29(a)(i) requires disclosure of absolute gross greenhouse gas emissions classified as Scope 1, Scope 2 and Scope 3, and paragraph 29(a)(vi) requires the entity to disclose which categories of the GHG Protocol Corporate Value Chain (Scope 3) Standard are included in its Scope 3 figure.

The FCA’s final rules recognise the practical challenges of Scope 3 data collection in two steps.

For accounting periods beginning on or after 1 January 2027, listed companies in scope report against UK SRS on a comply-or-explain basis, and a company may use one year’s relief from disclosing Scope 3.

After that year Scope 3 is disclosed, or its omission explained, like every other UK SRS disclosure.

The consultation, CP26/5, had proposed a mandatory UK SRS S2 core with Scope 3 outside it; the final rules put all of it on comply or explain, so there is no hard obligation for Scope 3 to graduate into.

Phasing for listed companies — final rules

  1. 1 Jan 2027
    UK SRS S1 and S2, comply or explain

    A company may use one year’s Scope 3 relief, stating that it is doing so.

  2. After year 1
    Scope 3, disclose or explain

    The relief is used up. Disclose Scope 3, or explain why not.

  3. Throughout
    Never mandatory

    The final rules adopt comply or explain across all categories of disclosure.

FCA PS26/19 ¶¶1.7, 3.12, 3.14, 3.20 — final rules, 30 September 2026

What S2 asks for

What Scope 3 covers under UK SRS S2

Scope 3 emissions are all indirect emissions that occur in an entity’s value chain, excluding Scope 2 emissions (purchased energy).

UK SRS S2 paragraph 29(a)(ii) requires greenhouse gas emissions to be measured in accordance with the GHG Protocol Corporate Standard unless a jurisdictional authority or exchange requires otherwise, and paragraph 29(a)(vi) frames Scope 3 by the 15 categories of the GHG Protocol Corporate Value Chain (Scope 3) Standard.

Paragraph 29(a) requires disclosure of:

  • Absolute gross Scope 3 emissions in metric tonnes of CO2 equivalent for the reporting period (¶29(a)(i)(3)).
  • Categories included — which of the 15 categories are in the entity’s measure of Scope 3 (¶29(a)(vi)(1)).
  • Measurement approach — the approach, inputs and assumptions used, and why they were chosen (¶29(a)(iii)).
  • Changes — any changes to the approach, inputs or assumptions during the period, and the reasons (¶29(a)(iii)(3)).

Paragraph B32 requires the entity to consider its entire value chain, upstream and downstream, and all 15 categories.

Which categories carry material information is a judgement made under the materiality principle in UK SRS S1, so the Scope 3 materiality assessment sits at the front of the exercise rather than the end.

The GHG Protocol Scope 3 Standard itself takes a stricter line: companies account for all Scope 3 emissions and disclose and justify any exclusions.

15
GHG Protocol Scope 3 categories an entity must consider under UK SRS S2 ¶B32, disclosing which are included
Consider is not report

Considering all 15 categories is not the same as reporting all 15.

The Standard asks the entity to disclose which categories are included, and ¶B33 makes that disclosure a requirement whatever measurement method is used.

The framework

The 15 GHG Protocol Scope 3 categories

UK SRS S2 adopts the GHG Protocol category framework: every category is considered, and the entity discloses which are included.

Upstream activities · Categories 1–8

Category 01

Purchased goods and services

Emissions from the production of goods and services purchased during the reporting period.

Category 02

Capital goods

Emissions from the production of capital equipment and infrastructure purchased during the reporting period.

Category 03

Fuel- and energy-related activities

Emissions from the production of fuels and electricity purchased that are not included in Scope 1 or 2.

Category 04

Upstream transportation and distribution

Emissions from transportation and distribution services purchased, including inbound logistics.

Category 05

Waste generated in operations

Emissions from disposal and treatment of waste generated in operations.

Category 06

Business travel

Emissions from employee air, rail, road and other transport for business purposes.

Category 07

Employee commuting

Emissions from employee transport between home and work.

Category 08

Upstream leased assets

Emissions from operating assets leased by the reporting entity, not included in Scope 1 or 2.

Downstream activities · Categories 9–15

Category 09

Downstream transportation and distribution

Emissions from transportation and distribution services not paid for by the entity.

Category 10

Processing of sold products

Emissions from processing of intermediate products sold by the entity.

Category 11

Use of sold products

Emissions from the use of products sold by the entity over their expected lifetime.

Category 12

End-of-life treatment of sold products

Emissions from disposal and treatment of sold products at the end of their life.

Category 13

Downstream leased assets

Emissions from operating assets owned by the entity and leased to others.

Category 14

Franchises

Emissions from the operation of franchised assets.

Category 15

Investments

Emissions associated with the entity’s investments not included in Scope 1 or 2 — financed emissions sit here.

Category 15 for financial institutions

An entity whose activities include asset management, commercial banking or insurance must disclose additional information about its financed emissions, which form part of Category 15, under UK SRS S2 ¶29(a)(vi)(2) and ¶¶B58–B63A.

Paragraph 29A, carried over from the ISSB’s December 2025 amendments to IFRS S2 (December 2025 text), permits the entity to limit its Category 15 measure to financed emissions and to exclude emissions attributable to derivatives.

Timeline

Timeline and comply-or-explain framework

Under the FCA’s final rules, Scope 1, Scope 2 and Scope 3 emissions are all on a comply-or-explain basis for in-scope listed companies from accounting periods beginning 1 January 2027 — the consultation had proposed Scope 1 and 2 as mandatory.

Step 1: comply or explain, with the Scope 3 relief (from 1 January 2027)

Listed companies in scope report Scope 1 and Scope 2 emissions from accounting periods beginning on or after 1 January 2027, or explain why not.

For Scope 3, a company may use the one-year relief and simply state that it is doing so.

No further explanation is required during the relief period (PS26/19 ¶3.20).

A company that already discloses Scope 3 is free to keep doing so.

Step 2: Scope 3 disclose or explain (after the relief)

Once the relief year is used, listed companies either comply — disclose Scope 3 emissions in accordance with UK SRS S2, in full or in part — or explain.

The content of an explanation, as consulted on, is set out in CP26/5 paragraph 4.8.

What an explanation covered, as consulted

CP26/5 proposed that a company not disclosing Scope 3, once the relief was used, would identify:

  • the specific paragraphs of UK SRS S2 not complied with;
  • the reasons;
  • the steps being taken or planned to make the disclosures in future, with the timeframe.

FCA CP26/5 ¶4.8 — the consultation; check the final wording in PS26/19

Reliefs

Transition reliefs available

The reliefs are optional, and they run out — under the FCA’s final rules the Scope 3 relief lasts one year and the UK SRS S1 non-climate relief two.

FCA final rules · PS26/19 ¶¶3.14, 3.20

One-year Scope 3 relief

An in-scope company may use one year’s non-disclosure of Scope 3 under UK SRS S2, stating that it is doing so; no further explanation is required during the relief period. CP26/5 ¶¶8.6–8.12 had proposed the same length.

UK SRS S2 ¶C1

First-year relief on comparatives

No comparative information is required in the first annual reporting period in which the Standard is applied.

FCA final rules · PS26/19 ¶3.14

UK SRS S1 non-climate relief

Under the FCA’s final rules a company may use two years’ non-disclosure of UK SRS S1 non-climate matters. The two-year figure is the FCA’s, not the Standard’s — Appendix E of UK SRS S1 carries no time limit of its own.

UK SRS S2 ¶C3 · CP26/5 ¶8.7

Alternative measurement methods

In the first annual reporting period an entity may measure its emissions using a method other than the GHG Protocol Corporate Standard, provided it used that method in the immediately preceding period.

The FCA’s relief windows are one year (Scope 3) and two years (S1 non-climate matters).

CP26/5 paragraph 8.11 proposed a trap for early movers — a company that chose to comply with the new rules early would not have had the transitional reliefs available; check the final rules before applying early.

For a voluntary user of the Standard outside the FCA’s rules, the Scope 3 relief in UK SRS S2 paragraph C4 carries no time limit at all; it is the FCA’s rules, through paragraph C6, that limit it for listed companies.

How each scope sits under the FCA's final rules. Sources: UK SRS S2 ¶C1; FCA PS26/19 ¶¶1.7, 3.14.
ScopeTimelineRequirement typeFirst-year reliefSector focus
Scope 1From 2027Comply or explainNo comparative dataAll sectors
Scope 2From 2027Comply or explainNo comparative dataAll sectors
Scope 3From 2027, with a one-year reliefComply or explainNo comparative data, plus one year’s relief from disclosureVaries by category
Financed emissionsSame as Scope 3Category 15 specific methodologySame as Scope 3Financial institutions only

The explain limb

Explaining under comply-or-explain

Neither CP26/5 nor the final rules publishes a list of acceptable reasons for not disclosing Scope 3.

What CP26/5 proposed is the shape of the explanation: the specific paragraphs of UK SRS S2 not complied with, the reasons, and the steps planned to make the disclosures in future, with a timeframe.

The reasons companies most often give in practice fall into four groups: data availability, commercial sensitivity, technical measurement and resource constraints.

Whatever the reason, an explanation built to those three limbs will be a documented one.

Comply-or-explain is the basis for Scope 3 under the FCA’s final rules, as for every other UK SRS disclosure.

Explaining is a legitimate long-run position rather than a temporary indulgence — but it is a documented position, not a blank.

The cost of explaining

CP26/5 paragraph 4.11: a company that explains rather than complies on Scope 3 may not be able to state compliance with UK SRS — the Standards’ own compliance statement (UK SRS S1 ¶72) requires all applicable requirements to be met.

Reasons companies commonly give

Practice, not a CP26/5 list — the FCA publishes no list of acceptable reasons.
GroupWhat it looks like
Data availabilitySuppliers or value chain partners unable or unwilling to provide primary emissions data, particularly in complex international supply chains.
Commercial sensitivityDetailed value chain disclosure would reveal competitively sensitive information about supplier relationships, pricing or business model.
Technical measurementCategories where methodology is particularly complex or uncertain, such as lifetime use emissions of certain products.
Resources and systemsInsufficient internal resources or systems for comprehensive value chain data collection, particularly for smaller listed entities.

Materiality

Scope 3 materiality assessment by category

UK SRS S2 requires an entity to consider all 15 Scope 3 categories (paragraph B32) and to disclose which are included in its measure (paragraph B33).

Which categories carry material information is judged under the materiality principle in UK SRS S1, and the GHG Protocol Scope 3 Standard expects any excluded category to be disclosed and justified.

A Scope 3 materiality assessment therefore needs a documented basis for every category left out, not just for those brought in.

The GHG Protocol’s criteria for identifying relevant Scope 3 activities are a practical starting point: size and sector guidance are the quantitative tests, and influence, stakeholders, risk and outsourcing the qualitative ones.

Entities should document their materiality assessment methodology and review it annually as business activities and value chains evolve.

UK SRS S2 paragraph B34 requires a reassessment of which Scope 3 categories are included when a significant event or a significant change in circumstances occurs.

GHG Protocol Table 6.1 — identifying relevant Scope 3 activities

Source: GHG Protocol Corporate Value Chain (Scope 3) Standard, Table 6.1.
CriterionTest
SizeActivities expected to contribute significantly to total anticipated Scope 3 emissions.
Sector guidanceSize of emissions relative to what sector-specific guidance identifies as significant.
InfluencePotential emissions reductions the company could undertake or influence.
StakeholdersActivities deemed critical by customers, suppliers, investors or civil society.
RiskActivities that contribute to the company’s climate-related risk exposure.
OutsourcingActivities outsourced that were previously in-house, or that peers typically perform in-house.
OtherAny additional criteria the company or its sector develops.
Sustainability Reporting Standards · Scope 3 materiality

Which Scope 3 categories matter — by sector

Under UK SRS S2 (paragraph B32), an entity must consider its whole value chain and all 15 GHG Protocol Scope 3 categories, and disclose which categories its Scope 3 figure includes — it is not required to report all 15. The materiality lens means most companies will only have a handful of dominant categories. This matrix shows where the weight typically sits — though every company's exact profile differs.

Last verified 26 September 2026 · Indicative · Companies must conduct their own materiality assessment
Low
Med-low
Med
High
Very high
Not typical
Scope 3 categoryOil & GasFinancial ServicesUtilitiesManufacturingReal EstateRetail / ConsumerTech / SoftwarePharmaTransport
Upstream categories
1Purchased goods & servicesUpstreamMedMed-lowMedVery highMedVery highHighVery highMed
2Capital goodsUpstreamMed-lowLowMedMedHighMed-lowMedMedHigh
3Fuel- & energy-relatedUpstreamHighLowHighMedMed-lowMed-lowMed-lowMed-lowHigh
4Upstream transportationUpstreamMed—LowHighLowHighLowMedVery high
5Waste in operationsUpstreamMed-low—Med-lowMed-lowMed-lowMed-lowLowMed-lowLow
6Business travelUpstreamLowMedLowLowLowLowMedMedLow
7Employee commutingUpstreamLowMedLowMed-lowLowMed-lowMedMed-lowMed-low
8Upstream leased assetsUpstreamLowMed-lowLowLow—Med-lowMed-lowLowMed-low
Downstream categories
9Downstream transportationDownstreamMed—LowMed—HighLowMedVery high
10Processing of sold productsDownstreamMed—Med-lowMed—Med-low—Low—
11Use of sold productsDownstreamVery high—HighHigh—HighMedMed-lowMed-low
12End-of-life of sold productsDownstreamMed—LowMedLowMedMed-lowMed-low—
13Downstream leased assetsDownstreamLowMed-lowLowLowVery highLowLow—Low
14FranchisesDownstream————LowMedLow—Low
15Investments (financed emissions)DownstreamLowVery highLow—Low————
Where the weight sits

Most sectors have 2–3 dominant categories

The materiality lens means companies don't need to measure all 15 categories with equal rigour, though each must be considered and the categories included must be stated (paragraph B32). Oil & gas concentrates in Category 11 (use of sold products — i.e. customers burning the fuel). Financial services concentrates in Category 15 (investments — financed emissions). Real estate concentrates in Category 13 (downstream leased assets — tenant energy use). Retail typically spans Categories 1, 4, 9, and 11.

Paragraph B59A

Financial institutions carry an extra explanation duty

Paragraph B59A is a UK addition to IFRS S2, made in the final version of UK SRS S2. Where an entity determines it is impracticable to reliably estimate its financed emissions for the same reporting period as its financial statements, it must disclose why, the measurement approach, inputs and assumptions used for any financed emissions it does report, and its plan and timeline for reporting on an aligned period. It is a disclosure duty about period alignment, not a relief from the Category 15 requirements.

Don't ignore "Low"

Low materiality must still be assessed

UK SRS S2 requires all 15 categories to be considered (paragraph B32). A category marked "low" or "not typical" here is not automatically immaterial for a specific company — only that it's unlikely to be material across the sector. Companies must conduct their own materiality assessment and disclose which categories are included in their Scope 3 figure (paragraphs 29(a)(vi)(1) and B33).

Professional services firms often find business travel (Category 6) and employee commuting (Category 7) among the few material categories.

These patterns are indicative; every company’s profile differs.

Data

Data collection strategies and methodology

Successful Scope 3 implementation needs structured data collection that balances accuracy, cost and practicality.

Primary data collection

Primary · upstream

Supplier engagement programmes

Direct collection of emissions data from key suppliers, typically the largest by spend or emissions impact.

Primary · downstream

Customer and partner engagement

Working with customers and distributors to collect use-phase and end-of-life emissions data.

Primary · systems

Technology platforms

Supplier portals and data management systems that enable systematic data collection and validation.

Primary data gives the highest accuracy but requires significant investment in supplier relationships and systems.

Most entities focus primary data collection on the categories with the largest emissions or where they have the most influence.

Secondary data and calculation approaches

ApproachHow it works
Spend-basedProcurement spend data combined with emissions factors to estimate supplier emissions.
Activity-basedPhysical activity data — quantities, distances, energy use — combined with appropriate emissions factors, such as the UK government conversion factors published by DESNZ for UK activities.
Industry averagesSector-specific emissions factors for categories where specific data is not available.
HybridPrimary data from key suppliers combined with secondary calculations for smaller suppliers or categories.

The GHG Protocol’s Scope 3 Calculation Guidance sets out calculation methods for each of the 15 categories, including data quality and uncertainty considerations.

Technology and systems

Systems

Enterprise sustainability platforms

Integrated collection, calculation and reporting across all Scope 3 categories.

Systems

Supply chain integration

Links between sustainability data collection and existing procurement and supply chain systems.

Systems

Industry collaboration platforms

Sector initiatives for coordinated data sharing and methodology development.

Systems

Assurance and verification tools

Data quality control and preparation for external assurance.

Financial institutions

Financial institution requirements

UK SRS S2 ¶29(a)(vi)(2) and ¶¶B58–B63A impose additional requirements on entities whose activities include asset management, commercial banking or insurance, for the financed emissions that form part of Category 15.

Source: DBT, UK SRS S2 (25 Feb 2026), ¶¶B58–B63A.
ActivityParagraphsMust disclose
Asset management¶B61Absolute gross financed emissions by Scope 1, 2 and 3; total AUM included; percentage of total AUM included, with an explanation of exclusions; methodology, including the allocation method.
Commercial banking¶¶B62–B62AAbsolute gross financed emissions by Scope for each industry by asset class; gross exposure to each industry by asset class, with undrawn loan commitments shown separately; percentage of gross exposure included, with an explanation of exclusions; methodology and allocation method.
Insurance¶¶B63–B63AAbsolute gross financed emissions by Scope for each industry by asset class; gross exposure to each industry by asset class; percentage of gross exposure included; methodology and allocation method.

The Standard is methodology-agnostic: it does not name the PCAF Global GHG Accounting and Reporting Standard for the Financial Industry, although PCAF is the method most financial institutions use for the attribution step.

Paragraph B59A is the one place where UK SRS S2 asks for more than IFRS S2.

Where an entity determines that it is impracticable to reliably estimate its financed emissions for the same reporting period as its financial statements, B59A requires it to disclose why, the measurement approach, inputs and assumptions used for any financed emissions it does report, and its plan, including the timeline, to bring the two periods into line.

B59A is a duty, not a relief

It is an added disclosure duty triggered by a timing mismatch, not a general relief from financed emissions reporting.

Recorded in Annex A of the DBT consultation response.

Planning

Implementation planning

Given the comply-or-explain timeline and the complexity of value chain data collection, entities should begin Scope 3 preparation well ahead of the end of the one-year relief.

The sequence runs from materiality and supplier strategy, through pilots and systems, to full collection, controls and drafting.

Companies that wait until 2027 to begin serious Scope 3 preparation are likely to find themselves relying on the explain option rather than disclosing once the relief ends.

Working back from the end of the relief

  1. 12–18 months
    Before the effective date

    Materiality assessment, supplier engagement strategy, technology platform selection.

  2. 6–12 months
    Before the effective date

    Supplier engagement programme launch, data collection pilots, internal systems development.

  3. 3–6 months
    Before the effective date

    Full data collection, methodology documentation, internal controls testing.

  4. Pre-reporting
    Before the report is drafted

    Board and audit committee education, assurance provider engagement, disclosure drafting.

Consider early voluntary disclosure

Disclosing Scope 3 in the first in-scope year, rather than using the relief, tests systems and processes before the relief would have ended.

The FCA said its rules would not prevent a company that already discloses Scope 3 from continuing to do so.

Assurance

Assurance considerations

The FCA’s final rules do not require assurance; where a listed company obtains it, it names the assurance provider, which disclosures were assured and which assurance standards were used (PS26/19 ¶2.45).

Scope 3 emissions still present particular challenges for assurance providers and for entities considering voluntary assurance.

The FRC’s ISSA (UK) 5000 standard, issued on 12 November 2025 for voluntary use, governs how a sustainability assurance engagement is performed if one is commissioned.

Practical guidance specific to Scope 3 assurance is still developing as market practice evolves.

To fold Scope 3 preparation into a wider programme, see our UK SRS compliance guide, the clause-by-clause reference for UK SRS S2, and the editorial UK SRS timeline.

Assurance is not required

Under the FCA’s final rules, where assurance is obtained the company names the provider, which disclosures were assured and which assurance standards were used.

Where Scope 3 assurance gets hard

IssueWhy
Data source verificationSupplier-provided data needs coordination between the assurance provider and supplier systems.
Methodology appropriatenessWhether the primary or secondary data approach is appropriate for each category.
CompletenessWhether all material categories have been identified and included.
Comply-or-explainFor entities that explain, the adequacy of explanations and improvement plans.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.

Checked against 10 sources fromGHG ProtocolDepartment for Business and TradeFinancial Conduct AuthorityIFRS FoundationDepartment for Energy Security and Net ZeroPartnership for Carbon Accounting Financials
  1. GHG Protocol
    Corporate Value Chain (Scope 3) Standard

    The 15-category framework UK SRS S2 ¶29(a)(vi) and ¶B32 refer to, and the Table 6.1 relevance criteria.

  2. Department for Business and Trade
    UK SRS S2 Climate-related Disclosures — final standard (PDF)

    Published 25 February 2026. ¶29(a), ¶29A, ¶¶B32–B34, ¶¶B58–B63A and Appendix C.

  3. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    First published 30 September 2026. The final rules: comply or explain across the UK SRS (¶1.2, ¶1.7); one year’s Scope 3 relief (¶3.14), stated as used (¶3.20); assurance (¶2.45).

  4. Financial Conduct Authority
    CP26/5: Sustainability disclosures

    The consultation PS26/19 finalises: the Scope 3 explain limb it proposed (¶4.8) and its draft reliefs (¶¶8.6–8.12).

  5. Department for Business and Trade
    UK SRS consultation response (PDF)

    Annex A records the untimed Scope 3 relief and the added paragraph B59A.

  6. IFRS Foundation
    IFRS S2 Climate-related Disclosures — December 2025 text

    The ISSB text UK SRS S2 is based on, including the December 2025 amendments on Category 15 and financed emissions (¶¶29A–29C, B58–B63A).

  7. GHG Protocol
    Scope 3 Calculation Guidance

    Category-by-category calculation methods, data quality and uncertainty guidance.

  8. Department for Energy Security and Net Zero
    Greenhouse gas reporting: conversion factors 2026

    UK conversion factors used in activity-based Scope 3 calculations.

  9. Partnership for Carbon Accounting Financials
    Global GHG Accounting and Reporting Standard for the Financial Industry

    The financed emissions method most institutions use for Category 15. UK SRS S2 does not mandate it.

  10. Financial Reporting Council
    ISSA (UK) 5000 issued (12 November 2025)

    The FRC sustainability assurance standard, issued for voluntary use.

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