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Upcoming Changes to the Greenhouse Gas Protocol Scope 3 Standard

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The GHG Protocol Scope 3 Standard provides the globally recognised framework for accounting and reporting value chain greenhouse gas emissions that occur outside a company’s direct operations (Scope 1) and purchased energy (Scope 2).

It structures Scope 3 emissions into 15 categories, covering both upstream and downstream activities, such as purchased goods and services, capital goods, fuel- and energy-related activities, transportation and distribution, use of sold products, and end-of-life treatment.

The Standard is principles-based and deliberately flexible. It allows companies to:

  • define organisational and value chain boundaries
  • select activity data and emission factors based on availability
  • apply assumptions and screening approaches where primary data is not feasible

This flexibility has enabled widespread adoption across sectors, but it has also led to:

  • inconsistent interpretations between companies
  • limited comparability of reported Scope 3 inventories
  • significant differences in data quality and boundary choices

As Scope 3 data increasingly feeds into target-setting, transition plans, and regulatory reporting, these limitations have become more visible.

The Current State of the Scope 3 Revision Process

The GHG Protocol has initiated a comprehensive update of its core Standards and Guidances, including the Scope 3 Standard. A dedicated Technical Working Group (TWG) is reviewing the full framework, with the current aim of publishing a final revised Scope 3 Standard by 2027, based on the latest known timelines.

Importantly, this is not a light-touch update. The TWG is reviewing:

  • all 15 existing Scope 3 categories
  • category definitions and boundaries
  • data requirements and methodological options
  • and potentially the overall structure of the framework itself

While the discussions are ongoing and outcomes are not yet final, several key topics under consideration give a strong indication of where the Standard may evolve.

Areas currently under discussion include:

  • the potential introduction of a 16th Scope 3 category, possibly separating commodities held as investments from the current Category 15. This would be particularly relevant for energy intermediaries such as oil, gas, and electricity traders
  • the treatment of capital goods across activities, for example whether embedded emissions of vehicles used in upstream or downstream transport should be included more systematically
  • category-specific boundary clarifications, such as whether teleworking should be optional or mandatory under Category 3.7 (Employee commuting), or whether maintenance of sold products should be optional or required under Category 3.11 (Use of sold products)
  • a potential requirement for cradle-to-grave emission factors for fuels and/or energy across all Scope 3 categories, which is currently optional under the existing Standard

Taken together, these discussions point in a consistent direction. The GHG Protocol appears to be moving toward clearer boundaries, more consistent treatment across categories, and higher expectations around data completeness and quality.

At this stage, none of these changes are final. The revision process will continue over the coming years, with further consultation and refinement before formal publication.

What Does This Mean for Sustainability Consultants?

For sustainability consultants, the Scope 3 revision process has important implications, even years before the revised Standard is published.

In the short term, there is no change to the rules. The current Scope 3 Standard remains the authoritative framework, and all existing inventories, targets, and disclosures continue to rely on it. Advisory work must therefore remain firmly grounded in today’s requirements.

At the same time, the revision discussions are highly relevant for forward-looking advice. They provide early signals on how expectations around Scope 3 accounting may tighten over time. Consultants can already help clients anticipate this direction of travel by:

  • stress-testing current Scope 3 boundaries against likely future clarifications
  • identifying categories where optional treatments today may become mandatory
  • prioritising data improvements in areas likely to face higher scrutiny

More broadly, these developments reinforce a shift in how Scope 3 work is positioned. What was once largely a modelling exercise is increasingly becoming a data and systems challenge. Clients are looking for support not only with methodology, but with supplier engagement, data governance, auditability, and alignment across reporting, targets, and transition plans.

As Scope 3 expectations continue to rise, consultants who understand both the existing Standard and the trajectory of its revision will be best placed to guide organisations through the next phase of value chain emissions accounting — one defined by greater consistency, clearer boundaries, and higher data expectations.

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