Are your “zero-emission” kilowatt-hours really zero-emission at all times of the day and night? Is your carbon footprint still a black box containing average indicators? These types of doubts and nuances related to carbon dioxide emissions are fueling the growing discussion about decarbonization. In this article, we would like to answer the question not so much of “whether to count” but “how to count” so that the figures provided are meaningful for knowledge and decision-making that takes into account real environmental impacts, reduction plans, order portfolios, and audits.
Over the years, we have learned to efficiently “do our homework” for Scopes 1 and 2, and cover the rest with a thick veil of “market averages.” But business does not operate on averages. It operates here and now — both at 7 p.m. in January, when your production line needs power, and in August, when the warehouse is running at half speed. The first option is a situation where your “green” energy may exist mainly on paper, rather than in the actual energy mix used. However, the moment is fast approaching when not only auditors but also customers will be asking about hourly demand coverage and local energy compliance.
And what about Scope 3? We know that this is usually the biggest piece of the cake—and the most difficult. From an accounting perspective, we would like to convert emissions spent by a single multiplier and close the case. However, true knowledge of the supply chain involves collecting and managing real primary data from suppliers, not just virtual indicators from publicly available tables. These are what determine whether an offer labeled “low-carbon” is credible, comparable, and will stand up in a tender.
In response to all this indicator confusion, new trends are emerging in the form of the largest GHG Protocol update in years, which aims to align the rules with our reality. In terms of Scope 2, it is based on a shift from “certificates per year” to time and place granularity. In Scope 3, we turn away from “big averaging” towards higher quality data and clearer boundaries. In the background, you can hear the choir of regulations, which, in the authors’ intentions, are meant to organize and unify the effort to limit greenhouse gas emissions. In response to the EU’s very ambitious goals for decarbonization and broadly defined sustainable development, ESRS/CSRD standards were implemented in 2024/2025, and then work began on implementing the VSME standard to organize and make realistic expectations for SMEs. Meanwhile, the CBAM standard shifts the burden to reliable data on real emissions. The direction is clear: fewer declarations, more evidence.
What is all the fuss about, and why now?
More than a decade after the publication of the main GHG Protocol documents, the world has “caught up” with spreadsheets. Businesses, regulators, and auditors began to demand that the data provided in reports reflect the physics of the system (e.g., where and when electricity actually flows) and a true picture of the supply chain, rather than a set of averaged indicators. Hence, the most significant review of standards in years:
Scope 2: In July 2025, the GHG Protocol ISB approved the submission of proposed changes to the location and market approach for consultation, with the public consultation itself announced for fall 2025. Its aim is, among other things, to clarify the hierarchy of emission factors and to achieve a closer temporal and geographical alignment between energy consumption and evidence of its “greenness.” The publication of the revised text of the GHG Protocol, which is the first phase of the entire process, is expected in the first half of 2026.
Scope 3: In January 2025, the Standard Development Plan – a map of changes for the standard and calculation guidelines – was published. Among the planned actions, it was planned to define clearer boundaries, materiality, and hierarchy of data quality that is a priority for primary data from suppliers where it is key, as well as better disclosure templates and convergence with financial practices. These are actions planned for the long term (at least until 2028), but the direction of the changes has already been officially announced.
Corporate Standard (third edition): the revision of the “main manual” (Corporate Standard) is taking place in parallel, so that the entire “corporate set” is consistent with the new expectations of the market and regulators.
Also, the EU regulations regarding the ESRS standard should not be forgotten. Currently, it is a binding legal act (delegated act 2023/2772), and Poland implemented the CSRD in December 2024 (amendments to the Accounting Act, among others). This means that the first companies have started reporting, and auditors are checking where the numbers and metadata come from. Of course, the future of this standard in light of the Omnibus, which significantly changes the current reporting requirements and scope, is highly uncertain, but many procedures are still implemented based on this standard.
The planned changes are intended to facilitate the functioning of SMEs and at the same time respond to growing expectations regarding the quality of supply chains. In July 2025, the Commission adopted a recommendation on a voluntary reporting standard for SMEs (VSME) to organize requests from large companies to their suppliers. These efforts aim to develop a common language and reporting framework that will reduce the chaos in surveys and spreadsheets. In parallel, in the “Omnibus I” package, the Commission signaled its desire to relieve smaller companies of reporting. However, the core in the form of the need to collect and process reliable data remains the same.
Another extremely important cornerstone of the improvements being introduced is the CBAM – a carbon border tax within the EU. After a transition phase conducted in 2023–2025, the mechanism enters its target period from January 1, 2026. From a practical standpoint, this translates to a demand for reliable data on emissions related to the trade of goods. This means that even if you don’t import yourself, someone in your supply chain probably does.
This is compounded by the assurance factor, or the embedding of reporting in auditing. Since the data is to be controlled (first in a limited scope and eventually in an expanded scope), it must be reproducible, comparable, and provided with metadata. This highlights the importance of details that until recently seemed unnecessary, such as:
– hourly energy consumption profile,
– residual mix (energy mix in the system after subtracting the energy to which the “green” attributes were assigned),
– certificate geography (in which market/country/balancing system the energy was generated),
– versions and sources of the emission factors in Scope 3,
– competition and tenders.
Larger clients, financial institutions, and public administration are increasingly requesting specific categories, periods, geographies, and data quality. This is due to the actual reduction commitments and regulatory risk in the chain.
In summary, we are currently experiencing a convergence of three vectors: (1) the GHG Protocol update (i.e., new rules of the game in Scope 2 and 3), (2) the hard ESRS/CSRD framework evolving towards VSME (i.e., auditable reports in the EU, including in Poland), and (3) market pressure (CBAM, customer requirements). That’s why we’re in the best position to summarize the data so far.
Scope 2: from “paper” to “physics” and why 24/7 matters
Imagine a factory that boasts a “zero” energy footprint in its report. It has documents confirming the guarantees of origin, elegant graphs, and green icons. However, the highest consumption is recorded during winter evenings, when the energy system barely meets the demand, and the mix includes more conventional sources. The “green” energy visible on the certificate was produced in the summer at noon in another market zone. This is where the core of the changes in Scope 2 begin: we move from numbers on paper to data that reflects the time and place of actual consumption.
Previously, two perspectives coexisted. In the locational method, you describe the world as it is “outside the window”: you count emissions according to the average grid mix in the place of operation. In the market method, you show the impact of your purchasing decisions: contracts, guarantees of origin, and certification systems. Both perspectives are needed, but for years it was too easy to label the source of energy as green by buying annual certificates from a distant market. The scope 2 review does not eliminate the market method; on the contrary, it wants to tie it to the physics of the system. If you say you use clean energy, show that it covers your consumption profile during the same hours and in the same market zone. In practice, this is a step towards the so-called 24/7 CFE. Instead of saying “we have so many MWh from renewable energy sources per year,” the question is asked: “At 7:00 PM in January, when the line is running at full speed, do you also have real coverage with green energy?”
With this, the role of the parameter that has been only an afterthought so far is growing — residual mix. This is the “remainder of the mix” left after subtracting the energy to which the attributes of greenness were assigned through the certificates held. The new approach is aimed at the reporting entity indicating the residual mix that was indicated and the origin of the factors used to calculate the declared emission. For the auditor, metadata such as:
- year and geography of the rate,
- system operator,
- the method of determining the mix,
- contract parameters of the electricity purchase agreement (including: age of the installation used for its production),
- for certificates: when and where the MWh assigned to them was generated.
The term “hourly” sounds ominous, but it’s not about every company suddenly becoming an energy trader. It’s about direction – certificates and contracts are to more accurately reflect the demand profile, not just the annual balance. From a business perspective, this means a change in the structure of purchases – long-term energy purchase agreements with a specific installation in the same market zone will have greater value, contracts with profiling closer to your consumption, and eventually granular certificates that allow you to document coverage at specific hours. Therefore, it is worth considering additional demand-side options, such as flexible scheduling of energy-intensive processes, energy storage, or modernization of heat and cold sources. They can help reduce the “gap” in peak energy consumption hours, which is when it is most difficult to prove the green origin of the energy.
What does this look like in practice in Poland? If your installation is located in the Wielkopolska region, purchasing an annual guarantee of origin from a wind farm on the Iberian Peninsula only partially fulfills the idea of market reporting of the green origin of the purchased energy. A much stronger proof would be a PPA (power purchase agreement) from a domestic source—preferably one whose production profile, for example, partially supplemented by an energy storage facility, overlaps with your consumption profile. You don’t need to have a perfect match right away. It’s enough to understand where and when your consumption “escapes” from the green coverage: winter, evenings, morning starts, weekend peaks. These are the windows that you will see in the report, and they will be the focus of the conversation with the auditor or client in the future.
In this world of data, order gives an advantage. Even if you don’t have hourly counters yet, you can reconstruct an approximate profile based on billing data and work schedule. It is important to link every purchasing decision to documentation from now on, so that you can answer questions about energy. Ultimately, Scope 2 doesn’t require perfect matching right away. It forces an honest answer to a simple question: Is your claim of clean energy true in the time and place in which you actually work? Companies that can demonstrate this, even partially, and with a plan to reach the required green energy participation indicators, gain peace of mind during audits and an advantage in tenders. And that is the kind of “granularity” we are aiming for.
3. Scope 3: from “high-level averaging” to “defendable data”
Imagine that your company is a house, and Scope 3 is both the attic and the basement: that’s where we store the most things, but the light is poor, and the boxes are labeled as “miscellaneous” and “to be reviewed.” It’s no wonder that for years it was tempting to put a big shelf here with the words “may be useful” (read: average indicators × expenses) and consider the matter closed. But soon, customers and auditors will require not stories, but
What we actually call the Scope 3 and why is it that important?
Scope 3 these are emissions beyond your direct operational control:
- with suppliers (raw materials, semi-finished products, transportation),
- with clients (usage and the end of product life),
- in capital (machines, buildings),
- in side activities (delegations, employee commutes).
In manufacturing companies, the lion’s share is usually in the categories: Purchased goods and services, Capital goods, Transport and distribution, and Product use and end of life. In services and finance, the burden shifts to non-productive purchases and, in the case of financial institutions, to financed emissions. The scale can reach 70-90% of the total footprint, so the way Scope 3 is calculated is usually the most important.
Why is “expenditure × indicator” alone no longer sufficient?
The spend-based method is like a weather map from last year: it’s good for a general idea of expected weather conditions, but it’s not enough to navigate during a storm. This method provides a general picture, but it blurs the qualitative and quantitative issues. There are various types of steel with different carbon and alloy contents, and “logistics” can mean a domestic truck or air transport halfway around the world. Moreover, such a calculation can be non-transparent: the indicator was taken from database X, from year Y, country Z — in such a situation, the auditor may ask why exactly these parameters were taken into account and how well they fit your chain. It is worth being prepared for such a question and demonstrating a factual argument.
New market expectations are moving towards a hierarchy of data quality. First, we look for primary data (the supplier declares the emission or energy consumption for a specific material/component), or, if this is not possible, we use process modeling (e.g., LCA for a given product). Then, we use averaged indicators (expense or product-based). It’s not about immediate perfection, but about a transition plan: where and when we will replace “average” with “specific”.
How can this be arranged to make sense and be feasible at the same time?
- Begin with „hotspots”, not everything at the time. Perform a quick screening: Which of the 3–5 categories accounts for 70–80% of Domain 3 for you? In production, these are usually raw materials/semi-finished products and transportation; in services, non-production purchases; in finance, the portfolio. Select
one product,one line,several of the largest suppliers. This is the best starting point because every percentage of data quality makes the biggest difference. - Set the boundaries and units before you collect a byte of information.
For the products:
- a functional unit (e.g. 1 item of product, 1 m² of panels, 1 MWh of energy),
- system borders (what we count and what we don’t count consciously),
- period and geography (the effects of transportation and energy mix are different in Poland than in Italy).
For the Purchasing:
- catalog material codes,
- assign them typical emission factors only where you really can’t get the primary data,
3. Agree on a “data language” with suppliers. If you ask 50 companies for “emissions”, you will get 50 different formats. Establish a short specification:
- what exactly are you collecting (e.g., kWh, liters of fuel),
- for what period,
- What method was used (original measurements, LCA, database X),
- What file format and how often.
Add a mini-quality checklist (year, country, data source). “Short but comparable” data are better than random megatables.
4. Give the expenditure method a “second life,” but do it consciously. It is needed, especially at the start and with the “long tail” of suppliers. However, it is worth strengthening it: match the indicators to the industry, country, and year, and where possible—replace them with expenditure by product (per kg, m³, or unit). Regularly update the collected information and record subsequent reports—without this, you won’t be able to compare years.
5) Do not confuse reduction with offsetting and “avoided emissions.” Scope 3 is the photography of the current responsibility in the chain. You can (and should) discuss innovations that reduce a customer’s emissions, but separately—it doesn’t replace calculating your own emissions in Scope 1–3.
4. In summary: fewer declarations, more evidence
If your “zero” was annual and global, the new rules set the rules of the game at the hourly and local level. On the one hand, we have the largest GHG Protocol update in years, and on the other, the maturing EU framework (ESRS/CSRD, VSME, CBAM), and between them, the realities of tenders and audits. The common denominator? Credibility. Numbers not only have to look nice, but also be reproducible in time, place, and documents. We showed why “now”: GHG Protocol opens work on Scope 2 and organizes Scope 3. This is not a trendy trend – it is a paradigm shift: from “do you count?” to “how do you count and can it be defended?” The faster you organize your data and metadata, the fewer surprises you will encounter during the audit and supply chain analysis.
