GHG Protocol Scope 3 Rules Are Changing: What ASRS Reporters Need to Know

Why this matters for ASRS reporters

The GHG Protocol and AASB S2 are not separate systems — one depends directly on the other. When the GHG Protocol updates its Scope 3 standard, ASRS reporters do not get to decide whether the changes apply to them.

What's actually changing

The GHG Protocol is proposing the most significant update to its Scope 3 standard since 2011. The proposed revisions are still pre-consultation draft, but they signal where the standard is heading clearly enough to act on.

A 95% coverage threshold

Under the current standard, companies must justify any Scope 3 category exclusions, but there is no defined minimum. The proposed revision would require at least 95% of required Scope 3 emissions to be reported for an inventory to be conformant.

A new Category 16 for facilitated emissions

The proposed revisions would add Category 16 to capture value chain activities that don't fit elsewhere, including facilitated emissions, licensing arrangements, and certain financial services activities.

Mandatory data quality disaggregation

Companies would be required to break down their reported Scope 3 emissions by data type for each category — distinguishing between primary data, supplier-specific calculations, and spend-based or activity-based estimates.

Three practical steps worth taking now

1. Audit your Scope 3 coverage against all 15 required categories. 2. Classify data quality by category. 3. Review Category 15 if you're in financial services.