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Renewables & Environment

Corporate carbon footprint: Scope 1, 2 and 3 and reporting duties after the Omnibus

How a company's carbon footprint is measured under the GHG Protocol and ISO 14064-1, how much electricity and gas weigh and who is required to report it after the revision of the CSRD.

4 min read

By IPGS ENERGYUpdated

The carbon footprint is the total quantity of greenhouse gases attributable to an organisation or a product, expressed in tonnes of CO2 equivalent (tCO2e). For organisations the references are the GHG Protocol Corporate Standard, which covers seven gases (CO2, CH4, N2O, HFCs, PFCs, SF6, NF3), and ISO 14064-1:2018; for products, ISO 14067:2018.

7
Greenhouse gases covered by the GHG Protocol
15
Categories of Scope 3 emissions
2
Calculation methods for Scope 2

Scope 1, 2 and 3

ScopeWhat it includesExamplesStarting data
Scope 1Direct emissions from owned or controlled sourcesBoilers and furnaces, company vehicles, processes, refrigerant gas leaksGas consumption per PDR, fuels, refrigerant top-ups
Scope 2Indirect emissions from the generation of purchased electricity, steam, heat and coolingGrid electricity, district heatingElectricity consumption in kWh per POD
Scope 3All other indirect emissions in the value chain, upstream and downstreamRaw materials, transport, business travel, use of sold productsPurchases, logistics, supplier data

The Corporate Standard requires at least Scopes 1 and 2 to be reported and leaves Scope 3 optional, although according to the GHG Protocol that is where the majority of a company's emissions come from.

Scope 2: two numbers, not one

The Scope 2 Guidance requires emissions from purchased electricity to be reported with two methods: location-based, which applies the average grid factor, and market-based, which uses the factors of contractual instruments. Guarantees of origin and PPAs affect only the latter. Anyone setting a target must disclose which of the two it is measured on.

The standards

  • GHG Protocol. Corporate Standard, Scope 2 Guidance (2015) and Corporate Value Chain (Scope 3) Standard (2011).
  • ISO 14064-1:2018. Emissions at organisation level, with requirements for verification of the inventory. Confirmed in 2024; ISO indicates that a revision is under way.
  • ISO 14067:2018. Carbon footprint of products, confirmed in 2024.

Who is required to report: status as of October 2026

The CSRD, transposed in Italy by Legislative Decree 125/2024, was amended by Directive (EU) 2026/470 of the Omnibus package, published on 26 February 2026. From financial years starting on or after 1 January 2027 the obligation concerns only undertakings, or groups on a consolidated basis, exceeding both EUR 450 million of net turnover and 1,000 employees on average. For financial years 2024–2026 the first-wave companies remain obliged, and Member States may exempt for 2025 and 2026 those below the new thresholds.

Member States must transpose the changes by 19 March 2027. As of 10 October 2026 the latest update of Legislative Decree 125/2024 on Normattiva dates back to 9 August 2025: the Italian transposition does not yet appear in the text in force.

From 2027 those remaining below these thresholds have no obligations of their own. Companies with up to 1,000 employees that supply an obliged company are "protected undertakings": they may decline data requests that exceed the voluntary standard, based on the VSME (Recommendation (EU) 2025/1710), whose basic module asks for energy consumption and Scope 1 and location-based Scope 2 emissions. On 3 July 2026 the Commission adopted two delegated acts: voluntary standards and simplification of the ESRS.

For a business: what to look at

When it is worth measuring

When a customer subject to reporting, a bank or a tender asks for the data; before deciding efficiency investments or an energy audit, to know where emissions are concentrated; when the cost of CO2 begins to weigh on gas and fuels (see the ETS).

What is needed

  • twelve months of electricity consumption for every POD and of gas for every PDR;
  • fleet fuels and refrigerant gas top-ups;
  • a defined boundary (sites, subsidiaries) and a base year;
  • emission factors with stated source and year.

Typical mistakes

  • estimating emissions from spend rather than from quantities consumed;
  • comparing years calculated with different boundaries or methods;
  • reporting only market-based Scope 2, omitting the location-based figure;
  • presenting as complete a Scope 3 that covers few categories.

What can and cannot be claimed

A business can state the emissions of a year, broken down by Scope, indicating standard, boundary and method, and specifying whether a third party has verified them. It cannot present as a reduction a fall due only to a change of method, nor attribute to guarantees of origin effects on Scopes 1 and 3. Since 27 September 2026 the rules of Directive (EU) 2024/825 prohibit telling consumers that a product has a neutral impact on the basis of the offsetting of emissions.

This work is part of the energy sustainability service for businesses.

If you want to start from the electricity and gas data your company already has, IPGS ENERGY examines them as a consultant independent of suppliers: Request a conversation.

Sources

Informational content by IPGS ENERGY. Information is reviewed as of the stated update date and does not replace a contractual, tax or regulatory assessment specific to an individual business.

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