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Scope 3 · Requirements
The Scope 3 reporting requirements in the UK are partial and scattered: no law asks a company for its whole value chain, but listed companies, unquoted SECR reporters, government suppliers, finance firms and pension trustees each meet a different slice.
The widest is the FCA’s, which from 1 January 2027 puts listed companies on comply or explain for UK SRS S2, with one year’s Scope 3 relief.
This page sets each rule out, with its provision, and marks what remains voluntary.
In one table
Each row is a separate duty with its own trigger, and none of them asks for the full value chain without an escape route.
The measurement side, category by category, is on the Scope 3 emissions reference.
| Regime | Who | Scope 3 asked for | Basis | Provision |
|---|---|---|---|---|
| UK SRS S2 under the FCA rules | Listed companies in UKLR 6, 14, 15, 16 and 22 | Gross Scope 3; all 15 categories considered; those included disclosed | Comply or explain from periods beginning 1 Jan 2027; one-year relief | S2 ¶29(a)(i)(3), ¶B32; UKLR 6.6.6R(7A); TP 16 |
| UK SRS S2, voluntary use | Any entity | As above | Voluntary; ¶C4 relief has no time limit | S2 ¶C4 |
| SECR, unquoted companies and LLPs | Exceeding two of £36m turnover, £18m balance sheet, 250 employees | Emissions from fuel consumed for transport the company is responsible for | Statutory, directors’ report or LLP energy and carbon report | Sch 7 ¶¶20D(1)(b), 20K |
| SECR, quoted companies | Every UK quoted company | None | Statutory | Sch 7 ¶15 |
| PPN 006 Carbon Reduction Plan | Bidders for in-scope central government contracts above £5m a year including VAT | Categories 4, 5, 6, 7 and 9 | Condition of participation in a procurement | PPN 006; Technical Standard |
| Companies Act climate disclosures | Traded, banking, insurance, AIM and high-turnover companies over 500 employees | No emissions figure required | Statutory, strategic report | s.414CB(2A) |
| FCA ESG sourcebook | In-scope asset managers and asset owners | Scope 1, 2 and 3 data for a product, on a client’s request | Rule, once a year per product | ESG 2.3.5AR |
| Occupational pension schemes | Trustees of in-scope schemes | Scope 1, 2 and 3 of scheme assets, as far as able | Statutory; Scope 3 excused in the first scheme year | SI 2021/839 Sch ¶¶18–19 |
| CSRD (EU) | EU undertakings and non-EU parents meeting the Omnibus I tests | Scope 3 from each significant category | EU law, financial years from 2027 under revised ESRS | ESRS E1-8 |
Every regime on this page sits in the wider map of UK duties on the sustainability reporting requirements hub.
Which rule reaches you
A Scope 3 requirement in the UK is always switched on by something other than Scope 3 itself: a listing, a size test, a bid or an investment book.
The trigger decides how much of the value chain is asked for, so two organisations of the same size can face very different duties.
A large private company that bids for no government work and has no listing meets only SECR’s transport-fuel limb.
A listed bank meets UK SRS S2 in full, including financed emissions, on a comply-or-explain basis.
The UK carbon reporting requirements register lists every duty side by side, whether or not it touches Scope 3.
UKLR 6, 14, 15, 16 or 22: gross Scope 3 under UK SRS S2, comply or explain after one relief year.
FCA PS26/19Large unquoted company or LLP: transport fuel it is responsible for, inside SECR.
Sch 7 ¶20D(1)(b)Contract above £5m a year: five named categories in a Carbon Reduction Plan.
PPN 006Finance firm or pension scheme: financed or portfolio emissions, Category 15.
UK SRS S2 ¶29(a)(vi)(2); SI 2021/8391 · UK SRS S2
UK SRS S2 ¶29(a)(i)(3) requires absolute gross Scope 3 greenhouse gas emissions for the reporting period, in metric tonnes of CO2 equivalent.
¶B32 requires the entity to consider its entire value chain and all 15 Scope 3 categories, and to disclose which categories it has included.
¶B33 adds that, whatever method is used, the categories included must be disclosed.
¶¶B38 to B57 set the measurement framework: inputs prioritised by direct measurement, value-chain specificity, timeliness and verification, with primary data preferred all else being equal.
¶B57 presumes that Scope 3 can be estimated reliably from secondary data and industry averages, so a spend-based estimate is not ruled out.
The standards were issued by the Department for Business and Trade on 25 February 2026 as voluntary standards, and ¶C4 relieves Scope 3 with no time limit for anyone applying them voluntarily.
For listed companies the FCA’s PS26/19 sets a comply-or-explain basis across all of UK SRS for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
Its ¶3.14 gives a relief from Scope 3 disclosure for one year from initial application, and ¶3.20 says that a company using it states the use and needs give no further explanation during the relief period.
For periods beginning on or after 1 January 2028 the relief has expired for new periods, and a company discloses Scope 3 or explains which requirements it has not met, why, and what it is doing about it under UKLR 6.6.6R(7A).
The FCA kept the requirement for climate disclosures and explanations, including on Scope 3, to sit in the annual report, with cross-referencing allowed where UK SRS S1 permits it.
The paragraph-level detail is on the UK SRS Scope 3 reporting guide and the UK SRS S2 reporting requirements page.
UK SRS S2 ¶C4, the standard’s own Scope 3 relief, has no time limit.
The FCA’s relief in UKLR TP 16 lasts one year from initial application and binds only listed companies within its rules.
¶B41 of UK SRS S2 still cites “C4(a)”, a cross-reference carried over from IFRS S2; the GHG-method relief it means is UK SRS S2 ¶C3.
2 · SECR
SECR asks large unquoted companies and LLPs for emissions from the combustion of gas, the consumption of fuel for the purposes of transport, and purchased electricity, under Schedule 7 ¶20D.
Paragraph 20K defines “for the purposes of transport” as consumption by an aircraft, road-going vehicle, train or vessel on a journey that starts, ends, or starts and ends in the UK.
The Environmental Reporting Guidelines say that only transport where the organisation is responsible for purchasing the fuel is required for unquoted companies and LLPs.
That reaches some business travel, which the GHG Protocol would place in Scope 3 rather than Scope 1.
DESNZ’s 2026 post-implementation review describes it as “a small amount of Scope 3 emissions from business travel”, and records that interviewees found the selective inclusion confusing.
No other Scope 3 category appears anywhere in Part 7A.
Quoted companies report under Part 7, which asks for global emissions from fuel combustion, the operation of facilities and purchased electricity, heat, steam or cooling, and carries no Scope 3 limb at all.
A company is a large unquoted company only if it exceeds at least two of £36m turnover, £18m balance sheet total and 250 employees, applied on the two-year rule; the full test is on the SECR reporting requirements page.
3 · PPN 006
PPN 006 asks bidders for in-scope central government contracts to provide a Carbon Reduction Plan, for procurements commenced from 24 February 2025.
It applies to central government departments, their executive agencies and non-departmental public bodies, for contracts with an estimated value above £5 million a year including VAT, averaged over the life of the contract.
The Technical Standard requires all Scope 1 and Scope 2 emissions and five Scope 3 categories, each to the GHG Protocol’s minimum boundary.
The footprint covers the organisation’s emissions from sources in the UK, and the plan confirms a commitment to net zero by 2050 at the latest.
The plan is published on the supplier’s UK website and reviewed within six months of each financial year-end.
It is a condition of participation in a specific procurement, not a legal duty on companies generally.
The Carbon Reduction Plan guide covers the template, and the Carbon Reduction Plan reporting requirements page the duty itself.
| GHG Protocol category | In a CRP? |
|---|---|
| 1 Purchased goods and services | No |
| 2 Capital goods | No |
| 3 Fuel- and energy-related activities | No |
| 4 Upstream transportation and distribution | Yes |
| 5 Waste generated in operations | Yes |
| 6 Business travel | Yes |
| 7 Employee commuting | Yes |
| 8 Upstream leased assets | No |
| 9 Downstream transportation and distribution | Yes |
| 10–15 Processing, use and end of life of sold products, downstream leased assets, franchises, investments | No |
4 · Companies Act climate disclosures
Section 414CB(2A) of the Companies Act requires eight climate-related financial disclosures in the strategic report of traded, banking, insurance, AIM and high-turnover companies with more than 500 employees.
The eight are governance, risk identification, risk integration, principal risks and opportunities, their impacts, scenario resilience, targets and key performance indicators.
None of them names Scope 1, 2 or 3, so a company may meet the duty with metrics of its own choosing.
In practice the targets and KPIs are often emissions, and a company reporting Scope 3 elsewhere usually draws on the same figures.
The government has confirmed that UK SRS S2 is a national reporting framework under s.414CB(6), so a company reporting under UK SRS S2 need not duplicate these disclosures (DBT consultation response).
The duty in full is on the CFD reporting requirements page.
5 · Finance
Category 15 of the GHG Protocol’s Scope 3 Standard covers investments, and the Technical Guidance applies it to investors and providers of financial services.
UK SRS S2 ¶29(a)(vi)(2) asks for additional information about financed emissions where an entity’s activities include asset management, commercial banking or insurance.
¶B61 asks an asset manager for absolute gross financed emissions split by Scope 1, 2 and 3, the assets under management covered, the percentage covered with an explanation of exclusions, and the methodology.
¶¶B62 and B63 set the equivalent for commercial banks and insurers by industry and asset class, including separate disclosure of undrawn loan commitments.
The December 2025 ISSB amendments, carried into UK SRS S2 as ¶¶29A to 29C, let an entity limit Category 15 to financed emissions and exclude derivatives, with an explanation.
For an in-scope listed financial firm these disclosures fall under the FCA’s comply-or-explain rules from 2027.
Separately, FCA-regulated asset managers and asset owners above the £5bn exemption must, under ESG 2.3.5AR, provide at least Scope 1, 2 and 3 data for a product when a client needs it for its own disclosure duties, once a year per product.
The product-level TCFD metrics that ESG 2.3 used to require were removed on 25 September 2026.
No UK rule names a method: PCAF is the method most firms use, and Part A’s third edition of December 2025 covers ten asset classes.
The FCA’s fund-labelling and disclosure regime is covered on the SDR reporting requirements page, and the wider rules on FCA sustainability disclosure requirements.
6 · Pension schemes
Trustees of occupational pension schemes in scope of SI 2021/839 must, in each scheme year and as far as they are able, obtain the Scope 1, 2 and 3 emissions attributable to the scheme’s assets.
Paragraph 19 of the Schedule excuses Scope 3 in the first scheme year in which the requirements apply.
The DWP’s statutory guidance calls these the scheme’s financed emissions, Category 15 in the GHG Protocol’s Technical Guidance.
The data feeds an absolute emissions metric and an emissions intensity metric, and the climate report is published within seven months of the scheme year end.
The duty applies to schemes with £1bn or more in relevant assets and to authorised master trusts and collective money purchase schemes, and is enforced by The Pensions Regulator.
The full duty is on the pension scheme climate reporting requirements page.
7 · CSRD for UK groups
After Omnibus I, the Accounting Directive brings an EU undertaking into CSRD only if it exceeds both 1,000 employees and €450m net turnover.
A non-EU parent, such as a UK group, is caught at more than €450m of EU turnover in each of the last two consecutive financial years, with an EU subsidiary or branch above €200m.
The revised ESRS in C(2026) 5010 apply to financial years beginning on or after 1 January 2027.
EFRAG’s simplified E1-8 asks for gross Scope 3 from each significant category, after screening all 15 GHG Protocol categories.
Under the same disclosure requirement, ESRS E1 asks for both location-based and market-based Scope 2, which UK SRS S2 does not.
The UK-group view is on the CSRD reporting requirements page and the comparison on CSRD vs UK SRS.
The method
Every UK rule above borrows its Scope 3 definitions from the Corporate Value Chain (Scope 3) Standard of 2011, which sets 15 categories, eight upstream and seven downstream.
The Standard requires all Scope 3 emissions to be accounted for, with exclusions disclosed and justified, so no category is optional in it.
The Corporate Standard on its own treats Scope 3 as optional, which is why the instruments give three different answers.
The GHG Protocol is revising its standards, but its own site says the existing standards and guidance stay in effect, and no revised Scope 3 Standard exists yet.
Category by category calculation methods are in the Scope 3 Calculation Guidance, and the overview of the Protocol is on our GHG Protocol page.
The UK conversion factors, including those for business travel, freight and waste, are DESNZ’s 2026 set, explained on the GHG conversion factors page.
Scope 3 is an optional reporting category; Scope 1 and 2 are the minimum.
All 15 categories accounted for, any exclusion disclosed and justified.
All 15 considered, those included disclosed, gross figure required.
Five named categories, UK sources only.
What stays voluntary
There is no general UK duty to report Scope 3; DESNZ’s own call for evidence describes Scope 3 as remaining largely voluntary.
A private company outside SECR, PPN 006 and the finance and pension rules reports Scope 3 only by choice, for example for a customer, a lender or a science-based target.
No UK rule requires Scope 3 to be assured; the FCA asks listed companies only to say whether assurance was obtained, and the sustainability assurance page sets out the standards.
No UK rule prescribes Scope 3 emission factors; UK SRS S2 ¶B29 asks for factors that best represent the entity’s activity.
A Scope 3 target is never required by UK law, though the SBTi asks for one where Scope 3 is 40% or more of total emissions, as the SBTi page explains.
“UK SRS S2 is mandatory for listed companies from 2027” — the final rules are comply or explain.
“SECR requires Scope 3” — false for quoted companies, one narrow limb for unquoted companies and LLPs.
“A Carbon Reduction Plan covers Scope 3” — five categories only.
“Scope 3 relief lasts two years” — the FCA’s final relief is one year.
Proposals
DESNZ’s 2023 call for evidence drew 184 responses, of which 80% supported the GHG Protocol for Scope 3 reporting, but no Scope 3 duty followed it.
The Modernising corporate reporting consultation, published on 7 September 2026 and closing on 30 November 2026, proposes to move SECR disclosures out of the abolished directors’ report, not to change what they contain.
The same consultation says the government will consider how UK SRS should be reflected in the Companies Act, without a proposal or date.
The SECR review recommended keeping SECR with amendments, and the consultation records that DESNZ intends to consult on SECR and ESOS later in 2026.
The FCA is consulting on draft Technical Note 803.1 on how to explain proportionately, with comments due by 28 October 2026.
The GHG reporting requirements page covers Scope 1 and 2 alongside these Scope 3 duties.
Check yourself
Each answer names the provision it turns on.
The regimes are easy to merge because they use the same word for different slices of the value chain.
True or false?
UK SRS S2 requires an entity to report all 15 Scope 3 categories.
A listed company using the Scope 3 relief must explain why it has not disclosed Scope 3.
A quoted company reports business-travel emissions under SECR.
A PPN 006 Carbon Reduction Plan must include purchased goods and services.
Pension trustees need not obtain Scope 3 in the first scheme year the duty applies.
UK rules require financed emissions to be measured with PCAF.
0 of 6 answered.
Nothing you choose is stored or sent.
Frequently asked
No UK law requires a company to report its full Scope 3 emissions.
Listed companies in UKLR 6, 14, 15, 16 and 22 must, for periods beginning on or after 1 January 2027, report Scope 3 under UK SRS S2 or explain why not, after a one-year relief.
SECR reaches one slice of Scope 3 for large unquoted companies and LLPs, PPN 006 asks government bidders for five categories, and pension scheme trustees must obtain portfolio Scope 3 as far as they are able.
The FCA’s rules apply to accounting periods beginning on or after 1 January 2027, and a company may use a one-year relief for Scope 3 from the date of initial application.
For periods beginning on or after 1 January 2028 the relief has expired for new periods, and Scope 3 is on the same comply-or-explain footing as the rest of UK SRS S2.
For its first UK SRS period, a listed company need not disclose Scope 3, provided it states in the annual financial report that it is using the transitional relief.
The FCA says use of the relief does not engage its explain rules, so no further explanation is needed during the relief period.
No. UK SRS S2 ¶B32 requires an entity to consider all 15 categories and to disclose which categories it has included in its measure.
Considering all fifteen is not the same as reporting all fifteen.
In the standard itself, no: UK SRS S2 ¶C4 carries no time limit, unlike IFRS S2.
The one-year limit comes from the FCA’s transitional provisions in UKLR TP 16 for listed companies, so the limit binds only where the FCA rules apply.
Only one narrow slice, and only for large unquoted companies and LLPs.
They report emissions from fuel consumed for the purposes of transport, which the Environmental Reporting Guidelines read as transport where the organisation is responsible for purchasing the fuel, and that reaches some business travel.
Quoted companies have no Scope 3 limb under SECR.
Five: upstream transportation and distribution, waste generated in operations, business travel, employee commuting, and downstream transportation and distribution, alongside all Scope 1 and Scope 2.
Purchased goods and services, capital goods and the other categories are not required.
No. PPN 006 is procurement policy that in-scope central government buyers apply to contracts above £5 million a year including VAT, so a supplier needs a plan only when bidding for such a contract.
It is a condition of participation in that procurement, not a statutory filing.
No. Section 414CB(2A) asks for eight disclosures, including targets and key performance indicators, but names no emissions figure.
A company may choose emissions metrics, and many do, but the Act does not require a Scope 3 number.
Financed emissions are the part of Scope 3 Category 15 attributed to an entity’s loans and investments.
UK SRS S2 ¶29(a)(vi)(2) asks for additional information on them where an entity’s activities include asset management, commercial banking or insurance, so for an in-scope listed financial firm they fall under the FCA’s comply-or-explain rules.
No UK rule names PCAF.
UK SRS S2 asks for financed emissions and the methodology used, without prescribing one, and the FCA Handbook does not mandate PCAF.
PCAF is a widely used method, and its Part A third edition was published in December 2025.
Since 25 September 2026 the product-level TCFD metrics are no longer an FCA rule.
In-scope asset managers and asset owners must instead provide, on request, at least Scope 1, 2 and 3 data for a product to a client who needs it for its own disclosure duties, once a year per product, under ESG 2.3.5AR.
Trustees of in-scope occupational pension schemes must, as far as they are able, obtain the Scope 1, 2 and 3 emissions attributable to the scheme’s assets each scheme year.
SI 2021/839 excuses Scope 3 in the first scheme year the duty applies, and the results feed the scheme’s published climate report.
Only where CSRD reaches them, which after Omnibus I is an EU undertaking exceeding 1,000 employees and €450m net turnover, or a non-EU parent with more than €450m of EU turnover and an EU subsidiary or branch above €200m.
Under the revised ESRS E1, an in-scope undertaking reports Scope 3 from each significant category after screening all fifteen.
Yes.
UK SRS S2 ¶B57 presumes Scope 3 can be estimated reliably using secondary data and industry averages, and DESNZ notes that Defra’s spend-based multipliers can give an initial assessment where activity data is lacking.
Primary data is prioritised, all else being equal.
No UK rule requires it.
Listed companies under the FCA’s rules must say whether they obtained third-party assurance and, if so, from whom and to what level, but obtaining it is not required.
In-scope CSRD reporting, by contrast, needs limited assurance under EU law.
The Corporate Value Chain (Scope 3) Standard of 2011, with its 15 categories.
The GHG Protocol is revising its standards, but no revised Scope 3 Standard exists yet, and the existing standards stay in effect.
No proposal for a general Scope 3 duty has been published.
DESNZ’s 2023 call for evidence found demand for Scope 3 reporting, and the September 2026 Modernising corporate reporting consultation proposes to move where SECR sits rather than to widen it.
Sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
¶29(a)(i)(3) gross Scope 3; ¶¶B32–B33 categories; ¶¶B38–B57 measurement; ¶C4 relief.
Issued 25 February 2026 as voluntary standards.
The renumbered transition appendices, including the untimed Scope 3 relief.
Comply or explain from 1 January 2027; one year’s Scope 3 relief.
The relief, the relief statement and UKLR TP 16.
¶¶29A–29C: the Category 15 financed-emissions limitation.
¶20D(1)(b): fuel consumed for the purposes of transport.
“For the purposes of transport”: aircraft, road-going vehicle, train or vessel.
Global emissions from fuel, facilities and purchased energy; no Scope 3 limb.
Only fuel the organisation buys counts as transport for unquoted companies and LLPs.
“A small amount of Scope 3 emissions from business travel.”
Contracts above £5m a year including VAT; from 24 February 2025.
Scope 1, Scope 2 and Scope 3 categories 4, 5, 6, 7 and 9.
Eight disclosures; no emissions figure as such.
ESG 2.3.5AR: Scope 1, 2 and 3 data on request, once a year per product.
Part A, Financed Emissions, third edition (December 2025).
Investments: equity, debt, project finance, managed investments.
Schedule ¶¶18–19: Scope 3 not required in the first scheme year.
¶120: Scope 3 of scheme assets, as far as trustees are able.
CSRD scope after Omnibus I: Arts 19a, 29a, 40a.
Applies to financial years beginning on or after 1 January 2027.
Scope 3 from each significant category; screen all 15.
Fifteen categories; §6.2 exclusions disclosed and justified.
Calculation methods by category.
184 responses; “Scope 3 emissions remain largely voluntary”.
80% supported the GHG Protocol for Scope 3 reporting.
Published 7 September 2026; closes 30 November 2026. A proposal.