ESRS Standard
ESRS Standard
44 The company shall disclose the following in metric tons of CO2 equivalent: (45)
a) its Scope 1 GHG gross emissions,
(b) its Scope 2 GHG gross emissions,
(c) its scope 3 GHG gross emissions; and
d) its total GHG emissions.
45. the purpose of the disclosure requirement in paragraph 44 is to,
(a) with respect to scope 1 GHG gross emissions referred to in paragraph 44(a), to provide an understanding of the company's direct impacts on climate change and the proportion of its total GHG emissions that are regulated under emissions trading schemes,
(b) with respect to Scope 2 GHG gross emissions referred to in paragraph 44(b), provide an understanding of the indirect impacts on climate change caused by the externally purchased or received energy consumed by the company,
(c) for Scope 3 GHG gross emissions referred to in paragraph 44(c), provide an understanding of greenhouse gas emissions in the company's upstream and downstream Value chain beyond Scope 1 and Scope 2 greenhouse gas emissions. For many companies, Scope 3 GHG emissions may be the main component of their GHG inventory and a significant cause of the company's transition risks,
(d) with respect to the total GHG emissions referred to in paragraph 44(d), provide a general understanding of the company's GHG emissions and whether they arise from its own activities or in the upstream and downstream Value chain. This disclosure is a prerequisite for measuring progress in reducing greenhouse gas emissions in line with the company's climate-related Targets and the EU's strategic objectives.
The information from this disclosure requirement is also necessary to understand the company's Climate-related transition risks.
46 When disclosing the information on greenhouse gas emissions required by paragraph 44, the entity shall refer to paragraphs 62 to 67 of ESRS 1. In principle, data on greenhouse gas emissions from associates or joint ventures that are part of the entity's upstream and downstream Value chain (ESRS 1 paragraph 67) are not limited to the proportion of ownership interest held. According to the extent of operational control over its associates, joint ventures, unconsolidated subsidiaries (investment entities) and contractual arrangements under joint arrangements that are not structured through an entity (i.e. jointly controlled operations and assets), the entity discloses their GHG emissions.
47. in the event of material changes to the definition of what constitutes the reporting entity and its upstream and downstream Value chain, the entity shall disclose these changes and explain their impact on the annual comparability of its reported GHG emissions (i.e. the impact on the comparability of the current and previous reporting periods on GHG emissions).
48. the disclosure of Scope 1 GHG emissions in accordance with paragraph 44(a) shall include:
(a) the gross Scope 1 GHG emissions in metric tons of CO2 equivalent; and
b) the percentage of Scope 1 GHG emissions from regulated emissions trading schemes.
Please refer to application requirement AR 43 and AR 44
49. the disclosure of Scope 2 GHG emissions in accordance with paragraph 44(b) shall include:
(a) the location-based Scope 2 GHG gross emissions in metric tons of CO2 equivalent; and
b) the market-related Scope 2 GHG gross emissions in metric tons of CO2 equivalent.
Please refer to application requirement AR 45 a) - f)
50. for the Scope 1 and Scope 2 emissions reported in accordance with paragraph 44(a) and (b), the company shall disaggregate the information, separately disclosing the following emissions:
(a) the group consolidated for accounting purposes (the parent undertaking and subsidiaries); and
b) entities in which investments are made, such as associates, joint ventures or unconsolidated subsidiaries that are not fully consolidated in the financial statements of the group consolidated for accounting purposes, and contractual arrangements that are joint arrangements that are not structured by an entity (i.e. jointly controlled operations and assets) over which the entity has operational control.
51. the disclosure of Scope 3 GHG emissions in accordance with paragraph 44(c) includes greenhouse gas emissions in metric tons of CO2 equivalent from each significant Scope 3 category (i.e., each Scope 3 category that is a priority for the entity).
Please refer to application requirements AR 46, AR 50 and AR 51
52 The disclosure of total GHG emissions in accordance with paragraph 44(d) consists of the sum of Scope 1, 2 and 3 emissions in accordance with paragraph 44(a) to (c). The disclosure of total GHG emissions shall take the form of a breakdown that distinguishes between the following:
(a) the total GHG emissions resulting from the underlying scope 2 GHG emissions measured using the site-specific methodology; and
b) the total GHG emissions resulting from the underlying Scope 2 greenhouse gas emissions measured using the market-based method.
Please refer to application requirement AR 47.
Greenhouse gas intensity based on net sales (46)
53 The company discloses the intensity of its greenhouse gas emissions (total GHG emissions per net revenue).
Please refer to application requirement AR 53
(54) The disclosure of greenhouse gas intensity in accordance with paragraph 53 includes the total GHG emissions in tons of CO2 equivalent (in accordance with paragraph 44(d)) per net revenue.
55 The entity shall disclose the reconciliation of net revenue (the benchmark for calculating GHG intensity in accordance with paragraph 53) to the relevant line item or note disclosures in the financial statements.
Application Requirements (AR)
Application Requirements (AR)
Guidelines for the calculation
AR 39 In compiling the information required by paragraph 44 for reporting greenhouse gas emissions, the entity shall do the following:
(a) It shall follow the principles, requirements and guidance in the GHG Protocol (2004 version) corporate standard. The company may consider Commission Recommendation (EU) 2021/2279 (58) or the requirements of EN ISO 14064-1:2018. If the company already uses the ISO 14064-1:2018 GHG accounting methodology, it must still comply with the requirements of this standard (e.g. in relation to reporting boundaries and disclosure of market-related Scope 2 GHG emissions).
b) It shall disclose the methodologies, significant assumptions and emission factors it uses to calculate or measure greenhouse gas emissions, together with a justification for their use, and provide a reference or link to other calculation tools used.
(c) It shall report the emissions of CO2, CH4, N2O, HFCs, PFCs, SF6 and NF3. Additional greenhouse gases may be included if they are considered significant.
d) It uses the most recent global warming potential ( GWP ) values published by the IPCC based on a time horizon of 100 years to calculate CO2 equivalents for emissions of non-CO2 gases.
AR 40 When preparing the information for the reporting of greenhouse gas emissions of its associates, joint ventures, unconsolidated subsidiaries (investment entities) and contractual arrangements in accordance with paragraph 50, the entity consolidates 100% of the greenhouse gas emissions of the entities over which it has operational control. In practice, this is the case if the entity has a license or permit to operate the assets of those associates, joint ventures, unconsolidated subsidiaries (investment entities) and contractual arrangements. If the entity has contractual temporary operational control, it consolidates 100% of the greenhouse gases emitted during the exercise of its operational control.
AR 41 In accordance with Chapter 3.7 of ESRS 1, the entity may be required to disaggregate information about its greenhouse gas emissions. For example, the company may disaggregate its Scope 1, 2 and 3 GHG emissions or its total GHG emissions by country, operating segment, economic activity, subsidiary, GHG category (CO2, CH4, N2O, HFCs, PFCs, SF6, NF3 and other GHGs considered by the company) or source type (stationary combustion, mobile combustion, process emissions and fugitive emissions).
AR 42 A company may have a different reporting period than some or all companies in its Value chain. In this case, the company is permitted to measure its greenhouse gas emissions in accordance with paragraph 44 using information for reporting periods that differ from its own reporting period if that information comes from companies in its Value chain with different reporting periods than the company's reporting period, provided that:
(a) The company uses the most recent available data from these companies in its Value chain to measure and report its GHG emissions.
b) The reporting periods are of equal length; and
c) The entity discloses the impacts of significant events and changes in circumstances (relevant to its greenhouse gas emissions) that occur between the reporting dates of the entities in its value chain and the date of the entity's general purpose financial statements.
AR 43 In compiling the information on gross Scope 1 GHG emissions required by paragraph 48(a), the entity does the following:
(a) It shall calculate or measure greenhouse gas emissions from stationary combustion, mobile combustion, process emissions and fugitive emissions and use appropriate activity data that includes non-renewable fuel consumption.
b) It uses appropriate and consistent emission factors.
c) It reports biogenic CO2 emissions from the Incineration or biodegradation of biomass separately from Scope 1 greenhouse gas emissions, but takes into account emissions of other types of greenhouse gases (in particular CH4 and N2O).
d) It excludes any removals or any Carbon credits or greenhouse gas allowances purchased, sold or transferred from the calculation of scope 1 greenhouse gas emissions.
(e) For activities reported under the EU ETS, it shall report scope 1 emissions using the EU ETS methodology. The EU ETS methodology may also be applied to activities in geographical areas and sectors not covered by the EU ETS.
AR 44 When compiling the information required under paragraph 48(b) on the percentage of scope 1 greenhouse gas emissions from regulated emissions trading schemes, the company shall do the following:
(a) it shall take into account greenhouse gas emissions from the installations it operates that are subject to regulated emissions trading schemes (ETSs), including the EU ETS, national ETSs and, where applicable, ETSs in countries outside the EU.
b) it only reports emissions of CO₂, CH₄,N₂O, HFCs, PFCs, SF₆ and NF₃,
(c) ensure that the accounting period for Scope 1 GHG emissions corresponds to the accounting period for emissions covered by the ETS; and
(d) it calculates the share using the following formula:
GHG emissions (in t CO₂e) from EU ETS installations + national ETS installations + non-EU ETS installations.
Scope 1 greenhouse gas emissions (t CO₂e)
AR 45 When compiling the information on scope 2 GHG gross emissions required under paragraph 49, the company shall do the following
(a) it shall take into account the principles and requirements of the GHG Protocol Guidelines for Scope 2 GHG emissions (2015 version, in particular the Scope 2 quality criteria in Chapter 7.1 relating to contractual instruments), and may also take into account Commission Recommendation (EU) 2021/2279 or the relevant requirements for quantifying indirect GHG emissions from imported energy in accordance with ISO 14064-1:2018,
b) it discloses electricity, steam, heat and cooling purchased or received by the company
c) it avoids double counting of greenhouse gas emissions reported under Scope 1 or 3 categories,
(d) it applies the site-based and market-based method for calculating Scope 2 greenhouse gas emissions and provides information on the proportion and types of contractual instruments. The location-based methodology quantifies Scope 2 GHG emissions based on average emission factors for energy production in specific locations, including local, subnational or national boundaries (GHG Protocol, Scope 2 GHG emissions guidelines, Glossary, 2015). Under the market-based method, Scope 2 GHG emissions are quantified based on the GHG emissions of generators from which the reporting company contractually purchases electricity bundled with instruments or unbundled instruments alone (GHG Protocol, Scope 2 GHG emissions guidelines, Glossary, 2015); in this case, the company may report the share of market-based Scope 2 GHG emissions associated with purchased electricity bundled with instruments such as Guarantees of Origin or Renewable Energy Certificates. The company provides information on the proportion and types of contractual instruments used for the sale and purchase of energy that is bundled with energy generation attributes or not bundled with energy attributes,
e) it discloses biogenic CO₂ emissions from the Incineration or biodegradation of biomass separately from Scope 2 greenhouse gas emissions, but takes into account emissions of other types of greenhouse gases (in particular CH₄ and N₂O). If the percentage of biomass or biogenic CO₂ is not separated in the emission factors applied, the company must indicate this. If greenhouse gas emissions of greenhouse gases other than CO₂ (in particular CH₄ and N₂O) are not available or excluded for site-specific average emission factors of the network or for the market-based method, the company shall indicate this,
f) it excludes any removals or any CO₂ allowances or greenhouse gas allowances purchased, sold or transferred from the calculation of scope 2 greenhouse gas emissions.
AR 46 When compiling the information on gross Scope 3 GHG emissions required under paragraph 51, the company shall do the following
(a) it shall consider the principles and provisions of the Accounting and Reporting Standard of the GHG Protocol for the Corporate Value Chain (Scope 3) (2011 version), and may also consider Commission Recommendation (EU) 2021/2279 or the relevant requirements for quantifying Indirect GHG emissions in accordance with ISO 14064-1:2018.
b) If it is a financial institution, it takes into account the Partnership for Carbon Accounting Financial (PCAF) Greenhouse Gas Accounting and Reporting Standard for the Financial Sector, in particular Part A "Financed Emissions" (December 2022 version).
c) It verifies, using appropriate estimates, its total Scope 3 GHG emissions based on the 15 Scope 3 categories described in the GHG Protocol's Corporate Standard and the GHG Protocol's Accounting and Reporting Standard for the Corporate Value Chain (Scope 3) (2011 version). Alternatively, it may verify its indirect GHG emissions based on the categories specified in section 5.2.4 of EN ISO 14064-1:2018 (except for indirect GHG emissions from imported energy).
d) It identifies and reports its significant Scope 3 categories based on the magnitude of their estimated GHG emissions and other criteria in accordance with the GHG Protocol's Accounting and Reporting Standard for the Corporate Value Chain (Scope 3) (2011 version, p. 61 and 65-68) or Annex H.3.2 of EN ISO 14064-1:2018, e.g. financial expenditures, impact, associated Transition risks and Opportunities or Stakeholder views.
e) It calculates or estimates greenhouse gas emissions in significant Scope 3 categories using appropriate emission factors.
f) It updates annually the Scope 3 GHG emissions in each significant category based on current activity data; it updates the entire Scope 3 GHG inventory at least every three years or when a significant event or significant change in circumstances occurs (a significant event or significant change in circumstances may relate, for example, to changes in the activities or structure of the company, changes in the activities or structure of its upstream and downstream Value chain(s), a change in the calculation methodology or the discovery of errors).
g) It discloses the extent to which its Scope 3 GHG emissions are measured using inputs from specific activities within the company's upstream and downstream value chain and the percentage of emissions calculated using primary data from Suppliers or other partners in the value chain.
h) For each significant Scope 3 category of greenhouse gas emissions, it discloses the reporting boundaries considered, the calculation methods used to estimate greenhouse gas emissions, and whether and which calculation tools were used. Scope 3 categories should be consistent with the GHG Protocol and include the following:
i. Indirect Scope 3 GHG emissions of the consolidated group companies (the parent company and subsidiaries).
ii. Indirect Scope 3 GHG emissions from associates, joint ventures and unconsolidated subsidiaries where the company has the ability to control the operating activities and relationships (Operational control).
iii. Scope 1, 2 and 3 greenhouse gas emissions from associates, joint ventures, unconsolidated subsidiaries (investment entities) and joint arrangements over which the company does not have operational control, where these entities are part of the reporting company's upstream and downstream Value chain.
i) It provides a list of the categories of Scope 3 greenhouse gas emissions that are included and excluded from the inventory, with a rationale for the excluded Scope 3 categories.
j) It reports biogenic CO2 emissions from the Incineration or biodegradation of biomass that occur in its upstream and downstream Value chain separately from Scope 3 GHG emissions and excludes emissions of other types of greenhouse gases (e.g. CH4 and N2O) and CO2 emissions arising within the life cycle of biomass other than from Incineration or biodegradation (e.g. GHG emissions from the processing or transportation of biomass) in the calculation of Scope 3 GHG emissions.
k) It excludes any removals or any Carbon credits or greenhouse gas allowances purchased, sold or transferred from the calculation of Scope 3 greenhouse gas emissions.
AR 47. in preparing the information on total GHG emissions required by paragraph 52, the company shall do the following:
(a) It shall use the following formulas to calculate total GHG emissions:
Total GHG emissions by site (t CO₂e)
= Scope 1 gross emissions + Scope 2 gross emissions by location + Scope 3 total gross emissionsGHG emissions market-related (t CO₂e)
= Scope 1 gross emissions + Scope 2 gross emissions market-related + Scope 3 gross emissions
b) It discloses the total GHG emissions, distinguishing between emissions derived from the location-based methods and those derived from the market-based methods when measuring the underlying Scope 2 GHG emissions.
AR 48 The company discloses its total GHG emissions by Scope 1, Scope 2 and significant Scope 3 GHG emissions in accordance with the table below.
See table AR 48.pdf
AR 49 To disclose potential transition risks, the company may disclose its total GHG emissions by significant countries and, where applicable, by operating segment (using the same segments as for the financial statements in accordance with the accounting standards, i.e. IFRS 8 Operating Segments or local accounting requirements). Scope 3 GHG emissions may be excluded from these country breakdowns if the relevant data are not readily available.
AR 50 Scope 3 GHG emissions may also be presented according to the indirect emission categories defined in EN ISO 14064-1:2018.
AR 51 If material to the company's Scope 3 emissions, the company shall report greenhouse gas emissions from purchased cloud computing and data center services as part of the overarching Scope 3 category "upstream purchased goods and services".
AR 52. the total GHG emissions broken down by Scope 1, 2 and 3 can be presented graphically in the Sustainability statement (e.g. as a bar chart or pie chart) so that the breakdown of GHG emissions within the Value chain (upstream, own activities, transportation, downstream) is shown.
AR 53 When disclosing the information required under paragraph 53 on greenhouse gas intensity based on net sales, the company proceeds as follows:
(a) It calculates GHG intensity using the following formula:
Total GHG emissions (t CO2e) / Net sales (currency unit)
b) It expresses the total GHG emissions in tons of CO2 equivalent and the net sales in currency units (e.g. Euro) and presents the results for the market-based and location-based method.
c) It enters the total GHG emissions in the numerator and the total net revenues in the denominator.
(d) calculate total GHG emissions in accordance with paragraphs 44(d) and 52; and
(e) calculate net revenue in accordance with the requirements of the applicable accounting standards for financial statements, i.e. IFRS 15 or local accounting requirements.
AR 54 The quantitative information may be presented in a table such as the following.
Connectivity of GHG intensity based on revenue with financial reporting information.
See below for table on AR 54
AR 55 The reconciliation of net sales used to calculate GHG intensity to the relevant line item or note disclosures in the financial statements (in accordance with paragraph 55) may be:
(a) by a cross-reference to the relevant line item or note disclosures in the financial statements; or
(b) by a quantitative reconciliation using the table format below if the net revenue cannot be directly linked to an item or disclosure in the financial statements.
Net sales used in the calculation of greenhouse gas intensity
Net sales (other)
Total net revenue (financial statements)
Table for AR 54:
GHG intensity per net revenue | Comparison | N | % N / N-1 |
Total GHG emissions (location-based) per net revenue (t CO2e/currency unit) | |||
Total GHG emissions (market-related) per net revenue (t CO2e/currency unit) |
Comparison... Energy intensity from a comparative year
N................... Energy intensity of the current year
% N / N-1... Ratio of the energy intensity of the current year to the previous year as a percentage
Examples from previous practice
Examples from previous practice
Examples merely serve as an indication of how a disclosure requirement has been stated by other companies to date. Audited ESRS reports are not yet available. There is no guarantee of accuracy and completeness.
E1-6 - Gross GHG emissions in Scope 1, 2 and 3 categories and total GHG emissions
Scope 1 and 2
Scope 1 and Scope 2 emissions increased in the reporting period. The increase is due to the company's growth, which is characterized by an increase in offices and employees worldwide. This growth has influenced the absolute emissions in both scopes.
However, the company remains committed to reducing emissions in Scope 1 and Scope 2. Actions such as power purchase agreements, energy management systems, the decarbonization of vehicle fleets and other CO₂-reducing initiatives continue to be invested in.
Scope 3
The emissions intensity of Scope 3 has improved due to a decline in air freight activities. This is due to lower transport volumes, particularly in the first half of the year, as the global supply chain situation eased after the pandemic and demand for urgent deliveries fell.
Total emissions in Scope 3 have also decreased, supported by improved data collection methods and more accurate reporting that relies more on activity data rather than sales data.
Total emissions
Total emissions have decreased, mainly due to a reduction in Scope 3 category emissions. As this category accounts for the majority of emissions, the reduction there led to a significant decrease in total greenhouse gas emissions.
The company continues to focus on actions to reduce its carbon footprint, based on more accurate data and a stronger focus on sustainable practices.
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