Scope 3 accounting starts asking transport to be measured.
The GHG Protocol Scope 3 standard is revising its accounting rules. It doesn’t target a single category — it reworks the whole rulebook — but several of those rules land especially hard on transport data. Below are the public proposals (Series A·B·C) and what they imply for transport (Scope 3 categories 4 and 9).
This revision now feeds a consolidated standard with ISO.
GHG Protocol announced that its Scope 1, Scope 2, Scope 3 and Actions and Market Instruments (AMI) standards will be consolidated with ISO 14064-1 into a single, co-branded corporate standard. The Series A·B·C proposals below become inputs to it. An integrated public consultation on the future corporate standard is planned for Q2 2027.
One part matters especially for transport and certificates. The proposal introduces a multi-statement reporting approach: physical emissions from a company’s own operations and value chain; emissions tied to market instruments such as commodity certificates and mitigation-related contractual agreements; and the emissions impact of actions and investment decisions. Purchased reductions are reported beside the physical inventory, not inside it.
Source: GHG Protocol announcement (2026-07-29). The consolidation timeline and the multi-statement approach are at proposal stage; final standard wording is not confirmed.
Transport lives in categories 4 and 9.
In Scope 3, transport is upstream transport (category 4) and downstream transport (category 9). This revision reworks the accounting rules across the board — data quality (how to trust), boundary setting (how much to include), and investment redefinition — and those rules squarely target the "spend-based estimate" habit in transport.
How do you trust an emissions figure?
The direction is to make it transparent how much spend-based estimation is mixed in.
Mandatory disclosure by data type
Disclose Scope 3 emissions split by data-type grade (primary data / activity-based / spend-based). The point is to reveal how much spend-based estimation is mixed in.
Mandatory verification disclosure
Verified companies must state "fully / partially / not verified". Alignment with ISO 14065 is under review.
Data-quality recommendations
Use high-completeness factors (≤5% cutoff), reflect trade in regional factors, and set primary-data-ratio and improvement targets.
Limit allocation of diversified suppliers’ company-wide emissions
Restrict splitting a "diversified" supplier’s company-wide emissions by spend ratio. Only homogeneous suppliers allowed; others need product/facility-level data.
How much emissions do you include?
The direction: "it was too small to count" no longer holds.
95% completeness rule
For conformance, calculate and report at least 95% of required Scope 3 emissions. Exclusions capped at 5%. Aligned with SBTi/CDP’s 5%.
100% quantification to justify exclusion
To prove exclusions stay within 5%, quantitatively assess 100% of required emissions annually. Simplified methods (hotspot analysis) allowed.
Clarified hotspot-analysis definition
Any calculation/estimation method may be used for hotspot analysis.
Exclusion disclosure, justification, notation
Excluding required emissions requires disclosure and justification; standard notation ("NA"/"X") introduced. A de minimis concept is introduced but kept within the 5% cap.
Separate reporting of required vs optional
Report required emissions and optional emissions separately.
New category 16 — facilitated activities
A category for "facilitated activities" not caught by the existing 15 — activities you neither buy/sell nor own but earn transaction revenue from (brokerage, licensing, financial services). Mostly optional (oil & gas distribution is required).
Category 15 is narrowed to financed emissions.
Category 15 is narrowed to "financed emissions" — investments only — while other financial services such as insurance/underwriting move to category 16.
- Clarified that category 15 applies to all companies (not only asset managers).
- Include Scope 1·2·3 of the investee within the boundary.
- Include debt in the denominator for share-proportional calculation (PCAF-aligned).
Four places the rules land hard on transport.
A whole-rulebook revision — yet it touches transport data especially sharply.
Spend-based estimation gets branded lowest-grade
A1Many shippers handle categories 4·9 as spend-based — "we spent X on freight, times an emission factor". The proposal requires disclosure split by data-type grade, and spend-based is explicitly labeled the lowest grade. Transport emissions get publicly shown as "the item we counted most poorly".
3PLs and forwarders can’t use company-wide averages
A83PLs and forwarders are mostly "diversified" operators mixing many shippers and modes. Until now their company-wide emissions could be split by volume/spend ratio, but A8 restricts this. This is the key pressure point of the transport cascade.
You can’t leave transport out as "negligible"
B1·B2Under the 95% completeness rule, even items you want to exclude must first be quantified to prove they’re within 5%. "Transport is small, so we left it out" no longer works — to exclude it you have to compute it first. For manufacturers/distributors, transport is far from negligible, so it is effectively forced in.
Verification status becomes public
A2With "fully / partially / not verified" required, unverified transport data shows up as "not verified".
Under this revision, measurement becomes a grade.
The revision converges on one thing — measured activity data, not spend or averages, in a verifiable form. LCS measures driving, fuel, and load at the vehicle every second with Carbon DTG, and calculates & reports to ISO 14083 with the LCS standard. Not lowest-grade spend-based, but verifiable primary data at the shipment and leg level.
Raise your transport data’s grade, starting now?
We’ll design the path from spend-based to measured primary data for your transport emissions in a 30-minute assessment.
This page summarizes public GHG Protocol Scope 3 revision proposals (Technical Working Group) and per-proposal public survey support. Final standard wording and effective dates are not confirmed; the source text prevails once in force.