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California SB 253: Climate Corporate Data Accountability Act · 2026-initial-regulation-as-amended-sb219
Disclosure SB253-SCOPE-2

Scope 2 greenhouse gas emissions

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official CARB source.

Dr Ross Kurinko, Sustainability Reporting Trainer
Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by CARB
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to report the greenhouse gas emissions linked to the electricity, steam, heating or cooling it uses, rather than emissions it creates directly on site. In practice, the focus is on the emissions associated with purchased energy across the organisation’s reporting boundary, so the organisation needs to identify where it uses energy and quantify the related indirect emissions in a consistent way.

The practical question is coverage: the report should reflect the organisation’s full operations that fall within scope, not just a few prominent locations or flagship sites. That means checking all relevant facilities, offices, warehouses, plants and other operations that consume purchased energy, so the reported figure is not limited to selected examples but represents the organisation’s overall footprint for this emissions source.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official CARB source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Energy purchased for use Record which bought-in energy forms are included in the Scope 2 inventory: electricity, steam, heat and cooling. Utility invoices, supplier statements, energy contracts, and the emissions calculation workbook showing the included energy types. Sustainability / Energy management
Grid-based Scope 2 emissions Capture the emissions figure calculated using the grid-average method for the reporting period, in tCO2e. Scope 2 calculation file, activity data, emission factors, and the period-end report used for consolidation. Sustainability / ESG reporting
Contract-based Scope 2 emissions Capture the emissions figure calculated using the supplier- or contract-based method for the reporting period, in tCO2e. Scope 2 calculation file, contractual instrument records, supplier data, and the final emissions summary. Sustainability / ESG reporting
Scope 2 reporting year State the reporting period covered by the Scope 2 figure, including the start and end dates used for the calculation. Annual reporting timetable, consolidation calendar, and the dated calculation workbook or management report. Finance / ESG reporting
Total Scope 2 emissions Capture the combined Scope 2 emissions total for the reporting period, in tCO2e, as reported after the relevant calculation method is applied. Final emissions inventory, consolidation workbook, and the signed-off reporting pack showing the rolled-up total. Sustainability / ESG reporting
+ Show SB253-SCOPE-2 sub-elements (LRA working checklist)

How to prepare it

1Set the boundary for this disclosure first: identify the electricity, steam, heating, and cooling you bought or otherwise obtained, and confirm which of those purchases sit within the reporting year you are using.
2Gather the source records that support those energy purchases, then use them to build the emissions figures for the same period in two ways: one based on the grid or local supply mix, and one based on the contractual or supplier-specific view you use internally.
3Calculate the overall amount for the period, making sure it reconciles to the two emissions views and to the underlying energy data you have collected.
4Keep a clear audit trail for any items you leave out, any estimation choices, and any changes to methods, data sources, or assumptions compared with the prior cycle or earlier drafts.
5Prepare the final disclosure package with the reporting period, the total emissions figure, and both emissions views in the required unit, supported by the evidence you assembled.
6Before submission, check your draft against the official source and confirm that the scope, figures, labels, exclusions, and method notes still match the current requirement.
Request the data

Request the electricity and heating data

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What energy we bought or used for the reporting period, and what that means for our Scope 2 emissions figures?

Use your organisation’s own names for sites, utilities, meters, invoices, and reporting packs first, then map them to the fields below. This is a possible LRA training template only; adapt it to your organisation and check the source material before sign-off.

Weak request

Please provide Scope 2 data, including location-based and market-based emissions, for the reporting period, with evidence.

Why it fails: It uses framework language that many operational teams will not use day to day, and it does not tell the owner which utility records, site data, calculation basis, or source files to pull together. It is also too vague about the period, the systems, and the evidence needed to support the figures.

Better request

Please send the energy and emissions pack for [reporting period] for [sites/business units]. Include the electricity, steam, heat, and cooling we bought or used, the emissions figures in tCO2e using both calculation approaches where available, the source files or invoices, the period covered, and any assumptions, estimates, or gaps. Use your normal site and utility names, then we will map them to the reporting fields.

Formal email template
Subject: Data request for [reporting period] energy and emissions pack

Hi [name/team],

Could you please send the data and supporting evidence for our [reporting period] energy and emissions pack for [sites/business units]?

Please include:
- the energy we bought or used for each site, covering electricity, steam, heat, and cooling where relevant;
- the figures we need to calculate our emissions using both the grid-average approach and the supplier/contract-based approach, where available;
- the total emissions figure for the period, in tCO2e;
- the period covered by each source file or invoice;
- the source system or document reference for each line;
- any assumptions, estimates, or gaps;
- any contractual documents or supplier evidence used in the calculation.

If it is easier, you can return the information in the table below and attach the source files.

This is a possible LRA training template only; please adapt it to your organisation’s own terms and check the source material before sign-off.

Thanks,
[preparer name]
[role]
[contact details]
Short Teams / Slack version
Hi [name/team] — could you send the [reporting period] energy pack for [sites/business units]? Please include the bought energy types, the emissions figures in tCO2e using both calculation approaches where available, the source files, and any gaps or estimates. A table is fine. Please use your usual internal names and attach the evidence. Thanks.
Industry examples
Manufacturing

Context. A multi-site producer with separate plant meters, utility invoices, and a central energy dashboard.

Adapted request. Please send the [reporting period] plant energy pack for [site names]. Include grid electricity, purchased steam, and any district heat or cooling, plus the emissions figures in tCO2e using the two calculation approaches where available. Attach the meter exports, invoices, supplier statements, and any estimate notes.

Example response. Attached are the plant meter exports, utility invoices, and supplier statements for [reporting period]. We included electricity, purchased steam, and district heat for three sites. The table shows the source period, quantities, location-based emissions, market-based emissions where available, and notes on one estimated month.

Property / Real Estate

Context. A portfolio team managing landlord and tenant utility data across offices and retail units.

Adapted request. Please provide the [reporting period] utilities pack for the portfolio. Include electricity, heat, and cooling bought for each building, the emissions figures in tCO2e, the source invoices or meter reads, and any notes on shared meters, estimates, or missing bills.

Example response. We have returned the portfolio table with building-level electricity and heat data, invoice references, and meter-read evidence. One retail unit had a missing invoice, so we used an estimated read and flagged it in the notes column.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

Explain which emissions basis was used, how the organisation defined the reporting period, and how the purchased energy figures were gathered and turned into the reported Scope 2 numbers.

Context note

Set out what the figures mean in practice: the amount of energy the business relied on from outside sources and the resulting indirect emissions attributed to that use.

Fluctuation statement

If the numbers moved materially, note the main operational or data-related reasons, such as changes in energy use, supplier information, or the calculation basis applied.

Content index entry
SB253-SCOPE-2 Scope 2 greenhouse gas emissions — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for SB253-SCOPE-2 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members
Go deeper · SB253-SCOPE-2
Learn to prepare this disclosure end-to-end

This guide covers one statutory requirement. The California Climate Regulation course walks SB 253 and SB 261 end to end — applicability, GHG inventories, climate-risk reporting and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We built the coverage figure from utility and supplier records for the energy we bought or used, and we checked that the boundary was set to capture those indirect emissions wherever the activity occurred.The assurer will test whether the boundary was applied consistently and whether any purchased energy streams were left out or double-counted.Boundary memo; list of included energy sources and sites; utility invoices and supplier statements; consolidation or mapping schedule showing how locations were captured; review notes confirming no exclusions without justification.
We prepared the emissions numbers using the same calculation approach and guidance set used across the rest of our greenhouse gas reporting, and we kept the working papers that show that approach was followed.The assurer will probe whether the figures were calculated on a consistent basis and whether the team can demonstrate alignment with the chosen reporting method.Calculation methodology document; version-controlled spreadsheets or system outputs; references used by the preparer; internal methodology sign-off; evidence of any updates and why they were made.
For the location-based figure, we used the grid or local supply data tied to the places where the energy was consumed, then converted the result into tonnes of carbon dioxide equivalent for disclosure.The assurer will check whether the location-based number reflects the right consumption data, the right emission factors, and the correct unit conversion.Consumption data by site; emission factor source files; calculation workbook; unit conversion checks; reconciliation from site-level inputs to the disclosed total.
For the market-based figure, we used the contractual and supplier information we held for the period, and we retained the evidence showing how those instruments or claims were applied in the calculation.The assurer will test whether the market-based result is supported by valid contractual evidence and whether the treatment of supplier-specific information is consistent and complete.Contracts, certificates, tariffs or other supplier documents; register of instruments used; calculation workbook; checks on validity dates and coverage; evidence of review for overlaps or gaps.
We reported the prior financial year as the period covered, and we checked that the disclosed total ties back to the underlying working papers before publication.The assurer will look for a clear reporting period, a complete roll-up to the total, and evidence that the final number was reviewed before release.Reporting calendar; period-end cut-off note; final consolidation file; tie-out from source data to disclosed total; approval or sign-off record; publication checklist.

Evidence pack to prepare

Common reporting gaps

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps

Mistakes to avoid when collecting the data

Wrong owner, wrong inbox
The request goes to a generic sustainability contact instead of the team that actually holds electricity and utility records, so the data never reaches the person who can verify it.
Using framework language too early
The ask is framed in reporting jargon rather than the organisation’s own utility and energy terms, so the recipient cannot tell which internal records are needed.
No clear boundary for what is in scope
The collector does not define which sites, entities, or energy bills belong in the dataset, so some relevant usage is left out while unrelated items are pulled in.
+ Show 5 more

Where judgement is often needed

Set the reporting boundary after a buy, sale, or reorganisation
Decide whether the year covers the business as it stood before or after the change, explain the cut-off used, and keep the same approach across the period unless a change is clearly described.
Handle country-by-country electricity labels with one internal rule
Where local utility or contract labels differ, map them to a single internal method for purchased power and explain the mapping so the same site is treated consistently across locations.
Decide how to treat sites or activities near the boundary
For shared buildings, leased spaces, joint ventures, or other borderline cases, state the inclusion rule you used and explain any exclusions or partial inclusions.
+ Show 5 more
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — manufacturing

During our 2025 reporting year, we recorded the electricity and other energy services we bought for our sites, including purchased power and district heating/cooling. For that period, our combined indirect emissions were 18,400 tCO2e on a location basis and 16,900 tCO2e using our supplier- and contract-based approach. - Reporting period: 1 January 2025 to 31 December 2025 - Energy bought: 124,000 MWh of electricity, plus 8,500 MWh of steam and 3,200 MWh of cooling - Indirect emissions total: 18,400 tCO2e location-based; 16,900 tCO2e market-based

This is a synthetic, illustrative narrative showing the period covered, the energy services purchased, and both ways of presenting indirect emissions from that energy use.

Illustrative (synthetic) example — retail

For our 2025 reporting year, we tracked the power and thermal energy we procured for stores, warehouses, and offices. Our indirect emissions from that energy were 9,600 tCO2e on a grid-average basis and 8,750 tCO2e on a contract-adjusted basis. - Reporting period: 1 April 2025 to 31 March 2026 - Energy bought: 62,000 MWh of electricity, 1,400 MWh of heat, and 900 MWh of cooling - Indirect emissions total: 9,600 tCO2e grid-average; 8,750 tCO2e contract-adjusted

This is a synthetic, illustrative example for a different type of reporter, showing the same core data points in plain language.

Company reportsReal published reports
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How companies report SB253-SCOPE-2 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Host Hotels & Resorts, Inc.
Real Estate · United States · 2025
Open report →
Host Hotels & Resorts, Inc.'s 2025 Corporate Responsibility Report provides a market-based Scope 2 emissions figure of 88,524 metric tons CO2e on page 18, linked to renewable energy sources such as solar. The report also mentions Scope 1 emissions of 92,608 metric tons CO2e and references Scope 2 emissions in a location-based context on page 54, but does not clearly disclose a total Scope 2 emissions value. Notably, there is no information on the types of energy included in Scope 2, the location-based Scope 2 emissions figure, or the reporting period for Scope 2 emissions.
C.H. Robinson
Air Freight Transportation and Logistics · United States · 2025
Open report →
C.H. Robinson's 2025 Sustainability Report provides location-based Scope 2 greenhouse gas emissions data, reporting figures such as 20,894 mTCO2e for 2024 on page 62. The report also includes combined Scope 1 and 2 location-based emissions totals for 2024, with a value of 23,860 mTCO2e noted on the same page. However, the report does not clearly disclose Scope 2 market-based emissions or specify the reporting period for Scope 2 emissions, with only unclear references found on page 62 and no explicit details elsewhere.
Sands China Ltd.
Hotels, Restaurants, Leisure, Tourism Services · Macao · 2025
Open report →
Sands China Ltd.’s 2025 ESG Report provides a covered datapoint for total Scope 2 location-based greenhouse gas emissions, reporting values such as 644,119 MT CO2e and a reduction trend down to 379,186 MT CO2e on page 31. The report also discusses targets for reducing Scope 1 and 2 emissions by 60.2% by 2030 from a 2018 base year, with references to progress and validation on pages 7, 29, 30, and 31. However, there is no quotable evidence found regarding the types of energy used for Scope 2 emissions, nor details on market-based or location-based Scope 2 emissions reporting periods.
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Scenarios to work through

A group leases two offices and a small warehouse. It buys grid electricity for all three sites, plus district cooling for one office, and the finance team has separate figures for a location-based calculation and a supplier-contract-based calculation for the same reporting year.

QShould the disclosure cover those purchased energy types, and should both calculation views be kept for the same period?
Reveal model answer →

A preparer has a year-end total for bought electricity and steam, but the warehouse team also has a separate estimate for chilled water used in the same period. The draft note currently shows only one combined emissions figure.

QWhat should the preparer do before sign-off if the energy list is incomplete?
Reveal model answer →

A company’s market-based figure is lower than its location-based figure because it has supplier arrangements for part of its electricity. The sustainability team wants to report only the lower number because it looks cleaner.

QCan the preparer choose just one of the two figures for the disclosure?
Reveal model answer →

A preparer has the emissions totals ready, but the supporting file names show one quarter from the prior year and three quarters from the current year. The team argues that the annual total is still close enough to use.

QIs it acceptable to mix periods if the annual total seems reasonable?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

California
SB253-SCOPE-2
within California SB 253: Climate Corporate Data Accountability Act
Open official source →
Primary
Related & explore
Go deeper · SB253-SCOPE-2
Learn to prepare this disclosure end-to-end

This guide covers one statutory requirement. The California Climate Regulation course walks SB 253 and SB 261 end to end — applicability, GHG inventories, climate-risk reporting and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

FAQ

Questions this page answers

SB253-SCOPE-2: what data do I need to gather before I start the disclosure draft?+
How do I use the SB253-SCOPE-2 step-by-step preparation section in practice?+
For SB253-SCOPE-2, who should own the data collection and sign-off process?+
What evidence should I keep for SB253-SCOPE-2 assurance readiness?+
What are the five assurance claims on the SB253-SCOPE-2 page and how do I use them?+
What are the common reporting gaps or mistakes on SB253-SCOPE-2, and how do I avoid them?+
How do I use the SB253-SCOPE-2 workbook download to prepare the disclosure?+
What should I put in the SB253-SCOPE-2 draft output section?+
Can I use the SB253-SCOPE-2 example disclosure as a template for my own report?+
How does SB253-SCOPE-2 relate to ESRS E1, and can I reuse the same data?+
More questions this page can help with
SB253-SCOPE-2 checklist for sustainability manager: what should be ready before drafting?SB253-SCOPE-2 data owner guide: who should provide energy purchased for use and Scope 2 emissions data?SB253-SCOPE-2 assurance pack: what evidence should I assemble for the five claims?SB253-SCOPE-2 workbook download: how do I use the .xlsx file to track evidence and checks?SB253-SCOPE-2 printable Library Card PDF: when is it useful during drafting and review?SB253-SCOPE-2 common mistakes: what gaps should I look for before sign-off?SB253-SCOPE-2 example disclosure: how do I turn the synthetic example into a real draft?SB253-SCOPE-2 narrative starters: what wording prompts does the page give for the draft output?SB253-SCOPE-2 content index line: how do I use it in the final disclosure?SB253-SCOPE-2 grid-based vs contract-based Scope 2 emissions: how should I organise the two datapoints in the workbook?SB253-SCOPE-2 reporting year: how do I make sure the year is consistent across the draft and evidence pack?SB253-SCOPE-2 ESRS E1 correspondence: can I reuse the same underlying data for both pages?
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