Disclosure focus
The practical focus is on comparability and coverage: whether the reporting covers the organisation’s full operations or only selected parts, and how emissions are treated across the relevant sources and activities. The aim is to make the reported data understandable and traceable, rather than presenting headline figures without the method behind them.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official CARB source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Reference year
Sustainability reporting / ESG data ownerState which earlier reporting year is being used as the comparison point or base for the current disclosure.
Evidence Prior-year emissions schedule, reporting pack, or methodology note showing the chosen reference year.
Watch for The comparison year is taken from a different reporting cycle than the figures being reported, so the base year does not reconcile to the current inventory.
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Corporate accounting standard
Sustainability reporting / ESG data ownerConfirm the named corporate emissions accounting framework used to prepare the organisation-wide inventory.
Evidence Methodology document, reporting policy, or assurance pack naming the framework used for the corporate inventory.
Watch for The inventory is prepared under a different corporate accounting framework than the one stated, so the source methodology does not match the reported basis.
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Protocol alignment check
Sustainability reporting / ESG data ownerRecord whether the reporting approach follows the relevant emissions protocol and guidance, and capture the yes/no position used for disclosure.
Evidence Methodology memo, internal sign-off, or assurance checklist confirming the stated alignment position.
Watch for The yes/no flag is set without checking the actual reporting method against the protocol guidance, so the disclosure does not match the underlying approach.
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Method changes
Sustainability reporting / ESG data ownerDescribe any changes in calculation approach, data sources, boundary treatment, or assumptions compared with the last report.
Evidence Change log, methodology comparison note, or prior-year reporting pack with tracked updates.
Watch for A revised calculation method is used but the change is not captured against the prior report, so year-on-year figures are not comparable.
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Operational boundary
Sustainability reporting / ESG data ownerExplain how the reporting perimeter is set for activities and emissions sources included in the inventory.
Evidence Boundary memo, control assessment, or reporting policy showing how included operations are determined.
Watch for The operational perimeter is defined one way in the methodology but applied differently in the data pull, so included sources do not match the stated boundary.
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Group boundary method
Finance / consolidation teamSet out the rule used to decide which entities or interests are counted within the organisation for reporting.
Evidence Consolidation policy, legal entity list, or group structure paper showing the boundary rule applied.
Watch for The entity boundary is taken from a different consolidation basis than the one used in reporting, so subsidiaries or joint interests are included on the wrong basis.
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Scope 3 framework
Sustainability reporting / ESG data ownerConfirm the value-chain emissions framework used for indirect emissions outside the organisation’s direct operations.
Evidence Methodology note, inventory workbook, or assurance pack naming the scope 3 framework used.
Watch for The scope 3 inventory is built using a different value-chain framework than the one declared, so the reported basis does not reconcile to the underlying calculations.
Before you start
- Have you settled which reporting year, or comparison year, these figures will sit against?
- Have you chosen the company-bounding approach you will use to decide what sits inside the reporting perimeter?
- Have you chosen the emissions-bounding approach you will use to decide which activities and sources are counted?
- Can you trace the numbers back to a source record or working paper for each figure?
- If your approach changed since the last report, have you already noted what changed and why?
- Have you confirmed whether your method follows the GHG Protocol basis for the main company inventory and, where relevant, the value-chain emissions method?
How to prepare it
Request the data
Request the emissions method and reporting basis pack
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which emissions method, boundary choices, and comparison basis were used for the latest inventory, and what changed from the prior submission?
Use your organisation’s own terms first, then map them to the reporting labels in the pack. For example, if your team says ‘inventory year’, ‘group boundary’, or ‘value chain method’, keep that language in the request and only translate it at the end for reporting review. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Weak request
Please provide the GHG Protocol methodology, organisational boundary, operational boundary, Scope 3 standard use, and conformance statement for the disclosure.
Why it fails: This is too close to framework language and does not tell the owner what practical records to pull. It also mixes reporting labels without anchoring them to the team’s own working terms, which makes it harder to answer quickly and consistently.
Better request
Please send the emissions method pack for [period]: the comparison year or base year, how the group boundary was set, how the operational boundary was set, the method used for value chain emissions, whether the inventory follows the GHG Protocol standards and guidance, whether the corporate accounting and reporting standard was used, and what changed since the last report. Use your team’s normal wording in the first pass, then we will map it for reporting review.
Formal email template
Subject: Request for emissions method and reporting basis details Hi [Name], Could you please send over the evidence pack for the latest emissions inventory, including the method used, the boundary approach, the comparison year or base year, and any changes since the last submission? Please include: - the reporting period covered - the comparison year or base year used - the approach used to define the group boundary - the approach used to define the operational boundary - the method used for value chain emissions - whether the inventory follows the GHG Protocol standards and guidance - whether the corporate accounting and reporting standard was used - any changes made since the prior report - the source file or system reference Please use your team’s usual wording where helpful, then we can map it for reporting review. This is a possible LRA training template, so please adapt it to your organisation and check the source material before sign-off. Thanks, [Your name]
Short Teams / Slack version
Hi [Name] — could you share the emissions method pack for [period]? Please include the comparison year/base year, boundary approach, value chain method, any changes since last time, and the source file/system. Use your team’s usual terms first; we can map them for reporting review. Please adapt to your organisation and check the source material before sign-off.
Industry examples
Manufacturing
Context. A plant-based group with central sustainability reporting and local EHS input.
Adapted request. Hi [Name] — for [period], please share the inventory method pack for the plants and shared sites: the comparison year/base year, how the group boundary was set, how the site boundary was set, the method used for supplier and downstream estimates, any changes since last year, and the source workbook or system. Please use your normal site and group terms first, then we can map them for reporting review. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Example response. We used FY2023 as the comparison year. Group boundary was set using the control approach. Site boundary covered owned and operated facilities plus leased warehouses. Value chain emissions used a screening method with supplier estimates. Changes since last year: updated electricity and freight factors. Source: Inventory_Master_FY2024.xlsx.
Financial services
Context. A corporate reporting team coordinating with operations, procurement, and a data platform team.
Adapted request. Hi [Name] — please send the emissions method pack for [period] covering the group boundary, operational boundary, comparison year/base year, and the method used for financed and other value chain categories in the inventory model. Also include any changes from the prior report and the source model or data extract. Use your team’s usual wording first, then we can map it for reporting review. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Example response. Comparison year: FY2023. Group boundary: control approach. Operational boundary: direct operations and selected leased assets. Value chain method: portfolio screening plus supplier estimates where available. Changes: revised data source for purchased services. Source: GHG_Model_Q4_2024.
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
State the reference year, the accounting approach used, the boundary choices applied to the organisation and operations, the framework used for the main inventory and the separate framework used for value-chain emissions, and whether the approach follows the relevant guidance.
Context note
Explain that these settings define the basis on which the emissions figures were prepared, so readers can understand what the numbers cover and how they should be compared with earlier reporting.
Fluctuation statement
If the figures move because the reporting approach changed, say which parts of the method were updated and note that the shift may affect comparability with the prior period.
Content index entry
SB253-METHODOLOGY GHG Protocol methodology and reporting basis — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for SB253-METHODOLOGY with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We used the immediately preceding financial year as the reference period for the figure.
Risk The assurer will check whether the period is the correct one, whether it is clearly identified, and whether the same period is used consistently across the disclosure.
Evidence to check Board or management-approved reporting timetable; draft and final disclosure showing the named period; internal reporting pack or inventory file covering that period; sign-off notes confirming the period choice.
We prepared the disclosure using the company-wide emissions accounting framework we say we follow.
Risk The assurer will probe whether the named framework was actually applied, whether the team understood it, and whether the disclosure is not relying on an informal or partial approach.
Evidence to check Methodology memo; inventory procedures; working papers showing application of the framework; reviewer sign-off; any gap log where the framework was mapped to internal data processes.
We have stated that our approach follows the relevant greenhouse gas protocol guidance.
Risk The assurer will test whether the claim of alignment is supported by the actual calculation approach, source data treatment, and any departures or limitations.
Evidence to check Cross-reference matrix between the disclosure and the protocol guidance used internally; calculation files; documented judgments; exception log; evidence of review by the preparer and checker.
Where our approach changed from the earlier report, we documented the differences before publication.
Risk The assurer will look for whether changes were identified, whether their effect on the figure was considered, and whether the disclosure explains the change clearly enough to avoid misleading comparisons.
Evidence to check Change log versus the prior submission; version history; comparison of old and new methods; internal approval notes; reconciliation showing the effect of the change, if any.
We set out the boundary approach we used so readers can see what was included in the inventory.
Risk The assurer will check whether the boundary choice is explicit, applied consistently, and supported by the underlying consolidation or control logic.
Evidence to check Boundary policy; group structure chart; list of included and excluded entities or operations; control assessment papers; working papers showing how the boundary was applied.
We also explained how we defined the reporting group for the inventory.
Risk The assurer will probe whether the organisational perimeter is coherent, consistently applied, and aligned to the data collected for the disclosed figure.
Evidence to check Entity inclusion schedule; ownership or control analysis; consolidation memo; legal entity register; evidence that the same perimeter was used in the calculations.
Evidence pack to prepare
Common reporting gaps
- The information is presented without a date or as-at point.
- The scope or boundary of the statement is left undefined.
- Key terms are used inconsistently across the report.
- Material changes since the previous period are not disclosed.
- Assertions are made without supporting detail or a source record.
- Boilerplate is used that does not actually answer what is asked.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong owner for the evidenceThe team asks a framework lead instead of the business owner who actually holds the source records, so the answer comes back in the wrong language and cannot be traced to the original files.
- Boundary not fixed before collectionPeople start gathering data before agreeing which parts of the business and which activities sit inside the reporting set, so later figures cannot be compared on the same basis.
- Wrong time basisThe collector uses a different reporting period or reference year from the one used elsewhere, which makes the methodology note inconsistent with the numbers it supports.
- Mixed counting basisInputs are pulled from different counting approaches and then merged, so the final evidence pack no longer shows one clear basis for how the figures were built.
- Source labels get stripped outOriginal file names, system tags, or extract notes are removed during handling, leaving no way to show where each figure came from.
- Separate populations are mergedData for different business groups, sites, or activity sets is combined into one file even though they should stay distinct, which hides differences that matter for the method note.
- Evidence metadata is missingThe pack contains numbers but not the supporting context such as source date, owner, or extraction point, so reviewers cannot test whether the data is fit for use.
- No sign-off trailThe draft is passed along without a recorded review or approval step, so no one can show who checked the basis before it was used in reporting.
Judgement needed
- Set the opening year and keep it consistentChoose one comparison year for the emissions baseline and explain it clearly, especially if a later report switches to a different year for practical reasons.
- Explain any change in the group of entities coveredIf acquisitions, disposals or restructurings change what sits inside the reporting perimeter, describe what moved in or out and how you treated the numbers for the affected period.
- State how you drew the company boundarySet out the rule used to decide which businesses, sites or interests are counted, and note any judgement where local legal structures or ownership patterns make the decision less straightforward.
- Clarify the scope of day-to-day operations includedDescribe the approach used to decide which activities are treated as part of operations, including any borderline cases where control, influence or practical responsibility is shared.
- Explain how you handled mixed or inconsistent country dataWhere local records, units or definitions differ across countries, say how you converted them into one reporting basis and which source took priority when figures did not align.
- Disclose whether figures are measured or estimatedState where readings came from direct records and where you used estimates, including the main assumptions, proxies or calculation methods used for the estimated share.
- Describe timing choices for the reporting periodIf data were collected on a different cut-off, lagged basis or rolling timetable, explain the timing rule used so readers can see how the period was aligned.
- Show how you treated small or borderline populationsExplain the rule used for people, assets, sites or transactions near the edge of the reporting scope, including any threshold or practical cut-off applied.
- Explain any privacy-driven grouping or maskingIf individual-level information could not be shown, describe the aggregation or anonymisation approach used and confirm that the reported totals still reflect the underlying activity.
- Note any rounding or presentation conventionsState the rounding rule used for totals and sub-totals, and make clear that any small differences are due to presentation rather than a change in the underlying calculation.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We set our reporting against the 2023 fiscal year as the base period, and we say our approach follows the GHG Protocol corporate reporting framework and its value-chain companion guidance. Our boundary approach is operational control, and we confirm that our method is aligned with those GHG Protocol materials; compared with the prior filing, we changed only the way we allocate a small number of leased assets, with no change to the overall boundary approach or the base year. - Prior period used for comparison: 2023 fiscal year; - Main reporting framework applied: GHG Protocol corporate reporting standard; - Value-chain emissions guidance applied: GHG Protocol Scope 3 guidance; - Alignment statement: yes, we say our method is consistent with the GHG Protocol materials; - Boundary choices: operational control for the company boundary; - Changes since last report: a limited update to leased-asset allocation, with the rest unchanged.
Synthetic example for practitioner review only. It shows how a company might describe its base period, framework use, alignment statement, boundary choices, and any changes from the previous report without naming the organisation.
Our comparison year is 2022, and we prepared the disclosure using the GHG Protocol corporate reporting framework together with the value-chain emissions guidance. We apply a financial-control boundary for the group, and we state that our reporting is consistent with the GHG Protocol materials; since the last report, we revised the treatment of a small set of franchised sites, while keeping the comparison year and the overall method in place. - Reference year: 2022; - Framework for company emissions: GHG Protocol corporate reporting standard; - Value-chain emissions guidance: GHG Protocol Scope 3 guidance; - Consistency statement: yes; - Boundary approach: financial control; - Method updates since the prior filing: revised treatment of a limited number of franchised sites only.
Synthetic example for practitioner review only. It demonstrates a different sector, a different base year, a different boundary approach, and a different kind of methodology update while still covering the same required datapoints.
Quality ladder
- Basic
I reported 2024 emissions using the GHG Protocol and a prior-year comparison.
- Better
I reported 2024 emissions using the GHG Protocol, with 2023 as the comparison year, and I applied our chosen company and operations boundary methods plus the Scope 3 guidance.
- Best
I reported 2024 emissions under the GHG Protocol, using 2023 as the comparison year, applying our selected company and operations boundary methods and the Scope 3 guidance, and I noted that the year-on-year shift mainly reflects a boundary update rather than a change in underlying activity.
Check your understanding
Scenarios to work through
A group prepares its first California emissions filing after a merger completed mid-year. The team has one consolidated ledger for the new group, but the prior year figures sit in two legacy systems and were not restated.
A sustainability team has been using a market-based emissions tool built for internal dashboards, but the California filing needs a method that aligns with the GHG Protocol corporate accounting and reporting framework. The draft currently says only that the numbers are “prepared using internal methodology.”
A company has always reported under an equity-share approach, but this year it changed to a control-based approach because it now manages most operating decisions in its subsidiaries. The draft filing mentions the new approach but does not say whether the change affects comparability with last year.
A preparer is compiling Scope 3 data from suppliers, logistics providers and product-use estimates. The team has a general emissions policy, but the draft does not say whether the value-chain standard was used or whether the calculations follow the same recognised guidance throughout.
Real reports
How 3 companies report it
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Ingersoll Rand Inc.
Bank of America
C.H. Robinson
| Field | Ingersoll Rand Inc. | Bank of America | C.H. Robinson |
|---|---|---|---|
| Reference year | Not found | Not found | Not found |
| Corporate accounting standard | Not found | Not found | Partial |
| Protocol alignment check | Partial | Not found | Not found |
| Method changes | Partial | Partial | Partial |
| Operational boundary | Partial | Partial | Partial |
| Group boundary method | Partial | Partial | Partial |
| Scope 3 framework | Not found | Not found | Partial |
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Advice, not assurance
Framework references
Relevant California requirements and related disclosures
California
SB253-METHODOLOGY
within California SB 253: Climate Corporate Data Accountability Act
Related & explore
More in California SB 253 →Browse full catalogue →Search all disclosures →
FAQ
Questions this page answers
The page says to prepare seven core datapoints: reference year, corporate accounting standard, protocol alignment check, method changes, operational boundary, group boundary method, and the Scope 3 framework. Use those as your starting checklist before you draft anything.
Use it as a working sequence for getting the disclosure ready rather than as a final answer key. The page is designed to help you move from scoping and data collection through to a draft output and an evidence pack.
The page flags both items as datapoints to prepare, so you should confirm which accounting standard you are using and whether your reporting approach aligns with the relevant protocol. Keep the check documented so the method is clear in the draft and in the evidence pack.
The page treats both as method choices you need to set out before drafting. Record the boundary approach you used and keep the rationale in your working papers so the disclosure can be traced back to the source data.
Method changes are one of the datapoints to prepare, so you should identify any changes and capture them clearly in the draft. The page also points you to the evidence pack, which is where you would keep support for those changes.
The page includes an evidence pack with five items to support assurance readiness. Use it to assemble the documents and working papers that back up the disclosure before review or assurance.
The page says there are six assurance claims to verify, each with a claim, risk and evidence angle. Use that list to check what could go wrong and what proof you need before the disclosure is signed off.
The page includes a list of common reporting gaps and mistakes, so use it as a pre-submission check. It is there to help you spot missing method detail, weak evidence or other avoidable issues before the draft is finalised.
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Use those as building blocks to turn your prepared data and method notes into a first draft.
The Download Centre provides a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise preparation and assurance work, and the PDF as a quick reference while you draft.
The page notes ESRS E1 (Climate Change) as the closest correspondence, so some data may be reusable across both. Treat that as a practical cross-reference, not as a statement that the requirements are identical.
More questions this page can help with