Disclosure focus
The practical focus is on the organisation’s full operational footprint, not just a few prominent sites. Teams should think about where direct emissions arise across the business and make sure the reporting boundary is applied consistently so the figure reflects the organisation’s own operations as a whole.
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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Boundary for emissions
Finance / Sustainability reportingState which parts of the business are included when compiling the direct-emissions figure, so the reporting perimeter is clear and consistent.
Evidence Group structure chart, consolidation memo, boundary policy, list of included entities/sites.
Watch for The boundary does not reconcile to the consolidation basis, so entities are included or excluded on the wrong control basis.
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Calculation approach
Sustainability / Environmental dataDescribe the method used to turn activity data into the direct-emissions total, including the main assumptions and emission factors applied.
Evidence Calculation workbook, methodology note, emission factor source file, assumptions log.
Watch for The calculation method is mixed with a different factor set or conversion basis, so the total cannot be reproduced from the source data.
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Reporting timeframe
Finance / ReportingSpecify the exact time window covered by the direct-emissions figure, including start and end dates used for the report.
Evidence Reporting calendar, period-end close pack, emissions data extract dates, management reporting timetable.
Watch for The period is misaligned with the source data cut-off, so part-year activity is included or omitted.
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Emission activity sources
Operations / SustainabilityList the operational sources that feed into the direct-emissions figure, such as fuel use or other on-site combustion sources, as applicable to the business.
Evidence Source inventory, meter list, fuel purchase records, site operations logs, asset register.
Watch for A source category is missed or double-counted, so the inventory does not tie back to the underlying site and asset records.
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Direct emissions total
Sustainability / FinanceEnter the full direct-emissions amount for the reporting period, expressed in tonnes of carbon dioxide equivalent.
Evidence Final emissions calculation file, reviewed consolidation schedule, sign-off pack, source data extracts.
Watch for The reported total does not reconcile to the calculation workbook, or gross and net figures are mixed up.
Before you start
- Have you fixed the company perimeter for this figure — which sites, vehicles, equipment, and operations count, and which sit outside it?
- Are you clear on the method you will use to turn activity data into the emissions total, and is that method the same one used across the period?
- Which reporting window will you use for the number — the full year, a different 12-month span, or another cut-off — and does it match the source records?
- Have you listed every direct release source you plan to include, so nothing is missed or counted twice?
- Can you trace the total back to source records and working papers, with enough support to explain how the final tCO2e was built?
How to prepare it
Request the data
Request the Scope 1 emissions pack from EHS / Operations
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What is our total direct greenhouse gas emissions figure for the reporting year, and what boundary, method, period and source list support it?
Use your organisation’s own terms first for the team, systems and asset groups involved, then map them to the reporting labels in the pack. Keep the ask in business language your colleagues already use, and check the source material before sign-off.
Weak request
Please provide the Scope 1 evidence for the disclosure.
Why it fails: It uses framework language only, so the owner may not know which team records, systems or assets to pull. It also does not say what period, sources, method or total should be included, so the response may be incomplete or hard to verify.
Better request
Please send the direct emissions pack for [reporting year] from your team’s records. Include the period covered, the sites/assets/fuel streams included, the calculation approach, the total in tCO2e, and the source extracts or workbook used to build it. Please use your team’s own names for the categories and add any estimate or exclusion notes.
Formal email template
Subject: Request for direct emissions data pack for [reporting year] Hi [name/team], Could you please send over the data pack for our direct emissions figure for [reporting year]? Please include: - the boundary used for the figures - the method used to calculate the total - the reporting period covered - the list of emission sources included - the total emissions value in tCO2e - the source files or system extracts used to build the numbers - any notes on estimates, exclusions or changes from the prior year Please also confirm the version date and who prepared the pack. If helpful, you can use the attached response form. Please adapt this to your organisation’s own terms and check the source material before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name/team] — could you send the direct emissions pack for [reporting year]? Please include the boundary, method, period, source list, total tCO2e, source extracts and any estimate/exclusion notes. Please adapt this to your organisation’s own terms and check the source material before sign-off. Thanks.
Industry examples
Manufacturing
Context. A plant with boilers, furnaces, backup generators and a company van fleet.
Adapted request. Please send the direct emissions pack for [reporting year] covering the plant, warehouse and fleet records. Include the fuel logs, generator run data, refrigerant records, the calculation workbook, the total tCO2e and any exclusions or estimates.
Example response. Attached: plant fuel ledger, fleet card extract, refrigerant log, emissions workbook v4, total direct emissions 12,480 tCO2e, with backup generator estimates flagged in notes.
Property / Real Estate
Context. A portfolio with offices, landlord-controlled plant and tenant areas.
Adapted request. Please send the direct emissions pack for [reporting year] covering landlord-controlled energy systems and any company-owned vehicles. Include the building list, meter extracts, refrigerant records, calculation method, total tCO2e and any sites excluded from the total.
Example response. Attached: portfolio boundary note, meter export, chiller maintenance log, vehicle fuel extract, calculation file v2, total direct emissions 3,210 tCO2e, with one leased site excluded and explained in the notes.
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 which parts of the business were included in the calculation, name the approach used to quantify the figures, and note the time window covered by the data.
Context note
Explain that the figures represent the organisation’s direct climate impact from the activities counted in the inventory, rather than a wider value-chain view.
Fluctuation statement
If the total moved materially, point to the main operational drivers, changes in included sources, or any shift in the calculation basis that affected the result.
Content index entry
SB253-SCOPE-1 Scope 1 greenhouse gas emissions — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for SB253-SCOPE-1 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
I prepared the coverage figure using the group structure and control position that applied in the reporting year, and I checked whether any acquisitions, disposals or other structural moves changed what should be included.
Risk The assurer will test whether the boundary was set consistently, whether all relevant owned or controlled sources were brought in, and whether changes in the business were reflected correctly.
Evidence to check Group structure chart; legal entity and operational control mapping; acquisition/disposal register; boundary memo; year-end consolidation papers; management sign-off on inclusion/exclusion decisions.
I treated the disclosed operations as covering sources we own or directly run, wherever they sit geographically, and I documented any exclusions with a clear reason.
Risk The assurer will probe whether the scope is complete across locations and whether any omitted sources were left out for a defensible reason rather than convenience.
Evidence to check Asset and site register; control assessment; list of included and excluded sources; rationale for exclusions; site-level inventory; internal review notes.
I calculated the figure using the accounting approach we selected for this disclosure, and I kept the working papers showing how the method was applied to the underlying activity data.
Risk The assurer will check whether the chosen method matches the stated reporting basis and whether it was applied consistently to all relevant data.
Evidence to check Methodology paper; calculation workbook; emission factor source list; activity data extracts; version history; reviewer comments and approvals.
I reviewed whether business changes during the year affected the way the number was built, and I adjusted the calculation basis where those changes would otherwise distort the result.
Risk The assurer will look for evidence that structural changes were identified, assessed and reflected in the calculation rather than ignored.
Evidence to check M&A and restructuring papers; change log; recalculation memo; prior-period comparison analysis; management review evidence.
I used the prior fiscal year as the reporting period for the disclosed number and checked that the dates in the supporting files matched that period.
Risk The assurer will test whether the figure relates to the correct year and whether the source data and final disclosure are aligned to that period.
Evidence to check Reporting calendar; period-end data extracts; ledger or operational reports for the year; reconciliation to the disclosed period; sign-off pack.
I listed the direct emission sources that fed into the total, and I kept a source inventory that ties each item back to the underlying site or asset.
Risk The assurer will probe completeness of the source list and whether each source can be traced to a real operational basis.
Evidence to check Source inventory; site/asset register; mapping from sources to locations or equipment; inclusion/exclusion rationale; supporting operational records.
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.
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 asked firstThe request goes to a team that does not hold the fuel, fleet, or site records, so the data chase starts with people who cannot confirm the numbers.
- Framework language used too earlyStaff ask for the figure in reporting jargon instead of the business terms used on the ground, which leads to mismatched answers and extra rework.
- Boundary never pinned downNo one agrees which parts of the business sit inside the data pull, so some sites or assets are included twice while others are left out.
- Wrong time window selectedThe team pulls activity from a different period than the one being reported, so the emissions total no longer matches the intended year or cycle.
- Counting basis mixed togetherDifferent calculation approaches are blended in one file without a clear split, which makes the final total impossible to trace back cleanly.
- Source labels stripped outOriginal tags from invoices, meter reads, logs, or system exports are removed, so later reviewers cannot see where each input came from.
- Separate populations mergedRecords that should stay apart, such as different sites, vehicles, or operating units, are combined into one pool and the underlying pattern is lost.
- Evidence trail left incompleteThe file has numbers but not the supporting metadata, so no one can tell who supplied the input, when it was captured, or which version was used.
- No sign-off recordedThe draft moves forward without a named reviewer confirming the source pack, leaving no clear trail of who checked the data before it was passed on.
Judgement needed
- Acquisitions, disposals, and other boundary shiftsIf the business has bought, sold, or restructured operations during the period, set out which sites and activities sit inside the reporting perimeter for the year and explain any change from the prior year basis.
- Different country rules for the same activityWhere local reporting or operational definitions differ across jurisdictions, choose one consistent company basis for deciding what counts in scope and explain that basis clearly.
- Borderline sources and shared operationsFor assets or activities that sit near the edge of the perimeter, decide whether they are included or left out using a documented control or ownership logic, and describe the treatment of any shared or jointly run sources.
- Period cut-off and timing choicesIf emissions data do not align neatly with the reporting year, explain the cut-off used, how late or early activity was handled, and whether any estimates were needed to bridge gaps.
- Measured data versus estimatesState which figures came from direct measurement and which were estimated, explain the method used for each estimate, and note any material assumptions that affected the total.
- Method changes from one year to the nextIf the calculation approach, emission factors, or source coverage changed, explain what changed, why it changed, and whether the prior-year figure was restated or left as originally reported.
- Rounding and presentation of the totalUse one consistent rounding approach across the disclosure, make sure the rounded total still reflects the underlying data, and note the rounding basis if it could affect comparability.
- Privacy limits and grouped reportingWhere site-level detail cannot be shown because of confidentiality or privacy constraints, aggregate the data at a higher level, explain the grouping used, and keep the total traceable to the underlying sources.
- Mixed ownership or operational controlFor assets that are partly owned, leased, or operated with others, explain the rule used to decide whether the emissions sit inside the company total and how any shared emissions were allocated.
- Incomplete source coverageIf some emission sources are not yet fully captured, disclose which sources are included, which are still being brought into the process, and how any missing data were treated in the total.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We report for our consolidated operations covering 1 January to 31 December 2025, and the figures below relate to the sites and activities we control in that period.
- We used an activity-based approach with emission factors to convert fuel use and other direct sources into tonnes of CO2e.
- Our direct emissions came from gas-fired boilers, company vehicles, and on-site backup generators.
- For this reporting year, our total direct greenhouse gas emissions were 18,400 tCO2e.
This example shows a first-person narrative disclosure that identifies the reporting year, explains the boundary in plain terms, names the main direct sources, and states the calculation approach and total.
Our disclosure covers the full year from 1 April 2025 to 31 March 2026 and includes the business units and facilities we operate and control.
- We estimated direct emissions using measured fuel consumption and standard conversion factors.
- The main sources were refrigeration leaks, natural gas used in processing, and delivery vans.
- Our total direct greenhouse gas emissions for the period were 9,750 tCO2e.
This example uses different wording and a different sector while still showing the period covered, the organisational boundary, the method used, the direct sources included, and the total direct emissions.
Quality ladder
- Basic
I report 12 tCO2e for our direct emissions.
- Better
I report 12 tCO2e for our direct emissions from owned vehicles and on-site fuel use, calculated for the 2025 financial year using our internal emissions method.
- Best
I report 12 tCO2e for our direct emissions from owned vehicles and on-site fuel use for the 2025 financial year, calculated using our internal emissions method, and the figure is lower than last year because we used less fuel across the fleet and facilities.
Check your understanding
Scenarios to work through
A manufacturing group runs one UK site and two overseas depots. The sustainability team has emissions from gas boilers, company vans and backup generators, but the finance team is unsure whether to include a leased warehouse where the group does not control fuel use.
A retailer has calculated direct emissions using fuel purchase records for its fleet and gas meters for its stores. The team also has an estimate for refrigerant leaks, but the working papers do not explain how the estimate was built.
A group reports on a calendar-year basis, but one business unit has prepared direct emissions for its own financial year ending 31 March. The consolidated pack also includes a total for the previous 12 months, but no one has confirmed which period the disclosure should cover.
An industrial company has direct emissions from boilers, owned delivery trucks and a small on-site generator. The draft note gives a total of 18,400 tCO2e, but it does not say which sources were included, and the team is unsure whether to mention all source types or only the largest ones.
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.
Host Hotels & Resorts, Inc.
C.H. Robinson
Bank of America
| Field | Host Hotels & Resorts, Inc. | C.H. Robinson | Bank of America |
|---|---|---|---|
| Boundary for emissions | Not found | Not found | Partial |
| Calculation approach | Partial | Partial | Partial |
| Reporting timeframe | Not found | Not found | Not found |
| Emission activity sources | Not found | Not found | Not found |
| Direct emissions total | Not found | Not found | Partial |
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Advice, not assurance
Framework references
Relevant California requirements and related disclosures
California
SB253-SCOPE-1
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
Use the page’s plain-language explainer and the datapoints to prepare as your starting checklist: boundary for emissions, calculation approach, reporting timeframe, emission activity sources, and the direct emissions total. The step-by-step preparation section then helps you turn those inputs into a draft.
The page tells you to prepare a boundary for emissions, so the practical task is to define what is in scope before you calculate or write up the disclosure. Keep the boundary decision documented in your evidence pack so the draft can be checked later.
The page asks you to prepare a calculation approach, so you should record the method you used and keep it consistent with the rest of the data you are reporting. The assurance section and evidence pack are there to help you show how the figure was built.
The page says to prepare the reporting timeframe, so make sure the period covered by the disclosure is explicit in your draft and supporting files. That helps the reviewer see which data set the direct emissions total relates to.
The page is useful for assigning ownership because it separates the data points, the assurance checks, and the evidence pack. In practice, that lets a sustainability lead, data owner, or reviewer see who is responsible for each part of the draft.
The page includes an evidence pack with five items for assurance readiness, so you should use that as the core file set behind the disclosure. It also lists six assurance claims to verify, which helps you match each claim to supporting evidence.
The page has a section on common reporting gaps and mistakes, so use that before finalising the draft to check for missing scope, unclear methods, or incomplete support. It is meant to help you catch avoidable issues early rather than after review.
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is designed to help you organise the preparation and assurance steps. Use it alongside the printable Library Card if you want a quick reference while drafting or reviewing.
The page includes synthetic illustrative example disclosures, including a quantitative table, so you can see how the information may be presented in practice. Treat the example as a drafting aid only and make sure your own figures and scope are internally consistent.
The page says the closest ESRS correspondence is ESRS E1 (Climate Change), so the data may be reusable across both contexts. It does not say the requirements are identical, so you still need to check the other framework separately.
The page has a draft-output section with visualisation ideas, narrative starters, and a content-index line, which you can use to shape the final write-up. That makes it easier to move from collected data to a clear draft for review.
More questions this page can help with