California SB 253 — Scope 3 greenhouse gas emissions

Q: For SB253-SCOPE-3, what data do I need to gather before I start drafting the disclosure?

The page says to prepare the included Scope 3 categories, category emissions split, data source mix, estimation approach, reporting year window and the Scope 3 total emissions. It also gives a step-by-step preparation section to help you organise those inputs before drafting.

Q: How do I work out which Scope 3 categories to include in the SB253-SCOPE-3 disclosure?

Use the page’s preparation list to identify the included Scope 3 categories and then keep the category emissions split aligned to those categories. The page is designed to help you set the scope before you turn the data into a draft.

Q: What should I record about the data sources and estimation approach for SB253-SCOPE-3?

The page asks you to prepare a data source mix and an estimation approach, so you can explain where the numbers came from and how they were built. That helps you keep the disclosure and the evidence pack consistent.

Q: How do I assign ownership for SB253-SCOPE-3 data collection across ESG, HR and data owners?

The page is set up for practical preparation, so you can use the workbook and step-by-step section to assign who owns each input, such as category data, source data and the final total. It is meant to support a clear handoff into drafting and assurance readiness.

Q: What evidence should I keep ready for assurance on SB253-SCOPE-3?

The page includes an evidence pack with five items and six assurance claims to verify, each with a claim, risk and evidence focus. That gives you a practical starting point for building an assurance-ready file set.

Q: What are the six assurance claims on the SB253-SCOPE-3 page and how do I use them?

The page says there are six assurance claims to verify, each linked to a claim, risk and evidence check. Use them as a review list to test whether your draft, calculations and supporting documents line up before sign-off.

Q: What are the common reporting gaps or mistakes on the SB253-SCOPE-3 page?

The page lists common reporting gaps and mistakes so you can check for missing categories, inconsistent splits, weak source explanations or gaps between the draft and the evidence pack. It is intended as a practical pre-submission check.

Q: How can I use the Prep & Assurance workbook for SB253-SCOPE-3?

The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is there to help you organise the preparation inputs and assurance checks. The page also provides a printable Library Card in .pdf for quick reference.

Q: How do I turn the SB253-SCOPE-3 data into a draft disclosure?

The page has a draft-output section with visualisation ideas, narrative starters and a content-index line to help you convert the prepared data into a written draft. It is designed to move you from data collection to a usable disclosure text.

Q: Can I use the SB253-SCOPE-3 page to compare my data with ESRS E1 climate reporting?

Yes, the page notes ESRS E1 (Climate Change) as the closest correspondence, so the data may be reusable across both contexts. It does not say the requirements are identical, so you should treat it as a practical cross-reference rather than a one-to-one match.

Disclosure focus

The practical emphasis is usually on coverage across the organisation’s operations and value chain, not just a few flagship sites or the easiest-to-measure activities. Organisations should think about whether their reporting approach is broad enough to reflect the full business footprint, while also being clear about any gaps, estimates, or areas where data quality is still developing.

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.

Included Scope 3 categories
Sustainability reporting / ESG data owner

List which indirect emissions categories are counted in the reported Scope 3 figure, using the organisation’s chosen category set for the period.

Evidence GHG inventory boundary note, category list in the emissions workbook, reporting pack sign-off.

Watch for Category list does not reconcile to the inventory workbook, so a category is counted in one place but left out of the reported set.
Category emissions split
Carbon accounting / sustainability analytics

Capture the emissions amount for each included Scope 3 category, with each category mapped to its own figure for the same reporting period.

Evidence Category-level emissions schedule, calculation workbook, source activity data and emission factor files.

Watch for Category totals do not reconcile to the category schedule, or a category is rolled into the wrong bucket.
Data source mix
Carbon accounting / data methodology lead

Record which parts of the Scope 3 calculation use direct records, supplier-provided inputs, proxy estimates, or sector averages.

Evidence Methodology note, source log, supplier data extracts, estimation workbook.

Watch for Source type labels do not match the calculation files, so direct supplier data is mixed up with proxy or average-based inputs.
Estimation approach
Carbon accounting / methodology owner

Describe the calculation approach used to turn activity data into Scope 3 emissions, including the main estimation logic applied.

Evidence Calculation methodology, model notes, emission factor library, assumptions register.

Watch for The method used in the workbook does not match the method described in the disclosure, so the calculation basis is misclassified.
Reporting year window
Financial reporting / ESG reporting controller

State the exact reporting period used for the Scope 3 figure, including the start and end dates covered by the data.

Evidence Annual reporting timetable, consolidation calendar, period control sheet.

Watch for The disclosure period does not match the underlying data cut-off, so part-year data is mixed with a full-year total.
Scope 3 total emissions
Carbon accounting / ESG reporting owner

Provide the single total amount of Scope 3 emissions for the reporting period, expressed in tonnes of carbon dioxide equivalent.

Evidence Final consolidated emissions statement, signed reporting pack, calculation summary.

Watch for The total does not reconcile to the sum of the included category figures, or a non-Scope 3 amount has been pulled into the total.

Before you start

Have you settled which upstream and downstream activity groups you will include in the total, and which ones you will leave out?
Will the figures come from one defined reporting window, and is that period the same one used across the rest of your emissions work?
Can each category figure be traced back to a source record or dataset, rather than only to a summary total?
For each category, have you decided whether the input comes from direct records, a secondary dataset, a proxy, or an industry-average source?
Have you fixed the method you will use to turn activity data into emissions for each category, so the approach is consistent and explainable?

＋ Show SB253-SCOPE-3 sub-elements (LRA working checklist)

How to prepare it

Set the reporting boundary first: confirm which indirect emissions sources you are covering for the period, and list the categories you will include in the submission.

For each included category, decide what counts as in-scope activity and gather the supporting records that show the source data used to build the calculation.

Choose and record the calculation approach for each category, including whether you relied on direct data, supplier information, estimates, or sector averages.

Compile the figures by category and then roll them up to the overall total for the reporting year, keeping the category breakdown and the total consistent with each other.

Note any exclusions, substitutions, or changes in method, and explain why they were made so the final submission can be traced back to the underlying evidence.

Check the completed disclosure against the official source before filing, making sure the period, category list, methods, evidence trail, breakdown, and total all align.

Request the data

Request the Scope 3 emissions data

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

What is the organisation’s total indirect emissions figure for the reporting period, with the category split, source basis and calculation approach behind it?

Use your organisation’s own names for the teams, systems and emissions buckets first, then map them to the reporting categories for this request. Keep the ask in everyday operational language rather than framework wording, and check the official source before sign-off.

Weak request

Please provide the Scope 3 disclosure data for the reporting period, including category coverage, category emissions, data sources, estimation methods and total emissions.

Why it fails: It uses framework language that many operational teams do not use day to day, so the owner may not know which systems, buckets or files to pull. It also does not tell them how to present the split, what to include as evidence, or which internal labels to use.

Better request

Please send the indirect emissions figures for [reporting period], split by your internal emissions buckets, with the source used for each bucket, the calculation approach, and the total for the period. Include any buckets that are only partly covered or excluded, and return the file or system name used to build the numbers.

Formal email template

Subject: Request for indirect emissions data for [reporting period]

Hi [name/team],

I’m pulling together the sustainability reporting pack and need your help with the indirect emissions figures for [reporting period].

Please send:
- the total indirect emissions figure for the period;
- the breakdown by your internal emissions buckets / activity areas;
- which buckets are included in the total and which are not;
- the data sources used for each bucket (for example, actual records, supplier data, proxy or industry-average estimates);
- the calculation approach used;
- the reporting period covered;
- the file name, system, or model used to produce the numbers.

Please return the figures in a table and add a short note on any assumptions, gaps, or changes from the prior period.

If helpful, I can send a simple template. Please adapt this to your organisation’s own terms first, then map it to the reporting categories. Check the official source before sign-off.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name/team] — could you send the indirect emissions figures for [reporting period], plus the split by your internal buckets, the data source for each one, and the method used to calculate them? Please include any exclusions, assumptions, and the file/system used. I can share a simple template if useful. Please adapt this to your organisation’s own terms first, then map it to the reporting categories. Check the official source before sign-off.

Industry examples

Retail

Context. A retailer tracks emissions across stores, warehouses, transport and supplier spend.

Adapted request. Please send the indirect emissions figures for [reporting period], split by your internal buckets such as inbound freight, outbound delivery, packaging, waste, business travel and purchased goods. For each bucket, include the source used, whether it is actual data or an estimate, and the method used to calculate emissions.

Example response. A table showing each bucket, the mapped reporting category, the data source type, the calculation method, and emissions in tCO2e, plus a note that supplier-specific data was available for some purchased goods lines and spend-based estimates were used for the rest.

Manufacturing

Context. A manufacturer collects data from procurement, logistics, travel and product teams.

Adapted request. Please send the indirect emissions figures for [reporting period], split by your internal activity areas such as raw materials, inbound freight, outbound logistics, waste, employee travel and product use assumptions. Include the source system for each area, the basis used where actual records are not available, and the total emissions for the period.

Example response. A spreadsheet with each activity area, the source system, whether the figure is based on primary records or a proxy, the calculation method, and emissions in tCO2e, plus a note that logistics data came from the transport management system and some supplier inputs were estimated using industry averages.

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 value-chain categories are included, what reporting period the figure covers, which calculation methods were used, and whether the inputs came from direct records, secondary records, proxy data, or sector averages.

Context note

Explain that the total reflects emissions across the included value-chain categories, while the category split shows where the main contributions sit and how much each part adds to the overall figure.

Fluctuation statement

If the total or category mix changes, point to shifts in the included categories, the underlying data sources, or the estimation approach, and note whether the reporting period itself also changed.

Content index entry

SB253-SCOPE-3 Scope 3 greenhouse gas emissions — [location / page] / [notes]

Download Centre

Preparation tools & forms

Download preparation tools for SB253-SCOPE-3 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access

01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Check

For each claim, check the evidence

We set out which parts of the wider value-chain inventory we included in the coverage figure, so readers can see the boundary we used.
Risk An assurer may test whether the boundary was chosen consistently, whether any relevant parts were left out without explanation, and whether the wording could mislead readers into thinking the figure is more complete than it is.
Evidence to check Inventory boundary paper; category inclusion/exclusion list; methodology note explaining any omissions; management sign-off on the final boundary.
We broke the disclosed amount down by category, rather than only giving one combined figure, so the underlying components can be traced.
Risk An assurer may probe whether each category total is supported by source data, whether categories were grouped or split consistently, and whether the sum of the parts reconciles to the published total.
Evidence to check Category-level calculation workbook; source extracts for each category; reconciliation from category totals to the published aggregate; review notes for any regrouping or mapping decisions.
For each part of the calculation, we recorded the type of input used, including direct records, third-party information, estimated inputs, and benchmark-based inputs where relevant.
Risk An assurer may challenge whether the input type was correctly classified, whether weaker inputs were used where better evidence was available, and whether the mix of inputs creates a material quality issue.
Evidence to check Data source register; evidence of source classification for each line item; supplier or internal records; rationale for any estimated or benchmark-based inputs.
We documented the calculation approach we used for the disclosed amount, including the estimation steps and any conversion or allocation logic applied before publication.
Risk An assurer may test whether the method was applied consistently, whether the chosen approach fits the stated accounting basis, and whether the calculation logic contains errors or unsupported assumptions.
Evidence to check Methodology memo; calculation model; emission factor or conversion factor file; assumption log; version-controlled spreadsheets or system outputs.
Where the reporting boundary changed because of a transaction or other structural event, we adjusted the disclosed amount using the same accounting approach throughout the period.
Risk An assurer may ask whether acquisitions, disposals, mergers, or similar events were identified completely, whether the treatment was consistent with the stated method, and whether the adjustment could distort comparability.
Evidence to check Corporate transaction register; boundary-change assessment; supporting schedules showing pre- and post-change treatment; approval of the adjustment approach.
We stated the prior financial year covered by the data and checked that the publication timing aligned with the required sequence of disclosures.
Risk An assurer may verify that the period stated matches the underlying data set, that the timing is correct relative to the earlier public release, and that the reported year is not ambiguous.
Evidence to check Reporting calendar; published dates for the earlier disclosure and the current one; period-end data extracts; final disclosure draft showing the stated year.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

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 askedThe team chases the sustainability lead for figures that sit with procurement, logistics, finance, or another operational owner, so the source data never comes from the people who actually hold it.
Framework terms used too earlyPeople ask for the data in reporting-language terms instead of the business terms used day to day, and the request is misunderstood or routed to the wrong internal team.
Boundary left vagueNo one pins down which parts of the business, subsidiaries, or activities are in the data set, so different teams collect different slices and the final numbers do not line up.
Wrong period basisThe collection window is not fixed to the same reporting period across teams, so some records are pulled from a different date range and cannot be compared cleanly.
Counting basis mixedOne team sends spend-based estimates while another sends activity-based figures without flagging the difference, which makes the combined result inconsistent and hard to reconcile.
Source labels stripped outOriginal tags such as supplier file names, system fields, or method notes are removed during consolidation, so the audit trail back to the starting record is lost.
Populations merged too soonSeparate groups such as business units, regions, or transport modes are rolled together before review, which hides gaps and makes it impossible to check each group properly.
Evidence details missingThe file arrives without the date, owner, version, or other trace details needed to show where it came from and when it was last updated.
No approval trailThe draft numbers move forward without a clear review and sign-off record, so nobody can show who checked the data or confirmed it before use.

＋ Show 5 more

Judgement needed

Set the group boundary after a buy-in or saleDecide whether to include emissions from businesses added or removed during the year, explain the cut-off date you used, and keep the same approach unless a change is clearly justified.
Handle mixed country definitions with one internal ruleWhere local records use different business or activity definitions, map them to one group-wide method, note any exceptions, and explain how you translated the source data.
Decide how to treat activities near the edge of the value chainFor items that could sit inside or outside the reporting boundary, state the rule used to include or exclude them and describe any material judgement made.
Choose one timing basis and stick to itIf source data arrive on different reporting cycles, explain whether you used actual period data, a later proxy, or another timing basis, and why that was the most workable option.
Separate measured figures from estimatesShow which parts come from direct records and which rely on proxies, industry averages, or other estimates, and explain the method used to fill gaps.
State how you dealt with privacy limits in small datasetsIf detailed operational data could identify individuals or sensitive sites, aggregate the figures before reporting and explain the level at which the numbers were combined.
Explain any rounding approachIf category figures or the total are rounded, say how you rounded them and make sure the rounded category values still reconcile sensibly to the total.
Keep the reporting year clear when the data trail is incompleteIf the best available evidence spans more than one internal cycle, explain the period covered, the basis for any roll-forward or roll-back, and how that affects comparability.

＋ Show 4 more

Examples

How it reads on the page

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

Illustrative (synthetic) example — Manufacturing

for the 2025 reporting year, we have set out the parts of our value-chain footprint that we included, the emissions attached to each part, and the methods and data types used to build the estimate. Our total Scope 3 figure is 1,240,000 tCO2e.

Illustrative Scope 3 breakdown for the 2025 reporting year (tCO2e)

Included value-chain area	Emissions (tCO2e)
Purchased goods and services	420000
Capital goods	90000
Fuel- and energy-related activities	60000
Upstream transport and distribution	110000
Waste generated in operations	30000
Use of sold products	530000

Illustrative only. Shows a concise first-person disclosure that names the included value-chain areas, gives category-level figures, and explains the main estimation approach and data inputs used for the year.

Illustrative (synthetic) example — Retail

for the 2025 reporting year, we included the value-chain areas listed below and estimated them using a mix of primary records, supplier inputs, proxy data, and sector averages where needed. Our total Scope 3 figure is 385,000 tCO2e.

Illustrative Scope 3 breakdown for the 2025 reporting year (tCO2e)

Included value-chain area	Emissions (tCO2e)
Purchased goods and services	150000
Upstream transport and distribution	25000
Waste generated in operations	10000
Business travel	15000
Employee commuting	5000
Downstream transport and distribution	180000

Illustrative only. Shows a second plausible reporter with a different mix of included areas and a smaller footprint, while still identifying the reporting year, the data sources used, and the estimation approach.

Quality ladder

Basic
My Scope 3 total for the period was 12,400 tCO2e.
Better
For the year ended 31 December 2025, I reported 12,400 tCO2e across purchased goods, transport, business travel and waste, using supplier data where available and estimates where not.
Best
For the year ended 31 December 2025, I reported 12,400 tCO2e across purchased goods, transport, business travel and waste, based on a mix of supplier records, proxy data and industry averages, and the rise from last year mainly reflects higher freight activity and broader category coverage.

Check your understanding

Scenarios to work through

A preparer has a draft table for the year ended 31 December 2025. It shows a single total for value-chain emissions, but the working papers only cover purchased goods, transport, and business travel; no other categories have been assessed yet.

QShould the disclosure go out with only those three categories listed, or does the team need to confirm whether any other value-chain categories are included before sign-off?

Reveal model answer →

A company has calculated its value-chain emissions using supplier-specific activity data for some purchased materials, spend-based estimates for freight, and an industry-average factor for leased assets. The draft notes mention the methods, but not which source type was used for each category.

QIs it enough to say the figures were estimated, or does the preparer need to identify the source type used for the different parts of the calculation?

Reveal model answer →

A group reports its value-chain emissions for the 2025 financial year, but one business unit has used calendar-year supplier data and another has used a rolling 12-month estimate ending in March 2025. The consolidated total is ready, but the reporting note does not explain the period basis.

QCan the preparer present the total without clarifying the time period used for the underlying calculations?

Reveal model answer →

A preparer has a final value-chain total of 18,400 tCO2e for 2025. The category breakdown adds up correctly to that total: purchased goods 9,600 tCO2e, upstream transport 2,300 tCO2e, business travel 1,100 tCO2e, and other categories 5,400 tCO2e.

QIs the total enough on its own, or should the disclosure also show the split by category and the overall figure together?

Reveal model answer →

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.

Real published reports

C.H. Robinson

Air Freight Transportation and Logistics · United States · 2025 · p.20 ↗

C.H. Robinson’s 2025 Sustainability Report provides a total Scope 3 greenhouse gas emissions figure, reported as 17,811,002 metric tonnes CO2 equivalent on page 62. The report references Scope 1, 2, and 3 emissions and includes some discussion of emissions intensity targets and an emissions dashboard (pp. 17, 21), but it does not provide a breakdown of Scope 3 categories, data sources, or the reporting period. Additionally, the report lacks clear information on the methods used to estimate Scope 3 emissions.

Cargill

Food Production — Agricultural · United States · 2025 · p.109 ↗

Cargill's 2025 Impact Report includes coverage of Scope 3 emissions, specifically noting the footprint of agricultural commodities sourced from producers (p.19). The report also references Scope 3 emissions in the cocoa and chocolate supply chain and related farmer support initiatives (p.65). However, the report does not provide a detailed breakdown of Scope 3 categories, data sources, estimation methods, reporting period, or total Scope 3 emissions, leaving these aspects unclear or missing.

Bank of America

None · United States · 2025 · p.18 ↗

Bank of America's 2025 sustainability report provides some context on Scope 3 emissions, noting the organizational boundary for GHG emissions reporting and gases included in Scope 1, 2, and 3 calculations (p.18). The report includes data on financed emissions by sector and subsector boundaries for 2023 and 2024 (p.23), as well as information on carbon credit retirements affecting net Scope 1 and market-based Scope 2 emissions (p.20). However, the report lacks clear disclosures on Scope 3 categories included, category breakdowns, data sources, reporting periods, and estimation methods, with the total Scope 3 emissions figure remaining unclear (p.18).

Field	C.H. Robinson	Cargill	Bank of America
Included Scope 3 categories	Not found	Not found	Not found
Category emissions split	Not found	Not found	Not found
Data source mix	Not found	Not found	Not found
Estimation approach	Partial	Partial	Partial
Reporting year window	Not found	Not found	Not found
Scope 3 total emissions	Not found	Not found	Partial

Full evidence map with quotes and page numbers →

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Framework references

Relevant California requirements and related disclosures

California

SB253-SCOPE-3

within California SB 253: Climate Corporate Data Accountability Act

Open official source →

Related & explore

Reporting entity applicability →Third-party assurance → Card GHG Protocol methodology and reporting basis → Card Public disclosure, reporting organization, and fees →Reporting timeline and filing status → Card Browse all disclosures →

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FAQ

Questions this page answers

For SB253-SCOPE-3, what data do I need to gather before I start drafting the disclosure?+

How do I work out which Scope 3 categories to include in the SB253-SCOPE-3 disclosure?+

What should I record about the data sources and estimation approach for SB253-SCOPE-3?+

How do I assign ownership for SB253-SCOPE-3 data collection across ESG, HR and data owners?+

What evidence should I keep ready for assurance on SB253-SCOPE-3?+

What are the six assurance claims on the SB253-SCOPE-3 page and how do I use them?+

What are the common reporting gaps or mistakes on the SB253-SCOPE-3 page?+

How can I use the Prep & Assurance workbook for SB253-SCOPE-3?+

How do I turn the SB253-SCOPE-3 data into a draft disclosure?+

Can I use the SB253-SCOPE-3 page to compare my data with ESRS E1 climate reporting?+

	Report A	Report B	Report C
Datapoint 1	✓ p.213	unclear	✓ p.87
Datapoint 2	✓ p.214	—	✓ p.90

Scope 3 greenhouse gas emissions

What to collect before drafting

Included Scope 3 categories

Category emissions split

Data source mix

Estimation approach

Reporting year window