C3 Climate Targets and Scope 3: When Quantification Is Appropriate

Technical status note. The Commission adopted C(2026) 5011 final on 3 July 2026. As at 1 August 2026, the delegated act was under European Parliament and Council scrutiny and had not yet completed the process leading to application. Recheck the Official Journal version, entry into force and any corrections before publication or client use.

Use note. This material separates requirements in the 2026 Voluntary Standard from London Reporting Academy implementation practices and illustrative wording. It does not replace the official text, legal analysis or entity-specific review.

Scope 3 is often the largest and least mature part of a greenhouse-gas inventory. A company can therefore make two opposite errors: delaying all disclosure until supplier-perfect data exist, or publishing a precise-looking total assembled from untested assumptions. C3 supports a more proportionate route. The undertaking screens its value chain, identifies significant categories, develops reasonable estimates, discloses limitations and improves the dataset over time.

Targets create a separate claim risk. A public aspiration can be commercially important, but it is not automatically a measurable target. Calling it a target without a boundary, base year, target value or approved actions can mislead users and make future performance impossible to evaluate.

Where appropriate, the undertaking discloses Scope 3 greenhouse-gas emissions together with the B3 greenhouse-gas information.

The undertaking refers to the 15 Scope 3 categories in the GHG Protocol Corporate Value Chain (Scope 3) Standard and includes significant categories based on its own assessment.

The Standard notes that Scope 3 is likely to be significant for activities such as manufacturing, agrifood, real-estate construction and packaging.

Where greenhouse-gas reduction targets have been established, the undertaking discloses absolute Scope 1 and Scope 2 targets and, if a Scope 3 target has been set, significant Scope 3 targets.

For each disclosed target, the undertaking reports the target year and target value, the base year and base-year value, units, the share of Scope 1, Scope 2 and Scope 3 covered, and the main actions planned to achieve the target.

A quantified value for every one of the 15 categories irrespective of significance.

Perfect supplier-specific primary data before any reasonable Scope 3 estimate can be reported.

A net-zero commitment, science-based-target validation or third-party assurance as a condition of using C3.

The relabelling of an aspiration, policy objective or proposed initiative as an established target.

The deduction of offsets, removals or avoided emissions from the gross inventory before the gross figure is visible.

A universal decarbonisation pathway or transition plan where the undertaking has not established one.

Figure 1. Scope 3 should move through screening, significance, data-quality and target-evidence gates. Illustrative implementation model.

Implementation note. The screen is an evidence-led prioritisation exercise, not a request to declare every missing category “not applicable”. Record why a category is excluded, what data were available and when the conclusion will be revisited.

The category has been screened as significant or is needed to explain a target boundary.

The organisational, value-chain and reporting-period boundaries are defined.

The activity data, factor and calculation method are suitable enough to produce a reasonable estimate.

Double-counting and category allocation have been considered.

The principal assumptions, exclusions and uncertainty can be explained without creating false precision.

A named owner can retain source evidence and a reviewer can reproduce the calculation.

Where those conditions are not met, a qualitative significance statement plus a time-bound data-improvement plan is more credible than a fabricated or unexplained figure. The improvement plan should identify the missing input, owner, planned method and next reassessment date.

Figure 2. An ambition can be reported honestly, but it should not be presented as an established C3 target until the target evidence exists.

The 2026 Standard defines gross greenhouse-gas emissions as emissions before deductions from offsets or carbon credits. Compatible official implementation guidance also recommends separating removals, avoided emissions and offsets from the inventory. This distinction prevents a user from mistaking credit purchases for operational or value-chain emissions reduction.

Calculation note. Percentage reduction = (base-year value - target-year value) ÷ base-year value × 100. For Scope 1 and 2: (2,000 - 1,200) ÷ 2,000 × 100 = 40.0%. For significant Scope 3: (8,600 - 7,000) ÷ 8,600 × 100 = 18.6%.

Why the wording is useful

It identifies the significant categories rather than reporting an unexplained total.

It states method, primary-data coverage and a material data gap.

It provides base and target values, years, scopes and main actions.

It distinguishes the established 2030 targets from the unquantified 2050 ambition.

It avoids implying that the illustrative figures are exact or independently assured.

Evidence required

Does C3 require a total Scope 3 number?

C3 asks the undertaking to include significant Scope 3 categories based on its own assessment and present the information with B3. A total can be useful where category coverage and aggregation are clear, but it should not replace the category breakdown and significance rationale.

Can a spend-based estimate be reported?

It can be used where it produces a reasonable estimate and its limitations are transparent. For a significant category, teams should normally plan a progression towards better activity or supplier-specific data where that would materially improve the result.

Is a 2050 net-zero commitment automatically a C3 target?

No. The claim must be tested against the C3 target fields and the undertaking's evidence. Without a controlled base, target value, boundary, scope coverage and actions, it is more accurately described as an ambition or strategic direction.

Should market-based Scope 2 be used in the target?

The target boundary and metric must be defined consistently with the underlying B3 disclosure and methodology. The article does not prescribe a market-based target; disclose the selected basis clearly and avoid switching bases without explanation.