Energy and GHG Disclosures Under the EU Voluntary Standard: Scope 1, Scope 2 and Evidence

A controlled calculation guide for energy, gross Scope 1 and location-based Scope 2

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Energy consumption and GHG emissions are related, but they are not the same dataset. Energy records must first be brought into a consistent unit and reporting boundary. The GHG calculation then applies emission factors to the relevant activity data. Supplier renewable claims, certificates, carbon credits and operational reductions sit around that calculation; they should not be allowed to change the required metric silently.

The practical risk is not only a wrong total. A report can be internally inconsistent when its total MWh excludes landlord-paid electricity, its Scope 1 includes vehicles outside the reporting entity, its Scope 2 uses supplier-specific factors but is labelled location-based, or its “gross” total is net of offsets.

Paragraph 32 requires total energy consumption in MWh. If the undertaking can obtain the information needed for a breakdown, it also reports renewable and non-renewable energy for electricity, as reflected in utility billings, and for fuels. The wording recognises that the split may not always be obtainable, but the total energy figure remains the starting point for undertakings above the 10-employee relief threshold.

Paragraph 33 requires estimated absolute gross emissions during the reporting period in tCO2e: Scope 1 from owned or controlled sources, and location-based Scope 2 from the generation of purchased electricity, heat, steam or cooling. The undertaking is directed to consider the GHG Protocol Corporate Accounting and Reporting Standard (2004).

Before collecting figures, list every energy stream and the route by which it enters the undertaking. The inventory should cover direct purchases, energy paid by landlords or shared-service arrangements, on-site generation, company vehicles, mobile combustion, stationary combustion and fuels held or consumed at sites. This is a completeness exercise, not yet an emissions calculation.

The energy register should retain the original quantity and unit, then convert it to MWh. A basic formula is: energy in MWh = source quantity × approved conversion factor. For electricity already billed in kWh, divide by 1,000. Fuels may require density, net calorific value or other conversions depending on the source unit and factor set.

Keep the original invoice quantity and unit; do not overwrite it with the converted value.

Store factor name, value, unit basis, geography, period, version, source and approver.

Use a factor that matches the activity unit - for example, litres, tonnes, kWh gross or kWh net.

Reconcile the total cost or quantity to finance, procurement or supplier summaries where possible.

Separate energy consumed from energy exported, sold or generated but not consumed by the undertaking.

The B3 table asks for a renewable/non-renewable split where the necessary information can be obtained. The evidence may differ by energy stream. A utility bill or supplier statement may identify the product or source mix; a fuel specification may classify biomass or fossil fuel; an on-site generation meter may support renewable electricity consumed. The team should document the classification rule and avoid converting a broad supplier claim into a precise percentage without evidence.

Scope 1 covers direct emissions from sources owned or controlled by the undertaking. A practical source map normally includes stationary combustion, mobile combustion, process emissions and fugitive emissions. The inventory should distinguish activity data from assumptions and should not infer emissions merely from the maximum capacity of equipment.

The general calculation is activity data × emission factor × any required unit or GWP conversion. The result should be absolute gross tCO2e. Report reductions, avoided emissions or offsets separately rather than netting them against the inventory.

Location-based Scope 2 represents emissions based on the average emissions intensity of the grids or locations where energy consumption occurs. For electricity, the calculation typically multiplies consumption by an appropriate grid-average factor. Heat, steam and cooling require a factor aligned to the supplied energy and geography.

Map each site to the correct country, region or grid factor.

Use the factor period and version most appropriate to the reporting year and explain any lag.

Apply the factor to purchased energy consumed, after controlling self-generation and exports.

Do not label supplier-specific or certificate-based results as location-based.

If supplementary market-based Scope 2 is provided, present both methods clearly and explain the contractual instruments used.

Figure 1. B3 data lineage separates source records, the energy register, Scope 1, location-based Scope 2 and the control layer.

“Gross” is a critical word in paragraph 33. The Scope 1 and Scope 2 totals should represent the emissions arising from the inventory boundary before compensation through carbon credits or offsets. Likewise, a renewable procurement claim should not be expressed as though it physically eliminated grid emissions in the location-based calculation.

A missing invoice creates measurement uncertainty, not an automatic exclusion. The reporting team should apply a source hierarchy that uses the most direct available evidence. The exact hierarchy will depend on the site, but it should be approved and repeatable.

Figure 2. A missing invoice is addressed through a controlled evidence hierarchy, estimate record and later true-up.

The company reports 2,200 MWh of electricity and the converted fuel energy in its total energy consumption. It classifies only the portion of energy for which the renewable evidence test is met; the remainder is non-renewable or unclassified with an explanation, depending on the approved method. It calculates location-based Scope 2 on all purchased electricity using grid-average factors. The incomplete contractual evidence is not used to reduce that total.

The December estimate is recorded with method, source, uncertainty, owner and expected invoice date. When the invoice arrives, the team replaces the estimate, checks whether the difference is material and updates comparative or correction records consistently.

Evidence needed: boundary map, energy register, invoices and meter records, conversion-factor register, Scope 1 source calculations, grid-factor register, estimate log, renewable-evidence record, reconciliation and review sign-off.

1. Reporting energy cost instead of energy consumption. Currency does not substitute for MWh. Obtain quantities or apply a controlled conversion only where defensible.

2. Leaving leased sites out because the landlord pays. Test the reporting boundary and obtain landlord or meter evidence.

3. Using certificates to set location-based Scope 2 to zero. Location-based accounting uses grid/location factors; contractual instruments belong to separate market-based information.

4. Subtracting offsets from gross emissions. Keep offsets outside the gross Scope 1 and Scope 2 totals.

5. Mixing factor units. Check whether factors are per kWh, MWh, litre, tonne, gross calorific value or net calorific value.

6. Silently carrying forward prior-year data. Label estimates, explain method and true up when better information becomes available.

7. Ignoring factor versions and geography. A result is not reproducible without source, year, location and version.