Disclosure focus
This disclosure asks an organisation to explain the greenhouse gas accounting approach it uses and the basis on which it prepares its emissions figures. In practice, that means being clear about the framework, boundaries and assumptions behind the numbers so a reader can understand what is included, what is left out, and how the reported totals were built.
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.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show SB253-METHODOLOGY sub-elements (LRA working checklist)
State whether your greenhouse-gas reporting follows the GHG Protocol guidance and standards.
Name the GHG Protocol corporate emissions accounting and reporting framework you applied.
Name the GHG Protocol value-chain emissions framework you applied for Scope 3.
Explain any changes in method compared with the previous report.
Describe how you set the operational boundary for the inventory.
Describe how you set the organisational boundary for the inventory.
Identify the prior reporting year or the base year you used.
How to prepare it
1Set the reporting year first, and note the earlier year or base year you will compare against. Keep that reference point consistent across the rest of the calculation pack.
2Choose and record the company boundary approach you used, then separately set out the method for the parts of the business you include in the emissions inventory. Make sure both choices are clear enough for someone else to follow.
3Confirm which GHG Protocol materials you relied on for the main inventory and, where relevant, for value-chain emissions. Keep evidence that shows the selected framework was actually used, not just intended.
4Gather the source records and working papers that support the figures or narrative you will report. This should let a reviewer trace the numbers back to the underlying evidence.
5Explain any changes from the previous report, including shifts in method, boundary approach, or other calculation choices. If something was left out or treated differently, describe that clearly so the comparison remains understandable.
6Check the final disclosure against the official source before filing, to confirm the selected year, methods, framework use, and any changes are all captured consistently and without gaps.
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.
Industry examples
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]
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Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
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.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner for the evidence
The 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 collection
People 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 basis
The 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 basis
Inputs 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 out
Original file names, system tags, or extract notes are removed during handling, leaving no way to show where each figure came from.
Separate populations are merged
Data 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 missing
The 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 trail
The 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.
Where judgement is often needed
Set the opening year and keep it consistent
Choose 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 covered
If 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 boundary
Set 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 included
Describe 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 data
Where 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 estimated
State 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 period
If 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 populations
Explain 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 masking
If 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 conventions
State 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
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
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.
Illustrative (synthetic) example — Retail
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.
How companies report SB253-METHODOLOGY in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Ingersoll Rand Inc.
Electrical Equipment and Machinery · United States · 2024
Ingersoll Rand’s 2024 Sustainability Report references use of the GHG Protocol Corporate Accounting and Reporting Standard (p.26) and the Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (p.32) for its emissions accounting. The report provides Scope 3 emissions data for 2020–2024 with specific metric ton CO2e values and targets (p.32), and notes progress towards Scopes 1 and 2 reduction goals (p.74). However, the report does not clearly disclose the base year or prior year methodology, nor does it provide explicit details on organizational or operational boundary methods or any methodology changes.
Bank of America
None · United States · 2025
Bank of America's 2025 sustainability report provides GHG emissions data with a baseline year of 2010, showing Scope 1 direct emissions figures for subsequent years (p.20). The report states that the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard was used to calculate Scopes 1, 2, and 3 emissions (p.18). However, the report lacks clear information on conformance with the GHG protocol, details on the operational and organizational boundary methods, and the specific standard used for Scope 3 emissions, while methodology changes are only partially described (p.3).
C.H. Robinson
Air Freight Transportation and Logistics · United States · 2025
C.H. Robinson’s 2025 Sustainability Report provides specific data on greenhouse gas emissions, including direct emissions from stationary and mobile combustion sources (p.20) and detailed figures for Scope 3 emissions, with totals reported for multiple years (p.62). The report includes updated 2024 emissions data, indicating ongoing tracking and revision of GHG figures (p.62). However, the report lacks clear information on the methodology used for emissions accounting, such as the corporate standards applied, base year selection, GHG protocol conformance, and boundary definitions, as no quotable evidence was found for these aspects.
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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.
QHow should the preparer decide what period to name as the comparison basis, and what should they do if the current method differs from the earlier filing?
Reveal model answer →Hide answer ↑They should identify the prior fiscal year or another chosen base year clearly, then explain any change in approach from the earlier report in plain terms. If the merger changed how the group is put together for reporting, the explanation should make that shift understandable rather than leaving the reader to infer it.
Why this matters · State the comparison year clearly and explain any change in approach so users can follow the trend line.
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.”
QWhat should the preparer check before sign-off, and how should the method be described in the disclosure?
Reveal model answer →Hide answer ↑They should confirm that the reporting basis is the GHG Protocol corporate accounting and reporting framework, not just an internal calculation tool. The disclosure should say the group used that corporate-level framework and, if relevant, note any practical adjustments in wording that do not change the underlying basis.
Why this matters · Use a recognised corporate emissions framework and describe it in a way that matches the actual reporting basis.
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.
QWhat should the preparer do about the boundary method and the change from the previous report?
Reveal model answer →Hide answer ↑They should name the organisational boundary approach actually used this year and explain that it differs from the prior report if that is the case. The explanation should be enough for a reader to understand that the year-on-year figures may not be directly comparable without that context.
Why this matters · Be explicit about the group boundary approach and flag any switch from the earlier reporting basis.
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.
QWhat judgement should the preparer make before finalising the filing?
Reveal model answer →Hide answer ↑They should check whether the value-chain emissions work was prepared using the GHG Protocol Scope 3 framework and whether the overall reporting follows the same recognised guidance consistently. If it does, that should be stated plainly; if not, the team should not imply that it does.
Why this matters · For value-chain emissions, confirm the framework used and avoid overstating consistency with recognised guidance.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
California
SB253-METHODOLOGY
within California SB 253: Climate Corporate Data Accountability Act
Open official source →Related & explore
FAQ
Questions this page answers
For SB253-METHODOLOGY, what data points do I need to gather before I start drafting the disclosure?+−
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.
How do I use the SB253-METHODOLOGY step-by-step preparation section in practice?+−
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.
What should I check for the corporate accounting standard and protocol alignment in SB253-METHODOLOGY?+−
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.
How do I decide the operational boundary and group boundary method for SB253-METHODOLOGY?+−
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.
What does the SB253-METHODOLOGY page expect me to do if my method changed from the prior year?+−
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.
What evidence pack do I need for SB253-METHODOLOGY assurance readiness?+−
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.
What are the six assurance claims to verify on the SB253-METHODOLOGY page?+−
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.
How can I avoid the common reporting gaps and mistakes on SB253-METHODOLOGY?+−
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.
How do I turn the SB253-METHODOLOGY page into a draft disclosure?+−
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.
How should I use the SB253-METHODOLOGY workbook and printable library card?+−
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.
Can I reuse SB253-METHODOLOGY data for ESRS E1 (Climate Change)?+−
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
SB253-METHODOLOGY checklist for reference year, accounting standard, boundary and Scope 3 frameworkHow to document method changes for SB253-METHODOLOGY disclosureWhat evidence should I keep for SB253-METHODOLOGY assurance readiness?SB253-METHODOLOGY common mistakes and reporting gaps to avoidHow to use the SB253-METHODOLOGY Prep & Assurance workbookSB253-METHODOLOGY draft disclosure narrative starters and content index lineSB253-METHODOLOGY synthetic example disclosure table how to read itWhere is the closest ESRS correspondence for SB253-METHODOLOGY?How do I assign ownership for SB253-METHODOLOGY data collection and review?What should an assurance reviewer look for in the SB253-METHODOLOGY evidence pack?How do I prepare SB253-METHODOLOGY if I am the HR or data owner?What is included in the SB253-METHODOLOGY from company reports table?
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