Regulations in the U.S. and abroad seek to require companies to publicly disclose climate-related risks on their finances, operations and assets. Some of these rules are proving more durable than others.
Real estate companies do not own or control sources in their supply chains. Thus, they should not be mandated to publicly report Scope 3 emissions and they should be voluntary if a company chooses to make them.
For example, real estate owners and developers do not control operations in tenant spaces. Nor do they control manufacturing processes for construction materials. Accordingly, owners and developers should be under no mandate to quantify and report Scope 3 tenant-based emissions, or embodied emissions that occur in factories during product manufacturing.
Policymakers can encourage voluntary Scope 3 reporting by helping building owners and developers capture valid and reliable data from supply chain sources. For example, governments should develop policies for utilities to provide building owners with tenant space energy data. Similarly, government agencies should create a uniform system of “product declarations” for manufacturers to disclose embodied carbon in materials purchased by developers and owners.
Any reporting cycles should be consistent across varying disclosure regimes, based on when companies collect and verify valid climate-related data within a fiscal year. No framework should require companies to issue a first report based largely on estimates, and then another report later based on collected and verified data, within the same fiscal year.