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How Can Businesses Prepare for Scope 3 Emissions Regulatory Reporting Requirements?

How Can Businesses Prepare for Scope 3 Emissions Regulatory Reporting Requirements?
How Can Businesses Prepare for Scope 3 Emissions Regulatory Reporting Requirements?
Written by:
Caroline Chen
Written by:
Trace Insights
Publish Date:
Feb 2026
Topic Tag:
Sustainability

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Scope 3 Emissions Reporting Guide for Australian Businesses

Written by Caroline Chen, Consultant, co authored by Emma Woodberry, Senior Manager and Sustainability Lead.

Scope 3 comes into the spotlight

Most businesses are familiar with their Scope 1 (direct) and Scope 2 (indirect from purchased energy) emissions. Scope 3 emissions, however, are often less understood – despite typically making up the largest share of an organisation’s total carbon footprint.  

Scope 3 emissions capture greenhouse gases that occur indirectly across an organisation’s entire value chain, both upstream and downstream. This includes emissions from purchased goods and services, transportation, waste, business travel, product use and end-of-life treatment.

Historically, Scope 3 reporting in Australia has been voluntary, meaning these emissions often flew under the radar when assessing sustainability performance. That has changed now with Australia’s Climate-related Financial Disclosure (CRFD) regime, which came into effect on 1 January 2025, requiring entities who meet the threshold to include climate-related disclosures in their annual financial reports lodged with ASIC – and this includes Scope 3 emissions.

Australia’s phased Scope 3 reporting schedule for AASB S2 Climate-Related Disclosures

Source: Who must prepare a sustainability report? | ASIC

Why Scope 3 is different – and why preparation and action matters

Scope 3 emissions are widely recognised as the most complex to measure. Challenges include:

  • Reliance on data from suppliers and customers across complex value chains
  • Use of estimates, proxies, and industry averages rather than direct measurement
  • Coordination across procurement, finance, operations, and sustainability teams
  • Resource and capability constraints, particularly in early years

Hence, preparation is pivotal for accurate reporting. Although early Scope 3 disclosures may require only limited assurance, reasonable assurance will be expected in later phases. Methodologies, assumptions, and governance decisions made now will form the baseline auditors rely on in future years. Reporting should therefore be viewed as a long-term capability, not a one-off exercise.

Investing early in repeatable, finance-grade processes enables traceable, defensible, and scalable systems. This sets the foundation for long-term success by:

  • Reducing compliance and assurance costs
  • Avoiding reputational and regulatory consequences
  • Strengthening supplier relationships
  • Building credible, investor-ready disclosures
  • Turning sustainability into a strategic advantage

Smaller businesses who sit outside ASIC reporting thresholds will be affected, as they often form part of the supply chains of large reporting entities. Scope 3 data requests should be expected, making early engagement essential regardless of size.

How businesses can prepare for Scope 3 reporting

Regulators recognise that early reporting will rely on estimates and industry averages. Establishing robust methodologies now ensures these estimates are defensible and improvable over time. A practical preparation approach can be broken into five phases:

Phase 1: Regulatory exposure and reporting boundaries

Clarity before data
  • What parts of our organisation and group entities are required to be included in reporting?
  • What consolidation approach applies (equity share, control, financial consolidation)?
  • Which Scope 3 categories are material for us and therefore in scope?
  • What assumptions, exclusions and methodological choices are we making, and are they documented?

Phase 2: Governance and accountability

Who owns Scope 3, and how is it controlled?
  • Who is accountable at executive and board level for Scope 3 reporting?
  • Who owns the data for each major emissions source (procurement, logistics, travel, etc.)?
  • How do finance and sustainability teams work together to reconcile emissions to spend and activity data?
  • What internal controls exist for review, approval and change management?

Phase 3: Data foundation and methodologies

Is our data defensible, traceable and repeatable?
  • What data do we already have, and where does it live?
  • Where can we use activity-based data versus spend-based estimates?
  • Which emission factors are we using, and are they credible, current and documented?
  • How confident is our data, and can we demonstrate year-on-year improvement?
  • Can every number be traced back to a source system or assumption?

Phase 4: Value chain coverage and supplier engagement

Are we focusing effort where it matters most?
  • What does our upstream and downstream value chain look like?
  • Which suppliers and activities drive the majority of Scope 3 emissions?
  • How are we engaging priority suppliers to collect data in a consistent way?
  • How are emissions expectations reflected in procurement processes and contracts?
  • What is our plan to improve supplier data quality over time?

Phase 5: Assurance readiness and strategic integration

Is Scope 3 embedded, not bolted on?
  • Are we ready for internal review or external assurance of Scope 3 data?
  • How are Scope 3 risks reflected in enterprise risk management and climate scenarios?
  • How do emissions insights influence strategy, capital allocation and supplier decisions?
  • Do we have an established reporting rhythm and improvement roadmap, rather than an annual exercise?

Turning Scope 3 Preparedness into Strategic Value

Building robust Scope 3 tracking systems is not just about preparing for future reporting requirements – it is the critical first step to achieving real emissions reduction and business impact. By investing early in high-quality data, governance, and supplier engagement, organisations create the foundation needed to actively manage and reduce Scope 3 emissions, rather than simply report on them.

This groundwork unlocks far more than compliance. It enables meaningful emissions reduction through smarter supplier selection and contract optimisation, product and material redesign, logistics and transport efficiency, energy and electrification strategies, and more informed capital investment decisions.

In parallel, these capabilities drive wider strategic benefits. Improved visibility across procurement, logistics, and product design strengthens strategic decision-making, supporting smarter, lower-risk choices. Transparent, credible disclosures enhance reputation and competitiveness, building trust with investors, customers, and employees. At the same time, value-chain insight fuels efficiency and innovation, highlighting opportunities for cost reduction and operational improvement.

Organisations that prepare now can turn Scope 3 tracking into a powerful business capability – transforming emissions management into a lasting competitive advantage.

How Trace can help

Preparing for Scope 3 reporting requires more than spreadsheets and one-off calculations. It demands structured data, governance, and audit-ready processes that evolve over time.

Trace supports organisations by:

  • Translating CRFD requirements into clear, practical actions
  • Identifying material Scope 3 categories and defining defensible boundaries
  • Establishing traceable calculation methodologies aligned to the GHG Protocol
  • Integrating emissions data with procurement, finance and operational systems
  • Supporting supplier engagement and data collection at scale
  • Building documentation and controls that stand up to future assurance
  • Turning emissions insights into strategic and cost-saving opportunities
  • Supporting Sustainability Report development  

We understand complex supply chains, and our deep expertise in operational environments, data analysis, and sustainable solutions can help you on your sustainability journey.

By starting early with the right foundations, businesses can move confidently from compliance to capability – and from disclosure to long-term value creation. Organisations that prepare now will ultimately be more prepared to thrive in the advancing sustainable business area, leveraging this legislation shift as an opportunity.  

Preparing for Scope 3 reporting doesn't have to be overwhelming. Our team understands complex supply chains and can guide you through every phase—from defining boundaries to building assurance-ready systems. Let's talk about how we can support your sustainability goals, contact one of our experts today.

Ready to turn insight into action?

We help organisations transform ideas into measurable results with strategies that work in the real world. Let’s talk about how we can solve your most complex supply chain challenges.

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