GHG Protocol Proposes 95% Scope 3 Coverage Rule and New Category 16 in Reporting Standard Update

GHG Protocol has released a March 2026 progress update outlining proposed revisions to its Scope 3 Standard, with some of the most consequential changes focused on reporting completeness, new value-chain boundaries, and stronger data-quality disclosures. The document is not yet a final standard, and GHG Protocol says it is still draft material subject to change, with a full public consultation draft still to come. That matters because GHG Protocol provides the world’s most widely used greenhouse gas accounting standards, so even draft changes can influence how companies, auditors, software providers, and investors prepare for future reporting expectations.

 

The headline proposal is a quantified Scope 3 threshold

 

The most important proposed change is a prescriptive completeness requirement. Under the draft language, companies would need to account for and report at least 95% of total required Scope 3 emissions, while exclusions could not exceed 5% of required Scope 3 emissions. The update also makes clear that the 95% inclusion rule would apply only to required Scope 3 emissions, not optional ones. GHG Protocol says the purpose is to make inventories more complete, consistent, and transparent by setting a standardized and verifiable threshold for exclusions rather than relying on broad disclosure language alone.

 

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Data transparency could become more structured

 

The update also points toward a more granular reporting model. One proposal would require companies to disaggregate Scope 3 emissions by data type for each category, with the goal of improving transparency, comparability, and the ability of users to distinguish between more specific and less specific emissions data. A separate proposal would require companies to state whether their reported Scope 3 data is verified by a third party, using labels such as verified, partially verified, or not verified. In practice, that would push Scope 3 reporting away from a single aggregate disclosure and toward a more layered disclosure structure that shows both data quality and assurance status.

 

Category 16 would expand the standard’s reach

 

Another major proposal is the creation of a new Scope 3 Category 16 for “other value chain activities.” According to the draft, this new category is meant to capture activities that are not clearly covered by the current 15 categories, especially facilitated activities where a company earns transactional income but does not directly buy, sell, or own the underlying activity. The progress update says most Category 16 subcategories would be optional, and it also includes a licensing subcategory so licensors can report emissions associated with activities enabled by their licenses. The draft further indicates that optional Category 16 emissions would be reported separately from required Scope 3 emissions to preserve comparability across inventories.

 

Investment reporting is also being narrowed and clarified

 

The revision package goes beyond the new category. GHG Protocol also proposes clarifying that Category 15 for investments applies to all companies, not only investment managers. At the same time, some activities currently associated with financial services would be moved out of Category 15 and into Category 16. The draft specifically says insurance-associated activities, underwriting, and issuance would be reclassified into optional Category 16 subcategories, while Category 15 would stay more tightly focused on investments proper and financed emissions. That change would make the investment category narrower and more consistent, especially for non-financial companies.

 

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What this means for corporate reporting

 

Taken together, the proposed revisions suggest that Scope 3 reporting is moving toward tighter quantitative boundaries, clearer separation between required and optional emissions, and more explicit disclosure of data quality and verification. If these changes are adopted in a later final standard, companies would likely face greater pressure to improve inventory coverage, document exclusions more carefully, and build reporting systems capable of distinguishing between different data types and boundary treatments. That would increase the operational discipline around Scope 3 accounting, even if it also raises the reporting burden for companies with complex value chains. This is an inference based on the draft proposals set out in the GHG Protocol progress update.

 

Why the update matters now

 

The significance of this release is not that the standard has already changed, but that GHG Protocol has now signaled the direction of travel. The progress update shows that the revision process is focused on completeness, boundary discipline, and usability of reported emissions data, while the public consultation draft is still forthcoming. For companies already preparing for stricter climate disclosure regimes, that makes this update an early indicator of where future Scope 3 expectations may tighten.