Can I measure all of my Scope 3 emissions now?
On This Page (6 sections)
Yes, you can estimate all of your Scope 3 now, even without supplier data. Start with rough, spend-based estimates for every relevant category, then improve the largest ones over time. You do not need perfect data to start, but you must say how you estimated.
Step 1: screen all 15 categories
Make a quick estimate for each of the 15 Scope 3 categories. For purchased goods and capital goods, multiply your spend by an average factor per RM or USD. For travel, freight and waste, use distances, weights and average factors. This shows where most of your Scope 3 sits. Step 3: Set your operational boundaries explains the screening.
Step 2: improve the largest categories
Spend your effort where the emissions are. For your largest suppliers, ask for activity data or their own emissions figures. Replace spend-based estimates with supplier-specific data year by year. Small categories can stay on average data.
What the rules expect
- IFRS S2 asks you to consider all 15 categories and to report those that are material. In the first year, you do not have to report Scope 3. It also asks how much of your Scope 3 uses data from specific activities and from verified sources.
- NSRF transition relief lets Malaysian companies leave out Scope 3 for the first 2 or 3 years, except for the categories that their regulator already requires.
- Bursa Malaysia already asks listed companies for at least business travel and employee commuting.
If it is truly impracticable to estimate Scope 3, IFRS S2 asks you to explain how you manage it instead. This is rare, because estimates are almost always possible.
Common problems
- Double counting between categories. For example, do not count freight in both category 1 (in the product price) and category 4 (as transport).
- Spend-based estimates and price changes. If your spend rises because of inflation, a spend-based estimate rises too, even if nothing physical changed. Note this when you compare years.
- No supplier answers. Use average data and record it. Then ask again with a simple, short form.
In Carbon GPT
Requests sends data collection forms to colleagues and suppliers, who can answer without logging in. It has ready-made forms for business travel, employee commuting, office energy and waste.
Sources
- GHG Protocol Corporate Value Chain (Scope 3) Standard, chapters 6 and 7
- GHG Protocol Technical Guidance for Calculating Scope 3 Emissions
- IFRS S2 Climate-related Disclosures, paragraphs 29(a)(vi), B38–B57 and C4
- Securities Commission Malaysia: National Sustainability Reporting Framework
- Bursa Malaysia: Main Market Listing Requirements

