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Interview: Scope 3 as a disclosure standard by ISSB

We talked to Sophie Kieselbach, Senior Implementation Engineer for Sustainability at Makersite, about the implications of the new ISSB requirements.

In 2021 the International Financial Reporting Standards Foundation (IFRS) announced the creation of the International Sustainability Standards Board (ISSB). The ISSB was then tasked with developing mandatory corporate ESG disclosures. The goal is to find a global baseline of sustainability disclosure standards by the end of 2022. The intention behind it is to standardize sustainability disclosures for investors. 

In October 2022, the IFRS Foundation stated that it had made significant progress on its draft requirements. The ISSB agreed that companies should disclose Scope 1, 2, and 3 emissions but will potentially have more time to report on Scope 3 disclosures and be supplied with “relief provisions” to help work out these disclosures. 

A mandatory Scope 3 disclosure is challenging for many companies. While Scope 1 and 2 emissions are company-owned and relatively easy to report, Scope 3 emissions occur upstream and downstream and are challenging to report on and even harder to improve. We talked to Sophie Kieselbach, Senior Implementation Engineer for Sustainability at Makersite, about the implications of the new requirements.  

How do you feel about the ISSB including Scope 3 into a global baseline for disclosure standards? 

I am happy that the ISSB includes Scope 3 reporting into their baseline for disclosure. Up to 90% of emissions are Scope 3 emissions. Any other decision would have been a drawback to GHG reporting and would not have given enough insights to investors to base investments. 


What companies will have to comply? 

The IFRS Foundation Trustees are committed to the International Sustainability Standards Board (ISSB) building on the work of existing investor-focused reporting initiatives—and ultimately becoming the global standard-setter for capital market sustainability disclosures. This effort includes further developing the Integrated Reporting Framework, which the International Accounting Standards Board (IASB) and the ISSB assumed responsibility for when the Value Reporting Foundation merged with the IFRS Foundation in August 2022. An integrated report is concise communication about an organization’s strategy, governance, performance, and prospects. Right now, the IRFS refers to the GHG reporting standard, so this is the first source to understand what to comply with (Standards | Greenhouse Gas Protocol (


In your opinion, how will the trend toward Scope 3 reporting continue? 

I find the word “trend” a bit unlucky as it implies that tracking and reporting on your Carbon footprint are only necessary now but might get less critical in the future. Companies must understand that it is not just an annoying task to tick off your checklist but a tool to optimize your products along the supply chain, which always comes with other, also financial benefits.  

I hope that with IFRS including it in the financial reporting standards, it gets once more the recognition it should get: Scope 3 reporting is a necessary tool to see if your company is future-proof and worth investing in.  


Are there companies that are already one step ahead? 

Yes. Several companies worldwide have employed sustainability teams for years and had the time to crunch their data and work on their goals. It isn’t easy to catch up with them, as they have already implemented knowledge and internal structures to comply with their plans. Companies still tend to underestimate the efforts behind a solid sustainability/GHG strategy. Nevertheless, it is never too late to join the party. 


And is it too late to be one of these companies? 

No, of course not. The good news is that the market to support you is growing, and getting the right help is easier and easier.  

Still, I cannot suggest pushing that task further down the timeline. It will be a standard task in your reporting, similar to reporting profit- and loss statements.  


How do you start reporting on Scope 3 emissions? 

  1. As already stated, the  GHG protocol is referred to by the IFRS, so this is the best start to understanding what should be reported.  
  2. I would always recommend asking for help to speed up the process: there are many consultants in the market with experience you can learn from 
  3. Crunching these numbers within Excel files is very old-school (and also slow, error-prone and horrible to update). To support reporting, I would always recommend using software applications to help make this task easier. 


What does this mean for suppliers? 

Questions about carbon footprint or, more generally, social, economic, and environmental impacts of products will increase.  

One can only advise that – if not already done – companies start now to get to know their product portfolio and to be able to provide these figures and set up their roadmap. It is a fact that if these figures cannot be provided and it cannot be credibly presented how they will be improved over time, companies will be at a competitive disadvantage.  


What are the seen and unseen benefits of reporting Scope 3 

There is a clear competitive advantage if one knows the numbers. 

Also, as soon as one starts digging deeper into the supply chain, it enables optimizations and is financially beneficial. Another benefit – most companies haven’t looked at their data in the way it is necessary for Greenhouse Gas reporting, so a company will likely gain new insights into their mechanisms.  


Any thoughts on the relief provisions? 

I hope these relief provisions will not lead to another delay in reporting Scope 3. Even though I understand the struggles with GHG reporting, the advantages outweigh the disadvantages. And as I said – one might be surprised by what insights can be gained. Wouldn’t you be curious about your impacts and the subsequent potential to perform better? 

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