Climate change duties: statutory guidance for public bodies

8. Reporting

All public bodies subject to the climate change duties should include climate change and sustainability reporting as part of their annual corporate reporting process.

Over 180 public bodies deemed to be ‘major players’ have a statutory duty under the Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015, as amended, to report annually on their compliance with the climate change duties. These bodies are listed in schedule 1 of the Order.

The Scottish public sector has been playing a crucial part in taking action on climate change for many years. Public bodies contribute to tackling climate change by supporting national and local climate policy, reducing emissions from public sector assets and supply chain, and ensuring public services are resilient. Recording greenhouse gas emissions, and the actions taken to contribute to adaptation and sustainability, allows public bodies to set targets and monitor progress towards achieving them. In order to reduce emissions and work towards net zero and other targets, bodies need to understand how their emissions and other impacts arise, through a combination of environmental and carbon management processes and reporting.

8.1 Public bodies climate change duties reporting

All public bodies subject to the climate change duties are expected, as best practice, to include climate change reporting as part of their annual corporate reporting process, in terms of mitigation (carbon emissions reductions), adaptation and sustainability.

Mandatory reporting on compliance with the climate change duties was introduced for the ‘major players’ within the public sector by the Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015 (‘the 2015 Order’), as amended. Bodies subject to mandatory reporting are listed in schedule 1 of the Order.

Using reports and information gathered from local authorities, from 2026-27 onwards, ESS will scrutinise their compliance with statutory climate change duties and delivery of climate activity.

Bodies not subject to mandatory climate change duties reporting are encouraged to adopt the principles outlined below as best practice.

8.2 The reporting duty

This section explains the mandatory public bodies climate change duties (PBCCD) reporting duty (‘the reporting duty’), which bodies are covered by it, and contains guidance to help public bodies understand and meet the duty. While the guidance is primarily addressed to the public bodies subject to the reporting duty, it is intended to be useful to all public bodies.

The reporting duty requires annual reports to be submitted using the standard Scottish Government reporting template. Detailed practical guidance on public bodies climate change reporting, completing the template and supporting resources are available on the Sustainable Scotland Network (SSN) website.

Annex H provides further guidance and information on boundary setting, conversion factors, reporting in shared public buildings, reporting on outsourced services, common sources of scope 3 data and guidance on expanding reporting of scope 3 beyond the best practice minimum.

8.2.1 Background and legislation

Provision for reporting on climate change duties was introduced by section 46 of the Climate Change (Scotland) Act 2009. Subsection 46(1)(a) states that Scottish Ministers may, by order, require relevant public bodies to prepare reports on compliance with the climate change duties. The order may set out the information to be included in the reports, the form and manner of the reports, and the reporting period.

Mandatory reporting for relevant public bodies using the power under section 46 of the 2009 Act was introduced by the Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015, which came into force on 23 November 2015. It has required over 180 listed public bodies to report annually on compliance with their climate change duties since 2015.

• Schedule 1 of the 2015 Order lists all public bodies who have a mandatory requirement to report.
• Schedule 2 includes the questions public bodies are required to answer as part of their report, such as details of their carbon emissions, and questions on mitigation, adaptation and procurement.

Since becoming a statutory requirement in 2015, Scotland’s reporting duty has been credited with driving climate action and delivering robust measurement of public bodies’ scope 1 and scope 2 emissions. Reports provide valuable detail to share on emissions reductions efforts by public bodies and in more recent years reports provide increased detail on scope 3 emissions. There is a strong demand among the public sector for robust, consistent and comprehensive measurement and reporting of the entire carbon footprint of public bodies. Mandatory reporting also helps to improve the transparency, consistency and quality of reporting, and increases collaborative working between public bodies.

Following public consultation in 2019, the Scottish Government strengthened the legislative framework for the reporting duty. The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Amendment Order 2020 amended the 2015 Order and from November 2022, relevant public bodies have been required to provide in their annual climate change duties reports:

• where applicable, the body’s target date for achieving zero direct emissions of greenhouse gases, or such other targets that demonstrate how the body is contributing to Scotland achieving its emissions reduction targets
• where applicable, targets for reducing indirect emissions of greenhouse gases
• how the body will align its spending plans and use of resources to contribute to reducing emissions and delivering its emissions reduction targets
• how the body will publish, or otherwise make available, its progress to achieving its emissions reduction targets
• where applicable, what contribution the body has made to helping deliver the National Adaptation Plan.

8.2.2 Reporting on scope 1, 2 and 3 emissions

All public bodies have a direct impact on emissions through the way they carry out their functions, including how they manage their estates and staff. To date, emissions reporting by public bodies has focused primarily on direct scope 1 and indirect scope 2 emissions: from the heating and power used in buildings, and on the emissions from fleet vehicles. Many bodies also include indirect scope 3 emissions such as those from waste, business travel and staff commuting.

For most public bodies, indirect emissions from the wider value chain will be where their greatest climate impact lies – noting that such emissions are outside the direct control of the body but can be influenced by it. It is estimated that typically over 90% of an organisation’s emissions fall under scope 3;^[30] and that the emissions from purchased goods and services could make up over 70-80% of a local authority’s overall carbon footprint.^[31]

It is important, moving forwards, that while bodies continue to focus efforts on reducing their scope 1 and 2 emissions, they also start to measure, monitor and reduce scope 3 emissions from the wider value chain. Where relevant, bodies should also report on progress of significant land-based mitigation and adaptation projects.

Reporting in line with the Greenhouse Gas Protocol

Reporting data on scope 1 and 2 emissions has improved and become more established since mandatory reporting began. The Greenhouse Gas (GHG) Protocol defines direct and indirect emissions as follows:

• direct GHG emissions (scope 1) are emissions from sources that are owned or controlled by the reporting entity, e.g. emissions from heating buildings with gas or oil, or from petrol or diesel fleet vehicles
• indirect GHG emissions are emissions that are a consequence of the activities of the reporting body, but occur at sources owned or controlled by another entity. They include emissions from purchased electricity, heat, steam or cooling (scope 2) and all other indirect emissions from the wider value chain (scope 3) such as those associated with procurement, business travel and waste.

Public bodies should align their carbon accounting methodology with the GHG Protocol. As set out in the Corporate Accounting and Reporting Standard, GHG accounting and reporting should follow five key principles:

• relevance – the inventory should appropriately reflect the emissions of the organisation
• completeness – all emission sources and activities within the chosen inventory boundary should be accounted and reported on, with any specific exclusions disclosed and explained
• consistency – use of consistent methodologies should allow meaningful analysis of emissions over time
• transparency – assumptions made and methodologies and data sources used should be clearly stated, producing a clear audit trail
• accuracy – estimation of emissions should be systematically neither under or over actual emissions, as far as can be judged, and uncertainties should be reduced as far as is practicable.

8.2.3 Scope 1 reporting

All relevant scope 1 emissions must be reported and are likely to include energy and fuel use in buildings and vehicles. Fugitive gases, such as leaks of refrigerants from cooling systems and heat pumps, should also be included as good practice.

Some public bodies may have specific fugitive emissions, for example anaesthetic gases in the health sector, that should be scoped and reported as they typically have a higher Global Warming Potential (GWP) and so may make a significant contribution to the footprint. A small number of public bodies may generate process emissions and effort should also be made to include these, where material.

Public bodies should refer to the GHG Protocol for guidance on the calculation of scope 1 emissions.

Over time, as bodies work to decarbonise their fleet and estate, emissions from fossil fuels will decrease, and the relative contribution made by sources such as fugitive gases may increase. It is therefore important that bodies undertake regular reviews of their GHG inventory, to ensure that their reports continue to be relevant and complete.

8.2.4 Scope 2 reporting

Scope 2 emissions must be reported on and include those from acquired electricity, heat, steam and cooling. For most public bodies, scope 2 emissions are likely to come primarily from mains electricity, but may also include heat and steam purchased from district heating networks.

When reporting on scope 2 emissions from the purchase of electricity, bodies should follow the location-based method and use the emission factor for standard UK grid electricity. REGOs (Renewable Energy Guarantee of Origin certificates) are not considered to be truly additional in relation to UK grid electricity. Any REGO certified electricity purchased should be reported, in terms of emissions, as grid standard. Any future change to this position will be communicated through the practical reporting guidance which supports the annual PBCCD reporting regime.

An exception to this may occur where a body purchases electricity via a Power Purchase Agreement (PPA). 100% renewably-generated electricity covered by the PPA may be reported as zero emissions.

Public bodies should refer to the GHG Protocol for guidance on the calculation of scope 2 emissions.

8.2.5 Scope 3 reporting

Scope 3 covers all indirect emissions (aside from those already accounted for under scope 2) from the value chain of an organisation. The GHG Protocol splits scope 3 emissions into 15 categories outlined in Table 3 below.

Table 3: Scope 3 emissions by category

Scope 3 category 1:

Description: Purchased goods and services

Scope 3 category 2:

Description: Capital goods, e.g. construction

Scope 3 category 3:

Description: Fuel and energy-related activities

Scope 3 category 4:

Description: Upstream transportation and distribution

Scope 3 category 5:

Description: Waste generated in operations

Scope 3 category 6:

Description: Business travel, including overnight stays

Scope 3 category 7:

Description: Employee commuting and homeworking

Scope 3 category 8:

Description: Upstream leased assets

Scope 3 category 9:

Description: Downstream transportation and distribution

Scope 3 category 10:

Description: Processing of sold products

Scope 3 category 11:

Description: Use of sold products

Scope 3 category 12:

Description: End-of-life treatment of sold products

Scope 3 category 13:

Description: Downstream leased assets

Scope 3 category 14:

Description: Franchises

Scope 3 category 15:

Description: Investments

All public bodies subject to the climate change duties are expected, as part of best practice, to include certain scope 3 emissions in their reports, where these are relevant. Public bodies are at different stages of maturity in relation to environmental data and reporting, and also have differing levels of capacity and resource. However, it is vital that bodies work towards expanding their reporting boundary to include relevant scope 3 emissions to better understand, monitor and reduce their overall climate impact.

Any statutory requirement to report on scope 3 categories in the future will be introduced by a formal Amendment to the 2015 Reporting Order. Introducing such an Amendment Order will require further consultation with public bodies.

Further guidance:

• GHG Protocol Corporate Value Chain Accounting Standard
• GHG Protocol scope 3 technical guidance

Scope 3 reporting – minimum expectations

As a minimum, public bodies subject to the reporting duty are expected, as part of best practice and where relevant, to include scope 3 emissions from:

• consumption of mains water (category 1)
• waste and waste water (category 5)
• business travel including, where appropriate, overnight stays (category 6)
• commuting and homeworking (category 7)
• fuel and energy-related emissions not included in scopes 1 and 2 (category 3).

Colleges and universities are, in addition, strongly encouraged to include student travel within their reporting boundary. This should include estimates of emissions from daily commuting to and from campus; and from relocation travel (travel from the place of permanent residence to the location of study at the start and end of each term or academic year). EAUC Scotland have provided a tool to support colleges and universities to calculate student travel (see Annex L).

The rationale for including waste, water, business travel, commuting and student travel is that these are areas where public bodies have more influence, and they offer opportunities to engage staff, visitors and customers. Behaviours related to these areas can be more easily influenced and managed through policy and operational processes. They are also areas where data should be more readily available to the organisation, or can be more easily and accurately estimated.

For many bodies, the emissions associated with water consumption will be small. However, careful management and conservation of water resources will become increasingly important in the future, particularly for those bodies located in eastern regions which are predicted to become more prone to drought and water shortages.^[32] Monitoring and reporting on water consumption is therefore important for wider reasons.

Reporting on fuel and energy-related emissions (category 3) provides a fuller picture of the carbon impact of using, say, natural gas as it includes the upstream emissions associated with extracting, refining and transporting the fuel. As such, it can assist in the development of robust business cases and impact assessments that support the transition to low or zero carbon alternatives.

If all relevant bodies include these categories of emissions, in a consistent approach across the public sector, it will allow more accurate analysis, and facilitate sectoral comparisons and benchmarking.

Where these emissions are not relevant to a body, a short explanation should be included in the annual report for clarity and transparency, e.g. IJBs do not employ staff and therefore should not report on staff commuting emissions.

When public bodies start reporting on scope 3 emissions, or expand their reporting to include previously un-reported sources, data maturity may be low. For example, data may be incomplete or contain a high level of uncertainty. However, bodies should not let this be a barrier to reporting on that source at all. It is recognised that each organisation is on a maturity journey, and it is essential that public bodies start to take the first steps into reporting scope 3. As part of this process, bodies should be transparent as to the source of their data, its limitations, and so the accuracy of the associated estimated emissions. Over time data quality, accuracy and completeness can be improved as data management processes mature.

Annex H outlines some of the common sources of data for the scope 3 emission categories public bodies are expected to include in their reporting as a best practice minimum.

Scope 3 reporting – going further

Over time those subject to the reporting duty, in particular bodies with larger spend and influence, are expected, as best practice, to expand reporting of scope 3 emissions to include all relevant categories.

Expansion of the reporting boundary can progress in a phased approach, focusing first on the scope 3 categories which contribute the most to the organisation’s overall footprint. Such priority categories will differ according to the body’s functions, budget and operations. As best practice, bodies should undertake an initial high level scoping exercise, first to identify the priority categories; and then to identify the emission ‘hotspots’ within those categories. Hotspots represent key opportunities where collaboration with suppliers, contractors and other stakeholders from the value chain to reduce emissions is likely to have the highest impact, allowing resources to be focused most effectively.

For many bodies, priority categories may typically include purchased goods and services (category 1) and capital goods (category 2), in particular the embodied carbon related to construction and large retrofit projects. Some bodies may find that downstream leased assets (category 13) and investments including pension funds (category 15) are also hotspots. Refer to Annex H for further information.

Where bodies choose to take a phased approach to expanding their boundary, they are encouraged to develop a clear plan and timeline for this, as part of their overall carbon management plan or equivalent. This should identify key stakeholders from across the organisation, as tackling scope 3 emissions is likely to require cross-departmental working, and involve staff who may never have been involved in environmental reporting before. It will be important that the plan recognises the need to provide training for such staff, to ensure they have the necessary climate knowledge and skills.

Any statutory requirement to report on additional scope 3 categories in the future will be introduced by a formal Amendment to the 2015 Reporting Order. Further practical guidance to support such changes to the PBCCD reporting regime will be provided separately, as required.

8.2.6 Reporting land and nature-based emissions and removals

Quantifying the emission reductions or carbon sequestered by land and nature-based projects can be complex. As noted in section 5.3.6, bodies should be aware of this and cautious with how such claims are communicated. Lack of quantitative data should not prevent reporting, and bodies can report on the progress of nature-based projects in a qualitative way. Bodies with larger landholdings and more significant projects should move towards quantitative reporting as outlined in Annex F.

8.2.7 Reporting on alignment of resources with net zero targets

Bodies subject to the mandatory reporting duty are required to include, in their annual reports, how they will align their spending plans and use of resources to contribute to reducing emissions and delivering their emission reduction targets. Bodies are encouraged to take a broad approach to reporting on this aspect of their activities and to consider staff resources and time, as well as financial resources. For example by:

• reporting on how their capital investments contribute to reduction of their scope 1 and 2 emissions, for example by investing in low emission replacement fleet vehicles, or by replacing polluting heating systems with clean heating systems in their buildings
• considering wider spending plans and budgets: spending on procurement and service design and delivery, for example, can be used to drive emission reductions
• demonstrating the use of appropriate tools and methodologies that have been used in policy and project appraisal, for example whole life carbon assessment, and incorporating the cost of carbon into the cost benefit analysis of business cases
• investing in systems that will support delivery of emissions reductions
• having staff members, roles or teams with a dedicated remit around climate action could help demonstrate alignment of resources with emission reduction targets, as could embedding climate action into annual staff objectives particularly for senior managers
• expanding staff resource allocated to climate action
• ensuring that staff are given the time to undertake climate-related and sustainability training, and for other climate-related activities and processes such as climate change impact assessments.

8.2.8 Reporting on adaptation action

A key goal of climate adaptation is to increase preparedness to extreme weather events now and in the future and to reduce vulnerability to climate change impacts.

Effective and inclusive adaptation action requires collaboration and flexibility within and between organisations. This also requires adaptation action to be embedded into an organisation’s strategies with links made to other relevant policy areas.

It is also important to think beyond direct physical impacts such as flooding or damage to estates, and to consider wider climate risks that may affect the delivery of essential services, supply chains, and overall organisational resilience.

The mandatory climate change duties report includes a set of questions focused on adaptation, the majority applying at corporate level, with one specific question on the contribution to national adaptation objectives.

Public bodies subject to the reporting duty should report on:

• understanding of current and future climate-related risks
• arrangements in place to manage climate-related risks
• action taken to adapt
• arrangements in place to review risk, and monitor and evaluate the impact of actions
• adaptation priorities for the year ahead.

Climate change mitigation measures, with the aim of reducing greenhouse gas emissions, should only be mentioned in the adaptation reporting section if they directly support adaptation action.

Public bodies subject to the reporting duty are, where applicable, also expected to report on:

• progress in delivering the Scottish National Adaptation Plan (SNAP3).

All public bodies should consider how the exercise of their functions can support the national adaptation objectives and, where applicable, report on contributions to national adaptation objectives, as outlined in chapter 6. Public bodies identified as owners of one or more policies (or proposals) in the Scottish National Adaptation Plan, should report on policy delivery.

To support statutory duties on adaptation action and reporting, public bodies are encouraged to use the Capability Framework developed by Adaptation Scotland for the Scottish public sector.

8.2.9 Sustainability reporting

Where bodies prepare annual corporate reports, these should incorporate sustainability. Bodies should, as best practice, report on alignment with, and contribution to, the NPF national outcomes through the delivery of their plans and programmes.

Sustainability reporting in annual reports and accounts

Those bodies producing annual accounts to comply with the Financial Reporting Manual (FReM, Government Financial Reporting Manual) will be aware of the development and extension of requirements to report on sustainability in annual accounts.

While the FReM presently draws on outputs of the Task Force on Climate-related Financial Disclosures (TCFD) to set out TCFD-aligned disclosures and application guidance, the FReM recognises that relevant authorities may have different frameworks already in place for reporting.

Paragraph 5.4.15 in the FReM 2025-26 and prior year equivalents states “Spending bodies accountable to the Scottish Parliament will report on sustainability within the framework established by the Scottish Government and in accordance with guidance issued by the Scottish Government.”

Similarly, the TCFD-aligned disclosure for the UK public sector application guidance document recognises that it applies where bodies have been directed or instructed to follow the guidance by their respective relevant authority.

The primary reporting requirements for Scottish public bodies remain those laid out in The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015, as amended.

The Scottish Government as “relevant authority” issues guidance on annual accounts requirements and will update its guidance as necessary for developments in climate change reporting, recognising the interest in having reporting in annual accounts. That guidance will continue to draw on the statutory requirements already in place, to allow material to be signposted and used for reporting in accounts.

Auditors will review compliance with any existing and emerging requirements that apply to Scottish public bodies. The latest guidance for external auditors is on the Audit Scotland website.

Mandatory PBCCD reporting

At time of publication, the mandatory reporting duty does not include a question explicitly around compliance with the third duty, to act in the most sustainable way. In the future, consideration may be given to introducing a question specifically around this duty; and relevant bodies would be required to comply with any additional reporting requirements.

Part 5 of the annual mandatory report focuses on procurement. Any procurement activity undertaken by Scottish public bodies should be in line with the Sustainable Procurement Duty (see section 7.3.6), and this part of the report should reflect that approach.

Bodies are encouraged to report on their compliance with the third duty using other sections of the reporting template, for example using the free text fields provided for additional and supporting information, and the recommended voluntary questions for reporting on wider influence. Mainstreaming sustainability into decision making through the use of sustainable development impact assessments, for example, would help demonstrate compliance with the third duty, and would produce a clear audit trail.

8.2.10 Reporting on wider influence emissions

Through the climate change duties, the 2009 Act requires all public bodies, in exercising their functions, to contribute to addressing climate change. Collectively, public bodies have a wide range of functions that can influence emissions including spatial and transport planning, place-making, investment, infrastructure development, economic development, funding, regulation, communications, education, community development, and partnership development and facilitation.

Bodies are unlikely to be able to report in quantitative terms on the emissions impact of these activities, but should make efforts to report these voluntarily in qualitative terms under the recommended wider influence questions in the reporting template.