The role of public sector bodies in tackling climate change: consultation

We are seeking your views on the way that information and knowledge are shared between public sector bodies; whether public bodies should set targets for themselves to achieve zero greenhouse gas emissions; and on proposed changes to the mandatory reporting duties.

Part 2: Targets and reporting

The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015 requires Public Sector Bodies to publish annual climate change reports. This was intended to demonstrate compliance with Public Sector Bodies’ climate change duties, to engage leaders and encourage action. The Order is reproduced in Annex A, and the list of Bodies required to report is in Annex B.  

The Scottish Government established a short-life, collaborative working group to carry out a preliminary review of the reporting duties and associated processes. The group consisted of representatives from 16 organisations including the Sustainable Scotland Network (SSN), COSLA, local authorities, educational institutions, NHS and environmental NGOs. Its main focus was to look for opportunities to increase the value of the reporting, while decreasing administrative burden.  

The group reviewed the structure and content of the current Order, the associated data collection system, the listed bodies and the way collected data are communicated. The group also revisited the purpose of mandatory reporting and agreed a set of criteria which would be used for evaluating the effectiveness of the reporting system.  

The group concluded that mandatory reporting should:

  • drive climate change performance within individual organisations; 
  • drive climate change action across the public sector as a whole; 
  • inform the ongoing development of policy, by linking it with national policy frameworks (such as the Climate Change Plan and Scottish Climate Change Adaptation Programme).

The group also agreed that reporting should be:

  • Efficient (designed to facilitate impactful analysis and aligned with other reporting mechanisms to avoid duplication, where possible);
  • Effective (informing leadership, action and decision making; enabling progress tracking; linking to national and local policy; shows wider impact and encourages collaborative work);
  • Professional and trusted (compliant with reporting standards; transparent; providing data that is easy to understand, communicate and access);
  • Adaptable (designed to evolve, as required; proportionate).

The key findings of the review were that:

a) Some parts of the reporting duties are too rigid, tied very closely to objectives, policies, priorities and programmes and therefore liable to become out of date over time. 

b) In contrast, other parts are too open, such as part 2 (governance, management and strategy), generating challenges for data collection and consistency.

c) The “procurement” sections currently provide little meaningful data and do not effectively monitor how procurement policies are contributing to emissions reduction.  

In light of the review and the Global Climate Emergency, the Scottish Government considers that the Public Sector Reporting Duties should be amended to:

1. require all Public Sector Bodies to state the year by which they will cease to emit any direct greenhouse gases and their targets for reducing indirect emissions; 

2. report on how Public Sector Bodies will align their spending plans with these targets; 

3. remove the detailed specification of all data fields from the Order itself, replacing this with a) high-level reporting requirements and b) a requirement that the Scottish Government produce detailed specification of every data field in a separate guidance document;  

4. update the list of Bodies that must report;   

5. remove the requirement to report information that is not directly pertinent to ending Scotland’s contribution to climate change; 

6. require every Public Sector Body to make their report publicly accessible, in a way that empowers stakeholders and members of the public to view and understand it, in addition to providing the report to the Scottish Government.

These proposals are explained more fully below. The changes proposed would come into effect in 2022.

In addition, and not requiring any changes to the secondary legislation, the Scottish Government will provide a publicly accessible analysis of all Public Sector Bodies reports that allows stakeholders and members of the public to readily understand the overall level of progress and ambition in tackling climate change across Public Sector Bodies.

1.1 Public Sector Bodies to set their own emission reduction targets

Our climate change targets mean that Scotland as a whole will achieve net-zero emissions of all greenhouse gases by 2045 at the latest.  Achieving net-zero emissions is a nation-wide endeavour. The CCC scenario for net-zero has all sectors at zero, or virtually zero, emissions except for agriculture, some parts of industry, and international aviation[1]. Remaining emissions from these sectors will need to be balanced, or outweighed, by negative emissions solutions such as tree planting and bioenergy with carbon capture and storage. The balance between remaining emissions and negative emissions needs to be across the whole economy, and the Scottish Government is committed to achieving this without the use of international offset credits.

Currently there is no requirement for Public Sector Bodies to report on the year by which they intend to achieve zero greenhouse gas emissions, either from their own estate and operations (their direct emissions) or, in the case of Local Authorities, for their Local Authority area. 

A lot of what individual Public Sector Bodies will be able to achieve in terms of reducing their emissions will be dependent on what progress is made in the rest of society. Within 6 months of the Climate Change (Emissions Reduction Targets) (Scotland) Bill receiving Royal Assent we will update the Climate Change Plan, setting out the pathway to decarbonisation for Scotland as a whole.  

Following the update to the Climate Change Plan, we propose that in their future annual reports, all Public Sector Bodies report the date by which they intend to achieve zero direct emissions – those are the emissions that the bodies are directly responsible for.  Recognising that indirect emissions are not entirely within Public Sector Bodies’ control, we recommend that each organisation sets their own targets, with dates, for the extent to which they aim to use their influence to reduce those. 

The targets that Public Sector Bodies set themselves will not be legislative targets, and the targets they set themselves in the first year of reporting may need to be amended in subsequent years reporting when further information becomes available, as progress in other parts of society become apparent for example, or to align with future Climate Change Plans

Q3. Do you agree that Public Sector Bodies should be required to set targets for when they will achieve zero direct emissions, and for reduced indirect emissions?  

Yes / no / don’t know

Please explain your answer.

1.2 Public Sector Bodies to report on how they use their resources to contribute to reducing emissions

The Scottish Parliament have debated whether Scottish Ministers should be  required to ensure that all Public Sector Bodies will use their resources in a way that will contribute to meeting or exceeding Scotland’s emissions reduction targets, prior to approving resources[5].  

We propose that a proportionate way for Public Sector Bodies to demonstrate that they are using their resources to contribute to reducing emissions is to require them report on how they do this, as part of their annual reporting.  

Q4. Do you agree that Public Sector Bodies should report annually on how they use their resources to contribute to reducing emissions? 

Yes / no / don’t know

Please explain your answer.

1.3 Specify detailed reporting requirements in Statutory Guidance

The current reporting template is prescribed in detail by the Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015  and secondary legislation is required to make any changes. The review process highlighted that a degree of flexibility in specifying the content of reports would be preferable. 

We propose to amend the Order so that it specifies high-level reporting requirements and refers to statutory guidance for the detail of what Public Sector Bodies must report on. Any future changes to the statutory guidance would be made in consultation with COSLA and key Public Sector Bodies. This would reduce the time and resources required to implement changes and would allow the reporting duties to evolve more flexibly in line with national policies and strategies. 

Q5. Do you agree that the details of what Public Sector Bodies are required to report on should be set out in statutory guidance instead of on the face of secondary legislation (otherwise known as an Order)?

Yes / no / don’t know

Please explain your answer.

1.4 Update the list of Public Sector Bodies required to report 

The reporting duties apply to Public Sector Bodies listed in schedule 1 of the Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015 (See Annex B).

We propose to make the following amendments to the listed bodies:


  • The chief constable of Police Service of Scotland (given that this is now included within the Scottish Police Authority)
  • The Registrar General of Births, Deaths and Marriages for Scotland (given that this is now included within the National Records of Scotland)
  • Integration Joint Boards (IJBs), as they do not own an estate and do not produce emissions. Since they do not have operational control of the services provided by their NHS and local government partners, no emissions data has been reported by IJBs to date. 


  • The Common Services Agency for Scotland, which is now known as ‘NHS National Services Scotland’
  • The Scottish Sports Council, which is now ‘Sportscotland’
  • Social Care and Social Work Improvement Scotland is now ‘The Care Inspectorate’
  • The Scottish Further and Higher Education Funding Council, which is now ‘The Scottish Funding Council’


  • South of Scotland Enterprise (due to be established in 2020)
  • Ferries owned by Scottish Government (Caledonian Maritime Assets Ltd and David MacBrayne Ltd) 
  • Scottish Prisons Service
  • Scottish Public Pensions Agency
  • Skills Development Scotland
  • Student Awards Agency for Scotland
  • Social Security Scotland
  • Scottish Forestry
  • Forestry and Land Scotland

Q6. Do you agree to the proposed changes to the list of Public Sector Bodies that are required to annually report their emissions?  

Yes / no / don’t know

If you answered no, please specify which aspect of the proposal you disagree with and why.

1.5 Emphasise delivery in the reporting requirements

In light of Scotland’s increased ambition, we want to ensure reports focus on delivery. The review process noted that, in order for the reporting to drive action, it should be as efficient and effective as possible. We are proposing a range of amendments to ensure that those criteria are met and to provide more clarity and simplification, where possible.

In Part 1 (Profile) we propose to remove 1d (Metrics used by the Body) and 1g (Context – a summary of the Body’s nature and functions that are relevant to climate change).

We propose removing Part 2 (governance and management), which asks questions about governance arrangements, strategy, how climate change action is managed, priorities, use of the Climate Change Assessment Tool, and for other supporting information. 

In Part 3 (emissions, targets and projects) we propose to:

  • Keep questions 3(a)-(c), which address overall emissions, sources and details of generation/consumption/use of renewable energy
  • Amend question 3(d), which asks about targets. This will reflect our proposal in Section 4.1 (above) to require Public Sector Bodies to commit to a net-zero emissions date and would address:
    • The organisation’s target date for achieving zero direct emissions and
    • The organisation’s reduction targets, including dates, for indirect emissions.
  • Remove questions 3(e)-(k), which ask about carbon savings, carbon reduction projects, estimated emissions and cost savings for the year ahead. 

We will update Part 4 (Adaptation) of the report. Our approach will seek information on progress with adaptation policies and strategies, focusing on outcomes, challenges and opportunities, rather than the specific objectives outlined in the existing order.  

The procurement section of the climate change reporting duties (Part 5) has not resulted in meaningful information being gathered, so we propose to stop collecting data in this way. Instead, we will explore how mandatory climate change reporting can best align with our Programme for Government 2019-20 commitment to mobilise the £11bn of annual procurement to support our climate emergency response, including consulting on legislation to require public bodies to set out how they will meet our climate change and circular economy obligations.

We propose to remove Part 6 (Validation) of the report.

Q7. Do you agree with our proposals for amending the reporting requirements as set out above?  

Yes / no / don’t know

If you answered no, please specify which aspect of the proposal you disagree with.

Q8. Is there anything else you think should be added to the reporting duties, or anything else you think should be removed?

1.6 Public Sector Bodies to make their reports publicly accessible 

Currently, Public Sector Bodies are required to submit their reports to the Scottish Government. The Scottish Government then makes the reports available to the public in the form in which they were provided. 

The review group agreed that reports should: drive climate change performance within individual organisations; drive climate change action across the public sector as a whole; and inform the ongoing development of policy. The group considered that there is currently a lack of clarity about the purpose of the data and how it is being used. 

The Scottish Government considers that each public sector body should be required by the legislation to make their reports publicly available and do so in a way that is accessible, prominent and meaningful, so that local stakeholders can use the reports to hold the public sector body to account.

Q9. Do you agree that Public Sector Bodies should each make their own report on emissions reductions publicly available?

Yes / no / don’t know

Please explain your answer.

The Scottish Government also considers that analysis of the reports needs to be improved. The analysis should be useful to Public Sector Bodies, and transparent and informative to others. We will ensure that improvements to analysis and communication are made following changes to the Reporting Duties. 

Other comments

Please use this space to make any further comments on the role of the public sector in tackling climate change.



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