The next shift in corporate carbon accounting will be how Scope 3 emissions are measured.
Most corporates started their carbon journey on spend-based accounting applied to an emission factor to £/€/$ spent, and call it Scope 3 emissions. While it was always an estimate, it was fast, and it got companies reporting.
Scope 1 and 2 have already moved past this. Most mature reporters now use activity-based data (e.g., actual kWh, actual fuel volumes, actual site-level consumption). It’s more accurate, auditable, and defensible to auditors and stakeholders. Scope 3 has always been a more challenging step. Not because the logic is different, but because the data has historically been unavailable at the level of granularity needed.
In 2026 that’s changing. And commodity EACs (Environmental Attribute Certificates) are a big part of why. Activity-based data is generally a prerequisite, and verified EACs are what make the switch pay worth the effort. Companies can’t attach a verified, unit-level instrument to a category you’re still measuring by spend.
Once a category is measured by activity a device, a tonne of material, a unit of energy = verification becomes possible. And once it’s verified, it clears bars a spend-based estimate never could:
✔️ Traceable to physical units, not abstract spend
✔️ Independently verified, e.g. to ISO 14064-2
✔️ Meets the EAC criteria in SBTi’s CNZS V2 draft guidance
✔️ Usable for actual reduction target-setting, not just reporting
That last point is the one that matters most. A spend-based estimate can be disclosed. It can’t be reduced against. Verified activity data is what turns a Scope 3 line item into an actionable decarbonisation target and reduction plan.
We expect this to start with the categories where unit-level activity data is easiest to capture and verify:
→ Category 1 (purchased goods and services): increasingly traceable to specific units purchased, not just spend
→ End-of-life / disposal (where ITAD and recycling data already exists at the device and material level)
For hardware-heavy industries in particular: telecoms, hyperscalers, enterprise IT. For any company with increasing AI spend this is where the pressure is building fastest. Once Scope 1 and 2 are activity-based, spend-based Scope 3 estimates increasingly look like the weakest link in the inventory = and the biggest opportunity for near-term decarbonisation.
Curious whether others are seeing the same pull towards activity-based Scope 3, or whether spend-based is still holding for most of your client base?
From Estimate to Evidence
Unit-level device and material data replace generic $-per-spend emission factors.
Audit-Grade by Design
ISO 14064-2 verification satisfies the commodity EAC criteria in SBTi’s CNZS V2.
Parity with Scope 1 & 2
Brings Scope 3 up to the same activity-based rigor already applied elsewhere in the inventory.
The First Tangible Lever
Verified activity data converts a Scope 3 estimate into an actionable decarbonization target.
Traceable to the Value Chain
Tied directly to physical units, e.g., devices refurbished & given a second life, materials recovered via recycling.
What Clears the Bar for Real Decarbonization Claims
Criteria per ISO 14064-2 and SBTi’s CNZS V2 draft guidance on commodity EACs.
| Spend-Based | Activity-Based | + Verified EAC | |
|---|---|---|---|
| Traceable to physical units | – | Yes | Yes |
| Independently verified (ISO 14064-2) | – | – | Yes |
| Meets SBTi CNZS V2 EAC criteria | – | – | Yes |
| Usable for reduction target-setting | – | Partial | Yes |
Activity-based data is the prerequisite. Verified EACs are what make the switch pay off — not the other way around.
Estimate
Measure
Verify
Decarbonize
The first two steps are within reach today. Commodity EACs unlock the last two.
