Scope 3 Reporting in 2025: What's Changed and What Hasn't

The SEC's climate disclosure rule, finalized in 2024 and partially stayed pending litigation, created significant uncertainty about Scope 3 reporting requirements for public companies. At the same time, the EU's CSRD extended mandatory Scope 3 reporting to a large class of companies operating in Europe.

Here is what the landscape actually looks like entering 2025.

For US-listed companies

The SEC rule, as it stands, requires Scope 1 and 2 disclosure for most registrants. Scope 3 disclosure was removed from the final rule before finalization. However: voluntary Scope 3 disclosures remain common among large-cap companies responding to investor pressure, and the SEC has indicated it will continue monitoring the space.

The practical implication: if your institutional investors are asking for Scope 3 data — and most are — you need it regardless of regulatory status. The audit risk is lower than Scope 1/2, but the expectation is there.

For companies operating in Europe

CSRD's Scope 3 requirements are mandatory for in-scope companies. The "double materiality" assessment required by CSRD means you must assess both how climate affects your business and how your business affects the climate. Scope 3 is central to both.

Where the audit risk actually sits

In our experience, the audit risk on Scope 3 is not in the reported numbers — it's in the methodology. Auditors are increasingly asking how emissions factors were selected, how data gaps were handled, and whether the calculation methodology is consistent year-over-year. Companies that can answer those questions have defensible disclosures. Companies that can't are exposed regardless of what the number is.

Residua's Carbon Visibility Reporting engagements produce disclosures that are methodology-first: every assumption documented, every data gap flagged, every calculation traceable. That's what defensibility looks like.