Navigating the Evolving Carbon Reporting Landscape
15 December 2025
Carbon reporting is no longer optional. Organisations in the UK and EU are under increasing pressure from regulators, investors, and stakeholders to demonstrate credible progress towards net zero. The landscape, once voluntary and fragmented, is now evolving rapidly into a complex web of regulatory obligations.
For IT and digital operations, this presents both challenges and opportunities. The majority of an organisation’s carbon footprint lies in Scope 3 emissions, particularly in purchased goods and services such as IT hardware. Understanding regulatory requirements and aligning reporting practices with global standards is essential for compliance, operational efficiency, and environmental leadership. For a detailed guide to UK and EU reporting frameworks, see the Carbon Reporting Primer.
Key Carbon Reporting Requirements
CSRD – Corporate Sustainability Reporting Directive (EU)
The CSRD applies to large undertakings with turnover over €50 million, balance sheet assets above €25 million, or more than 1,000 employees, particularly public interest companies. Reporting begins with fiscal years starting on or after 1 January 2025, with publication required within 12 months of the reporting period.
CSRD mandates Environmental, Social, and Governance (ESG) reporting aligned with European Sustainability Reporting Standards (ESRS). Organisations are required to report on their entire value chain, including Scope 3 emissions, where material. For IT, this typically includes asset manufacturing, transport, use, and end-of-life impacts, which can account for 30–50 per cent of enterprise CO₂e emissions.
The directive emphasises data quality, harmonisation, and comparability, requiring reasonable effort to collect supply chain information and align with global frameworks, including the International Sustainability Standards Board (ISSB) and the GHG Protocol.
SECR – Streamlined Energy and Carbon Reporting (UK)
SECR applies to all quoted companies and to large unquoted companies or LLPs that meet two or more thresholds (turnover above £36 million, balance sheet over £18 million, 250+ employees). Currently, reporting focuses on Scope 1 and 2 emissions, but Scope 3 is expected to become mandatory following consultation and alignment with ISSB standards.
Organisations are encouraged to prepare for Scope 3 reporting now, particularly for IT assets, to ensure compliance with the UK’s net zero commitments of an 81 per cent reduction by 2035 and net zero by 2050.
Aligning Global Standards
Both SECR and CSRD draw on the FSB Task Force on Climate-related Financial Disclosures (TCFD) for guidance. TCFD, in turn, references the IFRS ISSB standards, which rely on the GHG Protocol for measuring greenhouse gas emissions.
This alignment underscores the importance of accurate, auditable, asset-level IT carbon data. Organisations that measure CO₂e across the full lifecycle of their IT assets can generate reliable reports, optimise procurement and disposal strategies, and model the path to net zero with confidence.
ISO 14064 and GHG Protocol Harmonisation
Two of the most widely used frameworks for carbon accounting are ISO 14064 and the GHG Protocol. Historically, organisations have used them in combination: ISO 14064 for structured reporting and third-party verification, and the GHG Protocol for detailed Scope 1, 2, and 3 methodologies.
In September 2025, ISO and the GHG Protocol announced a strategic partnership to harmonise their standards. This collaboration aims to:
- Reduce duplication and improve consistency
- Create a co-branded international standard aligned with CSRD, ISSB, and GRI
- Introduce a joint product carbon footprint standard for more granular value-chain reporting
For UK organisations, the partnership represents a significant opportunity to streamline reporting processes, anticipate regulatory convergence, and build credibility with investors and stakeholders. While explicit UK recognition under SECR and TCFD is not yet confirmed, alignment with ISSB frameworks is expected to influence future disclosure obligations.
For more details on the differences, overlaps, and practical implications, see the ISO vs GHG Protocol document.
Practical Guidance for Organisations
- Understand the Current Frameworks: Familiarise your teams with ISO 14064 and the GHG Protocol.
- Monitor Harmonisation Developments: Stay up to date with draft standards and joint guidance.
- Embed Verification: Build capacity for third-party assurance to strengthen credibility.
- Prepare for Scope 3: Engage suppliers and measure IT assets across their lifecycle.
- Align IT to Corporate Goals: Use asset-level data to support sustainable procurement, retention, and disposal strategies.
Conclusion
The regulatory landscape for carbon reporting is accelerating. Organisations that prepare now, with robust, verifiable carbon accounting practices, will not only meet compliance obligations but also position themselves as leaders in sustainability.
Explore your regulatory reporting readiness and IT carbon footprint strategy with KA2. Schedule a short, no-obligation session with our consultants to discuss your compliance and sustainability priorities.
