Measuring what matters

Taking the first steps in greenhouse gas accounting

panellists at Terra 2025
  • Publication
  • 3 minute read
  • November 25, 2025

As the EU Commission proposes narrowing the CSRD’s scope to companies with more than 1,000 employees, it has also adopted a recommendation to support voluntary sustainability reporting for small and medium-sized enterprises. This is a timely opportunity for smaller businesses to embrace proportionate reporting that still meets market expectations from investors, lenders, and supply-chain partners. 

 

EFRAG’s Voluntary SME (VSME) standard is designed for exactly this purpose and is expected to serve as the basis for a future Commission delegated act.


Measuring what matters Taking the first steps in greenhouse gas accounting

Understanding and managing your greenhouse gas (GHG) emissions is one of the most effective ways to show that your organisation takes climate action seriously. But beyond being “the right thing to do,” GHG measurement delivers tangible business value:

1

Measuring your emissions ensures your organisation is prepared to meet emerging reporting standards with confidence and accuracy.

2

Investors, customers, and employees increasingly look out for evidence of credible climate action. Transparent, data-driven reporting on emissions signals accountability and builds long-term trust.

3

Reducing emissions can drive efficiency, lower operating costs, and unlock access to sustainability-linked financing or procurement opportunities.

GHG accounting may seem daunting or complex at first, particularly when you begin looking beyond your own operations into your supply chain. The key is to start with what’s manageable, build a foundation of reliable data, and then expand gradually.

A practical starting point on this journey is to focus on your organisation’s Scope 1 and Scope 2 emissions. These are the emissions that you directly control and where data tends to be most readily available.

Fuel burned on-site or in company-owned vehicles - for example, gas used in generators or diesel for company cars.

Emissions from the electricity, heating, or cooling that your organisation purchases from energy providers.

By quantifying these first, you can identify opportunities to improve energy efficiency, reduce fuel use, and lower utility costs.

Establishing a baseline year is an essential early step. This will act as a reference point for all future comparisons and helps you track progress over time. By comparing annual emissions to this baseline, you can assess the effectiveness of your reduction initiatives and communicate results transparently to stakeholders.

Looking further into your supply chain

Once your organisation is confident in measuring Scope 1 and 2 emissions, the next step is to explore Scope 3 emissions: the indirect emissions that occur across your value chain.

Scope 3 often represents the majority of a company’s total carbon footprint. It includes fifteen categories defined by the GHG Protocol, such as purchased goods and services, business travel and employee commuting.

For many organisations, addressing Scope 3 emissions often drives the most significant reductions in a company’s overall carbon footprint. Addressing these emissions is often seen as the truest measure of an organisation’s commitment to environmental responsibility – showing commitment to meaningful change.

However, not all Scope 3 categories will be equally relevant to your organisation. This is why a Scope 3 screening assessment becomes an essential part of the process to help identify those areas which contribute most significantly to your total footprint, to then prioritise action here. 

For instance:

GHG accounting as the foundation for further action

Once a reliable emissions inventory has been established, the next step is to turn insights into action. GHG accounting isn’t just a reporting exercise, it’s also a management tool, where data can be harnessed to accelerate meaningful progress:

Identify efficiency gains

Look for operational improvements that reduce both emissions and costs: such as energy optimisation and equipment upgrades.

Engage your suppliers

Encourage suppliers to measure and report their own emissions and collaborate on joint reduction strategies.

Set science-based targets

Use your baseline and early data to establish reduction goals aligned with recognised frameworks such as the Science Based Targets initiative (SBTi).

Track and communicate progress

Consistent, transparent communication builds credibility and can strengthen relationships with investors, customers, and employees.


How can we help?

Our team can help by assessing readiness and defining clear boundaries and methodologies aligned to the GHG protocol, then build a reliable Scope 1 and 2 inventory and establish a baseline year. We can support in conducting Scope 3 screening analyses to pinpoint the categories that matter most for your business, prioritise feasible data collection, and design supplier engagement programmes to improve data quality over time. Eventually, this can help identify emission hotspots to start your journey towards decarbonisation, where we can support target setting in line with the Science Based Targets.

If you’re interested in taking the first step towards GHG accounting within your organisation, please contact the PwC Malta Sustainability team.

This content is for general information only and does not constitute professional advice.

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Norbert Paul Vella

Norbert Paul Vella

Assurance Partner, PwC Malta

Tel: +356 9945 3843

Carl  Zammit la Rosa

Carl Zammit la Rosa

Manager, Advisory, PwC Malta

Tel: +356 7973 8459

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