If your carbon reporting relies on the quiet comfort of ‘we excluded that category because it wasn’t material,’ your grace period just got a lot shorter.
The GHG Protocol published its Scope 3 Standard Revisions Phase 1 Progress Update at the end of March 2026. Buried in the technical language is a shift that will reshape how companies account for their environmental impact: the proposed 95% coverage rule.
What the rule says
Under the current Scope 3 standard, companies can exclude emission categories with fairly loose justification. The revised standard proposes that companies must account for at least 95% of their total required Scope 3 emissions. Exclusions can’t exceed 5%, and those exclusions must be quantified, disclosed, and justified with hard numbers. The old approach of describing what you left out in a footnote won’t cut it anymore.
To prove your exclusions fall within the 5% cap, you’ll need to quantify 100% of your required Scope 3 first, including the bits you choose to exclude. In other words, you need to count everything before you’re allowed to leave anything out.
Why IT hardware matters more than most people think
End-user devices sit in either Category 1 (purchased goods and services) or Category 2 (capital goods) of the Scope 3 framework. Manufacturing a single laptop generates roughly 300 to 400kg of CO2e. Multiply that across a fleet of thousands of devices, refreshed every three to four years, and the numbers add up fast.
But here’s the bit that catches people out: end-of-life treatment sits in Category 5 (waste generated in operations) and Category 12 (end-of-life treatment of sold products). If your retired devices go to a vendor who can’t provide verified carbon data on what happened next, you’ve got a gap in your reporting. Under the 95% rule, that gap counts against you.
The reporting chain is only as strong as its weakest link
UK companies are already preparing for the UK Sustainability Reporting Standards (UK SRS), published in February 2026. Mandatory climate disclosures for listed companies start in January 2027. The FCA has proposed that Scope 3 reporting follows on a comply-or-explain basis from 2028.
When these standards converge with the GHG Protocol revisions, the message is clear: Scope 3 is moving from ‘best effort’ to ‘prove it.’ Every supplier in the chain, including your IT disposal partner, will need to provide data that stands up to scrutiny.
What to look for in your ITAD partner
The smartest organisations aren’t waiting for the final standard. They’re auditing their supply chains now and asking uncomfortable questions: can your ITAD provider tell you, device by device, what carbon was avoided? Can they show you the difference between a device that was refurbished and reused versus one that was shredded? Can they report on social outcomes alongside environmental ones?
The companies that treat this as a compliance exercise will spend the next two years scrambling to fill data gaps. The ones that see it as an opportunity will already have reporting infrastructure in place that turns surplus IT into measurable carbon reduction.
The 95% rule isn’t a surprise. It’s a signal. The question is whether you’re reading it.