Carbon reporting consultation toolkit

Everything you need to get your company behind mandatory emissions reporting

Quick summary

The government is consulting on a new law governing how companies report their carbon footprint. If they get it right, it could level the playing field and make it simpler to measure emissions. This is our chance to make it happen.

If you're pushed for time
Email [email protected].uk saying your company supports mandatory reporting for all Large Businesses (i.e. consultation option 3).

If you've got a bit longer
Use our handy toolkit below to write a full response to the government's consultation. You don't have to answer every question, but the more detail you can provide, the better. All you need to do is download the questions, fill them in and email them to 
[email protected].uk


What's this all about? 

As part of the Climate Change Act the government must make regulations on reporting greenhouse gases (including carbon) by businesses before April 2012 or explain to Parliament why they haven’t.

Defra is running a consultation on the issue, which closes on 5 July 2011. It offers a range of options including business as usual, a beefed-up voluntary system, and mandatory reporting for different groups of companies.

The main thing we need is numbers so even if you're pushed for time it's well worth writing in with your preferred option. If you've got a bit longer, try to answer as many of the questions as you can. The more detail you can provide, the better.

What are the options?

Option 0
Business as usual – this assumes no change to the current policy position.

Option 1
Enhanced voluntary reporting: increasing awareness of reporting guidance and outreach to businesses

Option 2
Mandatory GHG reporting under Companies Act for all Quoted companies

Option 3
Mandatory GHG reporting under Companies Act for all Large companies.

Option 4
Mandatory GHG reporting for all companies meeting an energy use criteria

Which option does 10:10 support?

While any mandatory reporting system would be a step forward, 10:10 supports Option 3 (mandatory reporting for large businesses) because it covers more companies and more emissions than any of the alternatives. And we're in good company – some of the largest 10:10 businesses, including Land Securities, Colliers International and Kyocera Mita UK, also favour Option 3. 

How do we submit a response?

To take part in the consultation all you need to do is answer these questions and email your response to [email protected] by Tuesday 5 July.

You don't need to answer all of them but it's good to provide as much information as possible.

For more information on the consultation and the different options you can download:

If you have any question you can contact Alice Douglas, at Defra, on 0207 238 6671 or email her on [email protected]

If you'd like to talk to the 10:10 team about why we're supporting Option 3, get some help with your response or provide a supportive quote for press, you can reach Harriet on 0207 388 6688 or email [email protected].

The consultation questions

Questions on the four options

  • Do you support Option 1(enhanced voluntary reporting)? If you do, please explain why. 
  • If you do support voluntary reporting, do you think there needs to be additional guidance, publicity or other support?  There are various ideas (outlined in Option 1) for increasing the number of companies reporting on a nonregulatory basis, have you any comments on these?  Have you any other proposals to increase the number of companies reporting and the quality and consistency of reports on a non-regulatory basis?   
  • Should corporate reporting of GHG emissions be made mandatory for some companies? If so, please explain.
  • If mandatory reporting is introduced, which would be your preferred Option:  2, 3 or 4? It would be helpful if you could explain your reasons.  Have you any suggestions for improving any of the regulatory options?
  • Do you have any comments on the economic analysis in the impact assessment?  In particular, do you think the costs and benefits for the different options are reasonable?  Can you provide any further information which would help in estimating costs and benefits for the different options?

Questions on organisational boundaries

  • Do you agree that a company should specify which approach is using to set its organisational boundary?
  • Do you agree that a company should (where possible) report on all their emissions within the chosen organisational boundary, including those that occur in their operations overseas? If you don’t agree, can you explain which emissions you think a company should report?
  • Do you agree that, if it isn’t possible for a company to report on emissions within their organisational boundary (because of data problems, etc.) then a company should clearly state the extent to which it had been able to reporting?

Question on gases to be reported

  • Do you agree that companies should be required to measure and calculate emissions from the six GHGs covered by the Kyoto Protocol? 

Questions on scopes

  • Do you agree that companies should be required to measure, or calculate, and report on all their scope 1 and scope 2 emissions? If not, which emissions do you think a company should measure, calculate and report and why?
  • Do you think that companies should be required to measure and report on any of their scope 3 emissions (in addition to scope 1 and 2)? If so, can you specify which ones you think should be required?

Questions on what companies should report

  • Do you agree that companies should specify in their directors reports, the company’s total annual amount of GHG emissions in CO2e broken down by direct emissions (scope 1) and indirect (scope 2)?
  • Do you agree that companies should specify an intensity ratio?
  • Should companies specify a base year when they report their annual emissions?
  • Is there any other information which you think a company should report?

Questions on assurance and verification

  • If reporting is mandatory, should companies be obliged to seek some kind of assurance or verification on their emission report? If not, could you explain your thinking.
  • Is internal verification of greenhouse gas emissions sufficient, or should external third party assurance be sought? If the latter, should it be limited or reasonable?

Download an editable Microsoft Word version of the questions