In Template 1 of the final ITS (Commission Implementing Regulation (EU) 2022/2453) in column j the "Of which Scope 3 financed emissions" should be reported. Reading Annex 2 of the Regulation, "Institutions shall disclose their scope 3 emissions" where "their" refers to "institution" - this would be the scope-3-financed emissoions of the PCAF standard and therefor the total financed emissions inclusing scope 1 /2 /3 of their (!) counterparties. Is is correct, that here only the counterparties scope-3-emissions should be reported?
While getting more and more involved in GHG Accounting, we have the feeling that the definition and reflexive use of "their" is not always clear in the Annex. Keep in mind, that financed scope 1/2/3-emissions of the counterparties are altogether scope-3-emissions of the institution. Therefore, we ask to have this clear here.
According to the instructions for Template 1, included in the Annex II of the Commission Implementing Regulation (EU) 2022/2453, in column “I” institutions shall disclose their scope 3 GHG financed emissions, which are scope 1, 2 and 3 emissions of their counterparties. Regarding column “j” (“Of which Scope 3 financed emissions”), the first sentence of the instructions for this particular column states that: Institutions shall disclose their counterparties’ scope 3 emissions associated with institutions’ lending and investment activities. It means that column “j” is dedicated specifically for scope 3 emissions of the counterparties.