SBTi’s greenhouse gas (GHG) emissions inventory requirements

Greenhouse gas (GHG) emissions inventories are typically aligned with the Greenhouse Gas Protocol. However, the Science Based Targets initiative (SBTi) Buildings Criteria require real estate companies to go beyond this standard by accounting for additional emissions categories.  In particular, data collection for certain categories—such as F-Gas from tenant-controlled systems and emissions from sold properties—is not yet common practice. As a result, many real estate companies may face data gaps when reporting emissions and setting SBTi-aligned targets.

Recognising this challenge, SBTi allows organisations to use estimated emissions data, provided that the estimates are based on a robust and verifiable methodology. This methodology is subject to review during SBTi’s target validation process. Additionally, all assumptions must be thoroughly documented and transparently disclosed.

Further details on these emissions categories are outlined below:

• Whole building F-gas emissions data: The Buildings Criteria require that emissions from refrigerant charge and leakage be accounted for across the entire building, including tenant-controlled areas. However, collecting tenant F-gas data presents a significant challenge in the UK. It is not standard industry practice, and many companies do not currently track F-gas emissions. Even when tenants do collect this data, data-sharing restrictions often prevent it from being passed on to landlords. Additionally, landlords face a considerable administrative burden in trying to gather this information. To address this gap, Greengage has developed a unique approach that leverages asset management data and existing CIBSE guidance to estimate tenant F-gas emissions in a robust and practical manner.
• Emissions of sold buildings: SBTi has made it mandatory for organisations to calculate and report the lifetime in-use operational, lifetime in-use embodied, and end-of-life emissions for any building developed by the organisation, which is sold in the reporting year. However, this is not standard practice and presents a significant challenge for companies. Estimating these emissions requires a whole-life carbon assessment and operational energy modelling, which are complex, resource-intensive, and not routinely undertaken across all developments. While these assessments are becoming more common, they are still largely confined to projects where such studies are mandated as part of the planning process. As a result, data availability and consistency remain key barriers to full compliance with the Criteria.
• Tenant’s embodied emissions: The Criteria requires inclusion of all in-use embodied emissions from renovation or retrofit activities carried out by tenants within the reporting year. However, this presents a significant challenge, as tenants do not typically calculate embodied carbon emissions associated with their retrofit works. Even where this data is collected, landlords often have no access to it due to the lack of formal data-sharing mechanisms. Tenants are not required to disclose material specifications or construction details, limiting transparency and data availability.

Baseline re-calculation requirement

In alignment with the GHG Protocol, SBTi requires organisations to retroactively update their base year and most recent year emissions if there have been any significant changes.  Any change exceeding 5% of the total emissions constitutes a significant change. This could be due to structural changes such as mergers, divestments or acquisitions, data availability and/ or methodology. The 5% threshold applies even if it is reached as an aggregate of different changes.

Target boundary must cover whole building emissions from all buildings

The target must cover 100% of the whole building’s embodied and operational emissions for all the buildings within the organisation’s portfolio in the base year. This applies across all building typologies and geographies.

If emissions from a building or group of buildings are no longer relevant to the portfolio — for example, due to divestment from a particular typology or geography — the organisation must either change the base year or recalculate the base year emissions.

Please note, in accordance with the GHG Protocol, organisations may exclude up to 5% of total emissions from their emissions inventory. Emissions from buildings may be excluded from the target boundary if they fall within this allowable threshold. However, data unavailability cannot be considered a valid reason for exclusion. Emissions must be estimated using a reasonable and transparent methodology to demonstrate that they represent less than 5% of total emissions.

Embodied carbon targets

Upfront embodied emissions targets, if applicable to the organisation, can only be set using the Buildings Sector Tool if they categorise the upfront embodied emissions in Capital Goods, at practical completion. If the company categorises these under Purchased Goods and Services, in the year the emissions occur, the Buildings Sector Tool cannot be used, and targets must be set using the cross-sector methods.

Timeline and validation cycle

The SBTi validation cycle follows a streamlined and standardised process that begins once the contract is signed, and a Lead Reviewer is assigned. From this point, the review period typically spans 30 days and includes two rounds of review. In the first round, the Lead Reviewer assesses the submission and flags any issues. Once those are resolved, the application undergoes a peer review for final approval. Organisations must ensure that they review and sign the contract as soon as it is issued to avoid delaying the target validation certificate, which is essential to publicly declaring the net-zero target.

Net-zero strategy

Organisations are required to provide an overview of the measures they will implement to meet their net zero targets across all scopes. With the release of the draft Corporate Net Zero Standard update, it is evident that scrutiny around target ambition will increase. Notably, the draft proposes that Transition Plans aligned with the recommendations of the UK Transition Plan Taskforce (TPT) may be required for target setting under the revised Standard. This makes it vital for organisations to develop well-defined, ambitious and actionable transition strategies. This will ensure that the necessary investments, governance structures, and operational changes are implemented to meet the targets over time.

As your organisation gears up to set SBTi targets, look out for our event to learn more about the real-world application of the Buildings Criteria.