AustraliaServices ESG & sustainabilityScope 3 supplier data pack

ESG & sustainability

Scope 3 supplier data pack for Australian businesses

Your Group 1 customer asked for emissions data — the pack that answers them, built from records you already have.

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What is scope 3 supplier data pack?

Your Group 1 customer asked for emissions data — the pack that answers them, built from records you already have.

The trigger for this pack is almost always the same email: a customer who is now a mandatory climate reporter under AASB S2 has sent a supplier questionnaire asking for emissions data, usually framed as "your emissions associated with the goods or services you supplied us this year." The customer needs that number because it has to disclose its own Scope 3 emissions — the indirect emissions in its value chain, which for most companies buying goods and services from suppliers falls into Category 1: Purchased Goods and Services under the GHG Protocol Corporate Value Chain (Scope 3) Standard. The supplier receiving the email is very often a business with no AASB S2 obligation of its own — Group 1 entities are large, listed or NGER-registered companies meeting a threshold two-of-three test, and most suppliers sit well under it. The obligation belongs to the customer; the data request is what lands on the supplier's desk regardless.

Under the Treasury Laws Amendment Act 2024 and ASIC's Regulatory Guide 280, mandatory sustainability reporting is phased in across three groups. Group 1 — the largest listed and NGER-registered entities — is reporting now, with first statutory climate statements lodged with the financial report for financial years starting on or after 1 January 2025; for a June-year-end Group 1 reporter that means a first lodgement around 2026-09-30. Group 2 picks up from financial years starting 2026-07-01, and Group 3 — a smaller two-of-three test of $50 million revenue, $25 million assets or 100 employees — from financial years starting 2027-07-01. A supplier doesn't need to track any of those thresholds to receive a data request; the customer's group status is what determines when the request arrives, and Group 1 customers are the ones already sending them.

Who does what

CapEasy prepares the data pack; anything lodged or assured runs through your registered agent and an AUASB-registered assurance practitioner respectively.

Who does what

Your CapEasy teamScope 3 supplier data pack, the reconciliations and reporting behind it, and the questions list that keeps it honest.
Your registered BAS or tax agentEverything that carries a licence in Australia — rendered exactly as written: work out what goes on your bas, or advise you on it — under tasa 2009 that requires registration we do not hold.
YouOne conversation with one named person, and the decisions that are genuinely yours.

Scope 3 supplier data pack in Australia

The supplier answering the request usually has no AASB S2 obligation of its own

Mandatory climate reporting under the Treasury Laws Amendment Act 2024 applies to Group 1, 2 and 3 entities defined by size and NGER-registration thresholds — a two-of-three test of revenue, gross assets and employee count, checked against ASIC Regulatory Guide 280. Most suppliers receiving a data request from a Group 1 customer sit under every one of those thresholds and are not themselves required to report anything to ASIC. The request is a customer relationship matter, not a regulatory one, until and unless the supplier's own size crosses a Group threshold — which is a separate question this pack does not answer.

Scope 3 sits inside a three-year modified liability window, and the pack is built to survive it ending

The Corporations Act gives Group 1 reporters modified liability protection on Scope 3 emissions, scenario analysis and transition-plan statements for their first three reporting years from the 2025-01-01 effective date — regulator-only enforcement, not private action, while Scope 1/2 and governance disclosures carry full liability from year one. That protection belongs to the customer's own disclosure, not to the supplier's pack, but it shapes what the customer needs from a supplier now: a defensible, clearly labelled calculation basis they can stand behind once the window closes, not a number that only holds up while nobody is checking it.

Spend-based estimates are a recognised GHG Protocol method, but they have to be labelled as estimates

The GHG Protocol Scope 3 Calculation Guidance explicitly permits spend-based calculation — applying a recognised emission factor (dollars spent per category, converted to CO2-e) — as a legitimate method where supplier-specific data isn't available, which covers most SME suppliers on their first data request. What the standard doesn't permit is presenting a spend-based estimate as if it were a supplier-specific measurement. Every line in the pack states its method, so the customer's reporting team knows which figures came from a metered bill or an itemised freight docket and which came from a category total run through a published factor.

Scope 1 and 2 run off NGER emission factors, updated every year

The National Greenhouse and Energy Reporting scheme publishes the emission factors that convert litres of fuel and kilowatt-hours of grid electricity into tonnes of CO2-e, and those factors are revised annually as the grid's generation mix changes. A pack built on last year's factor set understates or overstates the current year's emissions depending on which way the grid moved; we pull the current NGER factor set for the reporting period the customer asked about, not whatever factor happened to be cached from a previous job.

What your registered BAS or tax agent receives from us

  • A Scope 1 and 2 emissions summary for the requested reporting period, calculated from fuel and electricity invoices against the current-year NGER emission factors.
  • A Scope 3 Category 1 (Purchased Goods and Services) calculation covering the goods or services actually supplied to the requesting customer, method-labelled line by line as supplier-specific or spend-based.
  • The activity data behind every figure — litres, kilowatt-hours, freight distances, spend totals by category — traceable back to the source invoice or bill.
  • A calculation-basis note stating which GHG Protocol method (supplier-specific, spend-based, or hybrid) was used for each Scope 3 line, so the customer's reporting team can assess data quality on their end.
  • The emission factors applied — NGER factors for Scope 1/2, the published spend-based factor set for Scope 3 — cited by source and vintage.
  • A completed copy of the customer's own supplier questionnaire where one was supplied, populated from the calculation above rather than answered from memory.

Questions worth asking before you start

Who actually does the work — a person or an AI tool?

A named person on our team owns your file and reviews everything that leaves it. Software does a real share of the grinding underneath it — coding, matching, flagging the obvious gaps — but nothing regulated happens without a person’s judgement, and nothing here is signed or filed by an algorithm.

Who can legally lodge this?

CapEasy prepares the data pack; anything lodged or assured runs through your registered agent and an AUASB-registered assurance practitioner respectively.

Which software do you work in?

Whatever you already run. Most commonly QuickBooks, Xero, NetSuite, Sage, Zoho Books and a handful of others — we work inside your system rather than moving you onto one of our own.

How does this actually start?

A short, free read-only look at what you already have, and a written note on what we found. A scoping call decides the size of the engagement — nothing here commits you to anything.

What does it cost?

There is no published price for scope 3 supplier data pack — it depends on volume, how many entities are involved, and how far behind the books are. We quote after the read-only review, which is free.

How does this fit with the rest of esg & sustainability?

Scope 3 supplier data pack sits inside esg & sustainability, alongside AASB S2 readiness assessment, Group 3 “no material risk” statement prep. Most clients end up buying the category as a whole rather than one leaf at a time, but starting narrow is fine.

Our customer sent us an emissions questionnaire. Do we legally have to answer it?

There's usually no statutory obligation on the supplier — Group 1 reporting duties under AASB S2 sit with the customer, not with you, unless your own business independently crosses a Group threshold. The commercial reality is that the customer needs this data for their own mandatory disclosure, and answering it well is what keeps the relationship and the contract on good terms.

Does this mean our business is now subject to AASB S2?

Not from answering a data request alone. AASB S2 applies to Group 1, 2 and 3 entities defined by their own size and NGER-registration thresholds under the Treasury Laws Amendment Act 2024. If the numbers in your own business suggest you're approaching a Group 3 threshold, we'll flag that separately — it's a different assessment to this pack.

What exactly is 'Scope 3 Category 1' and why is that the one our customer keeps asking about?

Category 1 — Purchased Goods and Services — is one of 15 categories in the GHG Protocol Corporate Value Chain (Scope 3) Standard, and for most companies it's the largest single category in their value-chain emissions because it covers everything they buy. If you supply your customer with goods or services, your emissions in producing and delivering them sit inside their Category 1 number, which is why they're asking you directly rather than estimating it themselves.

What's the difference between a supplier-specific and a spend-based calculation?

Supplier-specific means the figure comes from your own metered or measured activity data — a fuel receipt, an electricity bill, an actual freight distance. Spend-based means a dollar total for a purchase category is run through a published emission factor to produce an estimate, which is the realistic starting method for most SME suppliers on their first request. Both are recognised under the GHG Protocol; the pack labels which one applies to each line so nobody mistakes an estimate for a measurement.

We don't track our emissions at all — can you still build this from scratch?

Yes, that's the normal starting point. We build the calculation from invoices, utility bills and accounting records you already have — fuel receipts, electricity bills, purchase categories — rather than requiring a metering or monitoring system to already exist.

How far back does the customer's request usually go?

Almost always one reporting period — the customer's own financial year, or the specific period named in their questionnaire. We calculate against whichever period the request actually asks for and use the emission factors current to that period, not a generic annual estimate.

Will this pack get audited or assured by anyone?

Not as part of this engagement. The pack is prepared data for a customer request, not a lodged or assured disclosure. If your own business later needs a statement that does require assurance, that runs through an AUASB-registered assurance practitioner as a separate, later engagement.

What if we get the same request from three different customers with different questionnaire formats?

The underlying calculation — Scope 1, 2 and Category 1 Scope 3 for the reporting period — is built once and populated into whichever format each customer's own questionnaire uses. You're not redoing the calculation for every customer, just re-presenting it.

Can this pack double as a first step toward our own AASB S2 readiness if we end up in scope later?

It's a useful head start — the Scope 1/2 baseline and the purchased-goods Scope 3 data carry forward — but AASB S2 readiness is a broader assessment covering governance, strategy, risk and scenario analysis, not just emissions data, and that's a separate leaf with its own scope.

Our customer's questionnaire asks about a target or a reduction plan. Do you handle that too?

This pack covers the emissions data itself. A stated reduction target or transition plan is a strategic commitment your business makes, not a figure we calculate on your behalf, and we'd flag that distinction rather than fill in a target for you.

What happens to the emission factors and methodology a year from now, when the same customer asks again?

The next year's pack is calculated against the current NGER factor set and current GHG Protocol guidance for that period, not carried forward unchanged — factors are revised annually, and reusing an old figure would misstate the new period.

Your CapEasy experts

Connect with us

Talk to the people who handle this work every day — no call centre, no hand-offs.

Ayush Joshi

Ayush Joshi

Co-Founder

Ex-OYO and Tenaciousfly. 7+ years in business development, strategic acquisitions, financing and debt syndication.

Aditya Jain

Aditya Jain

Co-Founder

Ex-Bank of America. 4+ years in investment banking, EU & Indian compliances, ESG compliances, and project management.

Manav Raval

Virtual CFO & Tax Specialist

Section 80-IAC, tax planning and startup compliance. Previously at Toyota Motor Corporation and Jaguar Land Rover.

Ayush Faldu

Virtual CFO & Tax Specialist

Financial strategy, budgeting and cash flow — a CFO’s judgement, monthly.

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