Introduction

The GHG Protocol’s ongoing Scope 3 revision could make Category 15 relevant to more companies, not only financial institutions. The proposed Category 16 could also change how companies separate investment emissions from other value chain activities, creating a clearer boundary-setting framework.

For executives, the message is practical. Companies that previously treated Category 15 as a narrow issue may now need to review whether investments, holdings, joint ventures, or similar activities belong more clearly within Scope 3.

Key takeaways

• Category 15 may become relevant across a wider range of companies where investment-related activities are material.
• Category 16 could provide a clearer home for certain other value chain activities that do not fit cleanly into Categories 1 through 15.
• The revision is about classification discipline, reporting completeness, and better comparability.
• Companies should start reviewing category logic, data readiness, and internal governance now.

The Scope 3 Revision Agenda Now Taking Shape

The current Phase 1 progress update shows that the GHG Protocol is revising core parts of the Scope 3 Standard. The main work areas are data quality, boundary setting, and classification and reporting requirements for Category 15 investments.

The update also introduces a proposed Category 16 for “Other value chain activities” not captured in Categories 1 through 15. While the revision is still in progress, the direction is already clear. Companies should expect a more disciplined Scope 3 framework with clearer rules on inclusion, exclusion, and category interpretation.

Key Proposed Changes in the GHG Protocol Scope 3 Revision

Revision area	Current direction of change	Why it matters
Category 15 classification	Investment-related emissions may be clarified more explicitly, and Category 15 may apply across all companies where relevant rather than being treated mainly as a financial-sector issue.	More companies may need to assess whether holdings, joint ventures, strategic investments, or similar relationships belong within Scope 3.
Category 16 proposal	A new Category 16, “Other value chain activities,” is proposed for activities not captured in Categories 1 through 15.	This could create a clearer boundary for activities that do not fit cleanly into the current Scope 3 structure.
Boundary setting	The revision places stronger emphasis on how companies define what belongs inside or outside the Scope 3 inventory.	Classification decisions may require more internal documentation and stronger cross-functional governance.
Completeness threshold	Companies may need to report at least 95% of total required Scope 3 emissions, limiting exclusions to 5% of required emissions.	This raises the bar for inventory completeness and could narrow the room for omission.
Exclusions	The revision signals stricter treatment of what can be excluded from required Scope 3 emissions.	Companies may need to revisit whether current exclusions remain defensible under the revised framework.
Reporting by data type	Reported Scope 3 emissions may need to be disaggregated by data type instead of being described mainly through qualitative methodology summaries.	Stakeholders would gain greater visibility into data quality, comparability, and the balance between more specific and less specific inputs.

Category 15 Is Becoming Relevant to More Companies

One of the most important signals in the revision is that Category 15 may apply to all companies where relevant, rather than being treated mainly as a financial-sector topic. That could expand the number of companies that need to assess investment-related emissions.

Many organizations have historically viewed Category 15 as something for banks, asset managers, or insurers. The current revision suggests a broader relevance-based approach. That means companies outside the financial sector may also need to assess ownership interests, holdings, strategic investments, or joint venture relationships.

For executive teams, this shifts Category 15 from a sector-specific issue to a corporate boundary-setting issue. The key question becomes whether the company has relevant investment-related emissions, not whether it identifies as a financial institution.

Category 15 Today and What the Revision May Change

Today, Category 15 is the Scope 3 category for emissions from investments. In practice, it has been most visible in the context of financial institutions, which is why many non-financial companies have paid limited attention to it.

The current revision suggests that this understanding may be too narrow. Category 15 may continue to cover investment-related emissions, but the rules around which entities should assess it and which activities belong there could become clearer and broader.

What may change:

• Category 15 may be treated as relevant to all companies where investment-related emissions are material.
• The classification logic for what belongs in Category 15 may become more explicit.
• Companies may need to review whether current exclusions or assumptions are still defensible.

This matters because a clearer Category 15 framework could improve comparability and reduce inconsistent reporting. It may also push more companies to review holdings, strategic investments, treasury-related exposures, and joint venture structures more carefully.

The Proposed Category 16 and Its Role in Scope 3

The proposed Category 16 would create a new reporting category for other value chain activities not currently captured in Categories 1 through 15. Its purpose is to improve Scope 3 boundary setting by giving certain emissions sources a clearer place in the framework.

The proposal is significant because some activities do not fit neatly within the current Scope 3 structure. Category 16 is intended to capture these unmatched or borderline activities rather than forcing them into categories where they do not belong.

In this context, facilitated activities generally refer to third-party activities or products that:

• are not owned or controlled by the reporting company
• are not purchased or sold by the company
• are not already covered by another Scope 3 category
• still generate transaction-related income for the company
• are directly or indirectly enabled, initiated, or substantially influenced by the company

This is why activities such as underwriting, issuance, insurance-related services, or advisory roles may come into the Category 16 discussion. They can create emissions linked to the company’s business activity even when they do not qualify as investments under Category 15.

How Boundary Setting Could Shift Between Category 15 and Category 16

The most important shift is that Category 15 and Category 16 could work together to create a more precise classification system. Category 15 may become more broadly relevant, while Category 16 may provide a clearer place for activities that are connected to the value chain but are not best treated as investments.

In practice, companies may need to separate:

• emissions tied to investment relationships
• emissions tied to facilitated or other adjacent value chain activities
• emissions that do not fit cleanly within the existing Category 1 through 15 structure

The current revision direction suggests that some activities under discussion, including underwriting, advisory services, insurance contracts, derivatives, cash deposits, and cash equivalents, may not remain within Category 15 in the same way under a revised framework. That could make Category 15 more precise without removing those emissions from the reporting discussion.

What Category 15 and Proposed Category 16 Include

Category 15

Investments

Category 15 covers investment-related emissions. Under the current revision direction, it may be treated as relevant to all companies where those emissions are material.

Includes

• Investment-related emissions
• Holdings and ownership interests
• Strategic investments
• Joint venture relationships
• Other relevant investment exposures

What it signals now

The revision may broaden awareness of Category 15 beyond financial institutions and make its classification logic more explicit.

Proposed Category 16

Other value chain activities

Category 16 is proposed for activities not captured in Categories 1 through 15. It is intended to create a clearer home for certain unmatched or borderline activities.

May include

• Facilitated activities
• Underwriting
• Advisory services
• Insurance contracts
• Derivatives, cash deposits, and cash equivalents under discussion

Facilitated activities

Third-party activities or products that are not owned, controlled, purchased, or sold by the reporting company, but are enabled, initiated, or substantially influenced by it and still generate transaction-related income.

New Reporting Expectations Emerging from the Boundary Update

The proposed category changes sit alongside broader reporting reforms. These include a 95 percent completeness threshold, tighter exclusion logic, and more transparent disclosure of data quality.

For companies, the practical implications could include:

• stricter limits on excluded Scope 3 emissions
• more explicit disclosure of data type and methodology
• greater pressure to support classification decisions with stronger documentation
• higher expectations for internal controls and assurance readiness

This means Category 15 and Category 16 decisions will affect more than category labels. They may also influence completeness calculations, data collection strategies, and audit preparation.

What Executive Teams Should Do Now

Executive teams should treat the current update as an early signal to test assumptions before the final standard is issued. The first priority is to review whether Category 15 is relevant to the company’s activities and whether any current exclusions rely on assumptions that may not hold under a revised framework.

Companies should also identify adjacent activities that may become relevant under Category 16 and assess whether current classification methods remain defensible. At the same time, sustainability, finance, legal, and audit teams should align on a common interpretation of boundary setting so the company can respond consistently when the consultation draft and final revisions are released.

Early preparation will put companies in a stronger position to handle more granular reporting requirements, tighter completeness expectations, and greater scrutiny of classification logic. More importantly, it will help executive teams build Scope 3 disclosures that are more credible, comparable, and decision-useful.

What Executives Should Do Now

1. Review Category 15 applicability. Assess whether investments, holdings, joint ventures, or similar relationships should be evaluated more explicitly within Scope 3.
2. Reassess current exclusions. Test whether existing assumptions remain defensible under tighter completeness and boundary-setting expectations.
3. Identify potential Category 16 activities. Map adjacent or facilitated activities that may not fit cleanly within Categories 1 through 15.
4. Align internal teams. Build a common interpretation framework across sustainability, finance, legal, and audit functions.
5. Prepare reporting systems. Evaluate whether data processes can support more granular data-type disclosure and stronger documentation.

Conclusion

The GHG Protocol’s ongoing Scope 3 revision suggests that Category 15 may become relevant to more companies than before, while the proposed Category 16 may create a clearer boundary for other value chain activities. Together, these changes point toward a more disciplined approach to classifying indirect emissions.

For executive decision makers, the next step is clear. Reassess Category 15 applicability, review where Category 16 may affect classification, and strengthen carbon accounting governance before the revised Scope 3 Standard is finalized.

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