The Scope 3 Black Hole: How Landlords Can Realistically Track Tenant Energy Use

The Direct Answer

Landlords do not need to wait for every tenant to provide perfect energy data. A useful inventory starts with four things: a clear reporting boundary, a register linking tenants to meters, a repeatable collection process and a transparent way to estimate missing consumption.

Where operations in a landlord’s leased assets fall outside its Scope 1 and 2 boundary, the associated emissions may belong in Scope 3 Category 13, downstream leased assets. The classification depends on the consolidation approach and leasing arrangements; it is not determined simply by whose name appears on the electricity bill.¹ ²

The immediate objective is a traceable record that improves each year. An estimate with a stated basis is useful. A blank cell silently treated as zero is not.

First Decide Whose Emissions You Are Measuring

Before requesting bills, agree the accounting boundary with the people responsible for the corporate inventory. GHG Protocol recognises equity-share, financial-control and operational-control approaches. These can produce different classifications for leased assets. Apply the organisation’s chosen approach consistently and document the reasoning for each building.¹

A simple decision path helps keep the discussion focused:

Apply this separately to base-building services, tenant-controlled equipment, shared cooling and separately supplied electricity. A central chiller and a tenant’s server room should not be assigned to a scope merely because they occupy the same building. Record who operates the equipment, what each meter covers and how the chosen boundary applies.

The same electricity can legitimately appear in a tenant’s Scope 2 and a landlord’s Scope 3. That overlap between organisations is different from counting the same source twice within one landlord’s inventory.¹ ²

This article focuses on energy data. A complete leased-asset inventory may also need relevant fuel, refrigerant leakage and other operational emissions; an electricity spreadsheet alone does not establish completeness.³

Why the Data Goes Missing

Tenant energy data is often fragmented across utility accounts, facilities teams and lease records. A landlord may see common-area bills while tenants hold the accounts for their own units. A meter might serve several spaces, or continue under an old identifier after a tenant moves out.

The first practical task is therefore a meter–tenant register: building, unit, tenant, meter identifier, supply type, data holder and tenancy dates. Record whether a meter measures a whole building, a shared service or an individual tenant load. Include replacements, vacant periods and changes in occupation.

A building management system can help, but first check what it actually measures. Visibility of central plant does not prove that every tenant socket, supplementary air-conditioning unit or server room is captured. Compare the system’s coverage with the electrical layout and the bills.

This diagnostic work connects with The 30-Day Energy Audit: understanding how a building uses energy provides the foundation for deciding where better measurement is needed.

A Practical Hierarchy for Closing the Gap

GHG Protocol’s leased-asset guidance allows asset-specific data, allocation from a counterparty’s aggregated data and average-data estimates. Category 13 refers to the calculation methods in Category 8.² ³ The following is a practical implementation order, rather than a separate accounting standard:

Benchmark choice matters. An office average is a poor substitute for a laboratory, cold store or round-the-clock operation. Match the activity, location and period as closely as the available evidence allows, and record the limitations.³

For a short missing period, consider whether adjacent readings genuinely represent the same operating pattern. A month of fit-out works should not automatically stand in for normal occupation. Keep the original gap visible alongside the replacement estimate.

For shared services, show how the allocations add back to the measured total. Reconcile differences before combining them with tenant records. In particular, do not add allocated central cooling to the landlord’s Category 13 calculation if those same emissions are already included in its Scope 2 boundary.

Turn a Data Request into a Tenant Process

A request for “your annual carbon data” leaves too much room for interpretation. A shorter, specific request is easier to act on:

Please provide monthly electricity consumption in kWh for [unit and meter identifiers], covering [start date] to [end date], through [secure submission route] by [deadline]. Please identify missing or estimated readings and any changes to meters or occupation.

Explain why the data is needed, who will access it and how results will be aggregated. Ask for consumption and enough supporting information to validate it, without collecting unnecessary personal details, payment information or commercially sensitive material.

Agree the sharing permissions and lease provisions with tenants and legal advisers. Check the existing agreement before assuming there is a right to obtain bills or access a tenant’s utility account. Where the lease does not provide a clear process, seek an agreed arrangement.

Renewals and fit-outs are useful opportunities to specify meter coverage, submission frequency, responsibilities and how data will be handed over when the occupier changes. Keep those requirements workable for the tenant’s facilities team.

Give something useful back. A monthly trend, an unexpected overnight load or a comparison with the tenant’s own previous performance can turn collection into a conversation about operating costs. Assign a named contact on both sides so queries do not disappear between finance, property management and sustainability teams.

Convert kWh into a Defensible Emissions Number

For an electricity calculation using a factor expressed in kilograms per kWh:

Electricity consumption (kWh) × emission factor (kg CO₂e/kWh) ÷ 1,000 = emissions (tonnes CO₂e).

For illustration only, 100,000 kWh multiplied by an assumed factor of 0.40 kg CO₂e/kWh gives 40 tonnes CO₂e. The 0.40 factor is hypothetical, not a stated Singapore grid factor.

For Singapore grid-based calculations, refer to EMA’s published grid-emission data and select the factor appropriate to the reporting year and methodology. Record its year, units and greenhouse-gas coverage. If a source reports CO₂ rather than CO₂e, preserve that distinction and address other gases where the reporting methodology requires them. Do not apply the latest factor retrospectively to every historical year.⁴

Keep the evidence behind the result: original readings or bills, calculation versions, allocation decisions, factor sources and review sign-offs. If better data replaces an estimate, record the change so an apparent reduction is not mistaken for an operational saving.

Renewable-energy claims require a separate evidence check. Where a market-based treatment is applicable, contractual instruments must meet the relevant quality criteria; ownership, retirement and matching to the consumption period matter. A certificate does not establish how much energy an unmetered tenant used, and it should not simply erase a missing load. Document the treatment used in the leased-asset inventory.⁵

The First 90 Days: Build Coverage, Then Improve Quality

The following is a proposed delivery plan, to be adapted to the portfolio and the availability of tenant data. It is not a guaranteed Savills service timetable.

Days 1–30: establish the starting position. Approve the boundary, build the meter–tenant register and identify the largest likely gaps. Assign an owner for each unresolved source and agree what evidence will be accepted.

Days 31–60: test the process. Pilot collection with a small group covering different tenancy arrangements. Check permissions, reporting periods and units; reconcile meters and bills; resolve duplicated or unexplained consumption before expanding.

Days 61–90: increase coverage. Extend the process to the remaining tenants, document estimates and prioritise metering investment. Base priorities on likely energy use, uncertainty and the cost of improving the data.

Use a dashboard that makes progress measurable:

A portfolio can cover all its leased area while relying heavily on estimates. Reporting both coverage and data quality prevents “90% complete” from implying more certainty than the evidence supports.

The Tenant Energy Readiness Checklist

Before closing the reporting cycle, confirm that:

• The reporting boundary has been approved and recorded.
• Tenants, meters, supply types and occupancy dates are mapped.
• Data-sharing permissions and responsibilities are agreed.
• Actual consumption has been collected and checked.
• Estimates have a stated method, source and limitation.
• Shared loads reconcile and duplicate counting has been removed.
• Emission factors and calculation versions are retained.
• Each remaining gap has an improvement owner.

The value of this process extends beyond an emissions total. It gives the landlord a clearer view of where energy is used, where evidence is weak and which improvements deserve attention first.

Speak to Savills Energy & Sustainability Management

Savills’ Energy & Sustainability Management services include energy audits, efficiency gap analysis and periodic reporting with analytics. These capabilities provide a practical starting point for understanding building performance and the quality of the data behind it.

Speak to the team about assessing your meter coverage, tenant-data gaps and a phased plan for improving energy reporting. The aim is an inventory that can be explained, checked and improved—and a collection process that tenants and property teams can sustain.

Footnotes

¹ GHG Protocol, Categorizing GHG Emissions Associated with Leased Assets, Appendix F; and landlord electricity pass-through FAQ. Classification depends on the organisational boundary and leasing arrangements.

² GHG Protocol, Technical Guidance for Calculating Scope 3 Emissions: Category 13, Downstream Leased Assets, pp. 128–129. Covers leased-asset operations outside the lessor’s Scope 1 and 2 and refers to Category 8 calculation methods.

³ GHG Protocol, Category 8, Upstream Leased Assets, pp. 94–101. Calculation methods, activity data, allocation and average-data estimates, as referenced by Category 13. The implementation hierarchy and 90-day plan in this article are editorial recommendations.

⁴ Energy Market Authority, Singapore Energy Statistics, Chapter 2: Energy Transformation, Grid Emission Factor section. Use the appropriate reference year and preserve the source’s units and gas coverage.

⁵ GHG Protocol, Scope 2 Guidance, Chapter 7 and Table 7.1, contractual instruments and Scope 2 Quality Criteria. Apply the accounting guidance relevant to the reporting period; do not treat proposed revisions as adopted requirements.