How to use this
Do not send this whole list to anyone. Send each group to the person who owns it — company secretary, facilities, finance, procurement, sustainability — with a date. A list of forty items sent to one person produces nothing; five lists of eight items sent to five people produce a disclosure.
Work through it before you start drafting. The purpose is to discover what is missing while there is still time to get it, rather than while you are writing.
1 — Governance evidence (company secretary)
Board or committee terms of reference
Showing sustainability and climate oversight explicitly, with the date the responsibility was assigned.
Minutes recording consideration
Dates on which the board or committee discussed sustainability matters, and what was decided. Not a standing agenda item with no substance.
Management responsibility
Named role accountable, reporting line, and how information reaches the board.
Skills and competencies
How the board satisfied itself that appropriate skills are available — training undertaken, advisers engaged, or committee composition.
Target-setting oversight
Where targets exist: evidence that the board approved them and reviews progress.
2 — Activity data (facilities and operations)
Electricity consumption, every site, every month
In kilowatt-hours, per meter, for the full reporting period. Gaps identified rather than estimated silently.
Generator fuel, per generator, every month
In litres, by fuel type. This is usually your largest source — do not accept a site-level total if per-generator is obtainable.
Other stationary fuels
Gas, LPG, HFO for boilers, kilns, dryers and furnaces.
Fleet fuel
From fuel cards or pump records, by vehicle where possible.
Refrigerant top-ups
Type and quantity of any refrigerant added during the period — the proxy for leakage.
Process data
Where you have process emissions: production volumes and the inputs that drive the chemical release.
3 — Source documents (whoever holds them)
Utility bills
The actual bill for each period, not a transcription. This is the evidence behind every Scope 2 figure.
Fuel delivery notes and invoices
Ideally showing site and date of delivery.
Generator log sheets
Photographs of the paper log are acceptable evidence and far better than nothing.
Supplier responses
For Scope 3: what was asked, what was returned, and when.
Meter readings and reconciliations
Where you read meters directly rather than relying on billed consumption.
4 — Method decisions to record (sustainability and finance)
Consolidation approach
Operational control, financial control or equity share, and why. Applied consistently.
Reporting boundary
The list of entities and sites inside it, and the basis for anything excluded.
Emission factors and versions
Which factor for each activity, from which source and publication year.
Global warming potentials
Which IPCC assessment the values came from.
Scope 3 materiality assessment
How each of the fifteen categories was assessed, which were judged material, and the basis for excluding the rest.
Estimates and their methods
Every figure that was estimated rather than measured, and how.
Restatement policy
What you will do when a factor is revised. Decided in advance.
5 — Narrative sections and who writes them
Governance description
Company secretary. Describes what actually happened, so it is written from the minutes.
Risks and opportunities
Risk function with sustainability input. Must connect to the enterprise risk register rather than sit beside it.
Effects on business model and strategy
Strategy or finance. The section investors read most closely.
Climate resilience and scenario analysis
Whoever ran it. Method disclosed, and it should have informed a decision.
Targets and progress
Sustainability, approved by the board. Base year, boundary, scope coverage and milestones stated.
Basis of preparation
Finance. This is the section an assurance provider reads first and the one most often missing.
Pre-submission checks
Before it goes anywhere: every required disclosure answered or explicitly omitted with a reason; totals reconciled to components; intensity figures sense-checked against the prior period; every estimate labelled; sign-off recorded against the version being filed; and a copy of that exact version retained unaltered.
Questions
What if we cannot get some of this?
Record the gap, the reason and what you are doing about it. Every first cycle has gaps. A disclosed gap with a remediation plan is a legitimate disclosure; a silently missing item is not, and it is the first thing a reviewer notices.
How far back should the source documents go?
The full reporting period, plus the comparative period once you have one. Retention should match your financial records policy — assurance providers may test several years back.
Can we use this checklist if we are not filing yet?
It is arguably more useful then. Running it a year early tells you exactly what you are not currently collecting, which is the entire point of a dry run.
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