Exploring Challenges and Potential Solutions FEBRUARY 2026|WHITEPAPER About This Report This report summarizeskey research findings from the Scope 3 for Software (S34S) Roundtableon challenges and solutions for software use-phase emissions.The report exploresthe complex To inform this report, theS34S Roundtable conducted desktop research,interviewswithkeyecosystem stakeholders (including cloud providers, accounting providers, industry coalitions, The S34S Roundtable is acohortof leading software companies, includingAVEVA, Coupa, This report was written byAriela Levyand Ameer Azimwith additional guidance and insights Disclaimer BSR publishes occasional papers as a contribution to the understanding of the role of businessin society and the trends related to corporate social responsibility and responsible business Working papers contain preliminary research, analysis, findings, and recommendations. Theyare circulated to stimulate timely discussion and critical feedback and to influence ongoing Suggested Citation Levy et al.February2026.“Accounting for Scope 3 Use-Phase Emissions for Software Companies.” Contents Introduction Scope 3Accounting ofUse-PhaseEmissionsof WhatAretheKeyChallenges? Scope 3 emissions from the use phase of software products (Category 11,orC.11, under theGreenhouseGasProtocol) have emerged as a critical issue given the expansion of softwareadoption and growing computational intensity. C.11 requires accounting of Scope 1 and Scope 2 Comparable and consistent accounting for cloud-based emissions remains constrained by theabsence ofclearmethodologiesbased on common standards. While theGreenhouse Gas(GHG)Protocol provides guidance for calculating operational emissions under C.11, detailedguidance for cloud emissions iscurrentlyinsufficientand does little to incentivizeadoptionthatscalesbestpractices. These challenges are compounded by limited transparency from cloud Companies are increasingly recognizing the importance of resolving this challenge. Customersand investors are requesting product-and customer-specific data more frequently.In parallel,ascompanies implement early decarbonization actions, access to accurate data becomesincreasingly important to track progresstoward net-zero targets.At the forefront remains theneed to address questions around operational control and who ultimately owns the service (e.g.,the software provider, or the customer),and thereforethe party responsible formanaging theseGHG emissions.Forexample,emissionsfrom cloud services and subscriptions procured WhyDoesItMatter? Use-phase emissions are increasingly critical in thesoftware world, particularly with the rapid adoptionof AI. Use-phase emissions tied to cloud estimate56-80percentof the ICT sector’s total life cycle impact can be attributed to the usephase).The expansion of AI and cloud workloads is creating unprecedented energy demandand emissions growth (in part due to the currentglobal energy mix).From 2020 to 2023, digital companies byUS$13-16 trillionin the long term, indicating the extent of its expectedproliferation. With policy headwinds and waningglobalclimate commitments,impacts on globalemissionsare predicted tobe severe.At the same time, customers and investors are Taken together, these trends underscore a critical truth: the growing scale and opacity ofsoftware use-phase emissions, especially in the AI and cloud era, make accurate, granular data transparency, neither practitioners nor customerscan credibly understand or reducethe climate A Note on SoftwareLifecycle Emissions While C.1 versus C.11accounting and measurementchallenges focus on usephase emissions, it isimportant to contextualizesoftware use phase emissionswithin the greater software Bridging this gap will require shared learning withstandard setters to clarifyguidance onmeasurement and accounting for C.11 versus C.1,bringing software guidance in line with how Research Findings Software companies are divided on the use of C.11 accounting, and approaches to C.1 versusC.11 continueto vary greatly. Few companies actively calculate C.11, citing lack of operational and lack of clear and consistent standards and guidance. At the same time, many softwarecompanies, accounting providers, and industry coalitions engaged in interviewssee little In general, hosting environmentstend to drive accounting decisions. Primarily,companies whoretain some on-premise(on-prem)infrastructure calculate C.11, while companies who mainlyleverage cloud hosting are more likely to focus on C.1.In part,this is because companies haveclearer operational control over on-preminfrastructure, while in cloud environments,they lackboth operational control and access to the data needed from suppliers for more detailed Throughthediscussions with software companiesandGHGaccounting providers, it became •Supplier-specific factors:Emissions accounting approaches vary widely depending onavailability ofsupplier-specific emissionfactors.Differences exis