FCAACSCFEIBBI/RV/03/2019/12333
Virtual Auditor

Carbon Accounting & GHG Inventory Services

By CA V. Viswanathan β€” FCA, ACS, CFE, IBBI Registered Valuer (IBBI/RV/03/2019/12333). Updated for FY 2025-26.

A greenhouse gas (GHG) inventory is the foundation of every credible climate disclosure. Whether you are reporting under BRSR Core, preparing for the EU Carbon Border Adjustment Mechanism (CBAM), targeting science-based climate goals (SBTi), or responding to a customer's Scope 3 questionnaire, you need a defensible GHG inventory built to ISO 14064-1:2018 or the GHG Protocol Corporate Standard. Virtual Auditor builds GHG inventories for Indian companies across manufacturing, IT/ITES, financial services, and infrastructure sectors.

Scope 1, 2, 3 β€” Categorisation and Calculation Basis

Scope 1 covers direct emissions from sources owned or controlled by the company: fuel combustion in boilers, vehicles, generators; process emissions; fugitive emissions from refrigerants. Calculated using activity data (litres of diesel, kg of refrigerant lost) multiplied by published emission factors (IPCC 2006 Guidelines, India GHG Programme). Scope 2 covers indirect emissions from purchased electricity, heat, steam. Calculated using either location-based factors (state-grid emission factor from CEA's annual CO2 baseline database) or market-based factors (supplier-specific factors where renewable PPAs apply). Scope 3 covers 15 categories of value-chain emissions β€” purchased goods, capital goods, fuel and energy, upstream transportation, waste, business travel, employee commuting, upstream leased assets, downstream transportation, processing of sold products, use of sold products, end-of-life treatment, downstream leased assets, franchises, investments. Most Indian companies materially under-report Scope 3 because of weak data architecture.

Why CBAM Now Matters for Indian Exporters

The EU's Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase from 1 January 2026. Indian exporters of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity to the EU must now report embedded emissions per tonne and pay carbon levies based on the EU ETS price. Default values are no longer accepted from 2027. Companies must build product-level Life Cycle Assessment (LCA) calculations from primary data, verified by an accredited verifier. For an Indian steel exporter shipping 100,000 tonnes/year to the EU, CBAM liability could reach β‚Ή150-300 crore annually. Building a verified GHG inventory is no longer a CSR exercise β€” it is a tariff-mitigation imperative.

ISO 14064-1 vs GHG Protocol β€” Which to Choose

GHG Protocol Corporate Standard is the most widely used framework globally and is what BRSR, CDP, SBTi, and IFRS S2 are based on. ISO 14064-1:2018 is the formal international standard, and certification by an accredited body provides third-party verification credibility. For most Indian companies, the practical answer is to apply both: GHG Protocol for the calculation methodology, ISO 14064-1 for the verification regime. Our standard inventory engagement produces an inventory that satisfies both standards simultaneously without rework.

Setting Science-Based Targets (SBTi)

The Science-Based Targets initiative (SBTi) provides a framework for setting emission-reduction targets aligned with limiting global warming to 1.5Β°C above pre-industrial levels. Targets must cover Scope 1+2 (mandatory) and Scope 3 (where Scope 3 exceeds 40% of total emissions). Validation by SBTi takes 6-9 months and requires a baseline GHG inventory, target-setting, and a transition plan. Over 250 Indian companies have committed; only ~70 have validated targets. SBTi-validated targets are increasingly required by global customers (Microsoft, Google, Apple) and major Indian buyers.

Common Calculation Errors We Find

(1) Using stale CEA emission factors β€” the factor for FY 2023-24 is 0.716 tCO2/MWh, materially different from earlier years; (2) Excluding refrigerant fugitive emissions (R-22, HFC-134a) which can be significant for IT companies with extensive cooling infrastructure; (3) Reporting diesel-genset emissions only at peak hours instead of full operating hours; (4) Mixing units (some sites in litres, others in kg, some in BTU) without conversion audit; (5) Double-counting Scope 2 when Scope 3 Category 3 (fuel and energy related activities) is reported. Our verification methodology systematically tests for these errors.

Engagement Models

(a) One-time baseline inventory β€” single financial year, β‚Ή5-15 lakhs depending on number of sites and Scope 3 coverage; (b) Annual inventory and verification β€” recurring engagement with year-on-year comparability, β‚Ή8-20 lakhs/year; (c) Product-level LCA for CBAM β€” per product line, β‚Ή3-8 lakhs; (d) SBTi target-setting and validation support β€” β‚Ή10-25 lakhs over 9-12 months. Pricing depends on number of facilities, geographic spread, data system maturity, and assurance level required.

How Virtual Auditor Delivers This

Virtual Auditor's CA-CS-IBBI Valuer team handles carbon accounting & ghg inventory services as an integrated engagement β€” no hand-offs between firms, single point of accountability, fixed-fee transparency. CA V. Viswanathan (FCA, ACS, CFE, IBBI RV) personally reviews every engagement deliverable. Offices in Chennai, Bangalore, and Mumbai serve clients across India. Free 30-minute scoping consultation available β€” no obligation.

Get Started β€” Book a Consultation

Call +91 99622 60333 or email support@virtualauditor.in to schedule a free 30-minute consultation with CA V. Viswanathan. No obligation. We will give you a clear scope, timeline, and fixed-fee quote within 24 hours of the call.

Frequently Asked Questions

Is a GHG inventory mandatory in India?

Mandatory for top 1,000 listed companies via BRSR Section C disclosures (Scope 1 and 2 essential, Scope 3 leadership). Mandatory for Indian exporters under EU CBAM definitive phase from January 2026. Voluntary but increasingly customer-required for unlisted companies.

What is the difference between location-based and market-based Scope 2?

Location-based: average emission factor of the grid from which electricity is drawn (CEA factor for India). Market-based: emission factor of the specific supplier or contractual instrument (renewable PPA, REC). Companies with substantial renewable energy procurement should disclose both.

How does CBAM affect Indian companies?

Exporters of cement, iron/steel, aluminium, fertilisers, hydrogen and electricity to the EU must report embedded emissions and pay levies based on the EU ETS price. Definitive phase began January 2026. Default values phased out 2027 β€” primary verified data required.

How long does it take to build a GHG inventory?

First-year baseline: 8-12 weeks for a single-entity company; 16-24 weeks for a multi-site multi-business group. Subsequent years: 4-6 weeks for refresh. Verification adds 4-8 weeks.

What are emission factors and where do they come from?

Conversion factors that translate activity data (litres of diesel, kWh of electricity) into emissions (kg CO2-e). Sources: IPCC 2006 Guidelines, India GHG Programme, CEA CO2 Baseline Database, IEA, DEFRA UK. The choice of factor must be documented and consistently applied.

Do we need a GHG inventory if we are not exporting to the EU?

Not by CBAM, but yes for BRSR (if listed top 1,000), for SBTi if you commit to targets, for customer ESG questionnaires (Walmart, Apple, Microsoft increasingly require Scope 3 data from suppliers), and for sustainability-linked financing.

Carbon Accounting β€” Why It Matters in 2026

Carbon accounting is the systematic quantification of greenhouse gas (GHG) emissions from an organisation's operations, supply chain, and value chain. In India, the regulatory and commercial pressure for credible carbon accounting is accelerating rapidly: SEBI's BRSR Core mandates Scope 1 and 2 GHG disclosure for top 1,000 listed companies, the EU's CBAM (Carbon Border Adjustment Mechanism) requires Indian exporters to report product-level carbon intensity, and the Indian government's Carbon Credit Trading Scheme (CCTS) under the Energy Conservation Amendment Act 2022 is creating a domestic carbon market. For companies with net-zero commitments, a credible GHG inventory is the foundation of the entire decarbonisation journey.

GHG Protocol β€” The Global Standard

The GHG Protocol Corporate Standard (developed by World Resources Institute and World Business Council for Sustainable Development) is the globally accepted standard for corporate GHG inventories. India's BRSR, CDP reporting, and SBTi (Science Based Targets initiative) all use GHG Protocol as the methodological basis.

The Three Scopes of GHG Emissions

ScopeDefinitionExamplesDifficulty
Scope 1 β€” DirectEmissions from sources owned or controlled by the companyFuel combustion in own vehicles/boilers, industrial process emissions, refrigerant leaksLow β€” data from fuel purchase records
Scope 2 β€” Indirect EnergyEmissions from purchased electricity, heat, steam, coolingElectricity consumed from grid, district heatingLow β€” from electricity bills Γ— grid emission factor
Scope 3 β€” Value ChainAll other indirect emissions in company's value chain, upstream and downstreamBusiness travel, employee commuting, purchased goods, waste, use of sold products, investmentsHigh β€” requires data from suppliers, customers

Scope 3 Categories β€” Full List

GHG Protocol identifies 15 Scope 3 categories. Companies typically prioritise the material ones:

CategoryTypical for Indian Companies
1. Purchased goods and servicesVery material for manufacturing, retail
2. Capital goodsMaterial for infrastructure companies
3. Fuel and energy related (not in Sc 1/2)Transmission losses, upstream fuel extraction
4. Upstream transportationMaterial for import-heavy industries
5. Waste generated in operationsAll industries
6. Business travelIT services, consulting, banking
7. Employee commutingLarge employee-intensive companies
11. Use of sold productsMaterial for auto, appliances, chemicals
15. InvestmentsMaterial for banks, insurance, conglomerates

Emission Factors for India

Accurate GHG inventory requires using the correct emission factors:

GHG Inventory β€” Our Step-by-Step Methodology

  1. Organisational boundary setting β€” Equity share approach vs operational control approach. Define which subsidiaries, JVs, and facilities are in scope
  2. Operational boundary setting β€” Which Scope 3 categories are material? Materiality threshold: any category >1% of total emissions
  3. Data collection β€” Activity data from: electricity bills, fuel purchase invoices, fleet fuel logs, production records, HR systems (for headcount and travel), waste disposal manifests
  4. Emission factor selection β€” CEA grid factors, IPCC combustion factors, DEFRA transport factors, ecoinvent database for supply chain
  5. Calculation β€” Activity data Γ— Emission factor = tCO2e. Apply GWP factors for non-CO2 gases (CH4 Γ— 28, N2O Γ— 273, HFCs as per AR6 GWPs)
  6. Quality assurance β€” Internal review, year-on-year comparison, intensity ratio benchmarking against industry
  7. Third-party verification β€” ISO 14064-3 verification against GHG Protocol standard (required for BRSR Core assurance and CDP reporting)
  8. GHG inventory report β€” Published in BRSR/annual report format, or standalone sustainability report

Carbon Credit Trading in India β€” PAT and CCTS

India has two carbon market mechanisms:

CBAM β€” Carbon Border Adjustment Mechanism Impact for Indian Exporters

EU's CBAM imposes a carbon cost on imports of steel, aluminium, cement, fertilisers, hydrogen, and electricity into the EU. From January 2026 (financial phase-in), Indian exporters in these sectors must:

  1. Calculate and report embedded GHG emissions per tonne of exported product
  2. Purchase CBAM certificates for the embedded emissions not covered by India's domestic carbon pricing

The embedded emissions must be calculated per GHG Protocol methodology and, eventually, verified by an accredited verifier. Our CBAM-ready GHG reporting service prepares Indian exporters for this requirement.

Net-Zero Planning

Beyond reporting, a GHG inventory is the starting point for net-zero strategy:

  1. Baseline GHG inventory (Scope 1, 2, and material Scope 3)
  2. SBTi (Science Based Targets initiative) target setting β€” near-term (2030) and long-term (2050)
  3. Abatement levers analysis β€” renewable energy (PPAs, rooftop solar), energy efficiency, electrification, fuel switching, supply chain engagement
  4. Carbon credits (offset) for residual emissions
  5. Annual GHG inventory and progress tracking