About.
Large enterprises across CSRD, California SB 253, UK SRS, and the 36-plus jurisdictions adopting IFRS S2 must now disclose Scope 3 emissions — the emissions from things they buy. Scope 3 typically accounts for around 75% of an organisation’s total carbon footprint, rising to around 90% in many companies. The data has to come from suppliers.
What suppliers send up the chain today is mostly modelled estimates. Auditors have publicly stated the sector is “some way off” being able to provide reasonable assurance for Scope 3. The measurement infrastructure to do this honestly is being built between now and 2028.
The regulatory cascade.
- CSRD· Corporate Sustainability Reporting Directive
- EU Directive 2022/2464, amended by the Omnibus I directive (Directive (EU) 2026/470, in force March 2026). Originally expected to apply to around 50,000 companies, narrowed by Omnibus I to roughly 5,000 large EU undertakings with more than 1,000 employees and over €450m turnover, plus non-EU groups above €450m EU turnover. The cut happened because the underlying measurement infrastructure was not yet in place. Companies in the revised scope begin reporting on FY2027 data in 2028. Maximum penalty cap: 3% of net worldwide turnover, with member states required to transpose by 19 March 2027.
- California SB 253· Climate Corporate Data Accountability Act
- The 2023 act, amended by SB 219 in 2024. About 5,400 businesses with $1bn+ in annual revenue doing business in California must report scope 1 and 2 emissions from 2026 and scope 3 from 2027, with third-party assurance. The act carries a $500k/year administrative penalty. Assurance phases in from limited to reasonable.
- California SB 261· Climate-Related Financial Risk Act
- Companies with $500m+ in annual revenue doing business in California must publish biennial climate-related financial risk reports aligned with the TCFD framework or IFRS S2. Lower revenue threshold than SB 253, wider scope.
- UK SRS· UK Sustainability Reporting Standards
- UK SRS S1 and S2, published February 2026, endorse IFRS S1 and S2 with minor modifications. Voluntary on publication; the FCA is consulting (CP26/5) on mandatory reporting for certain UK-listed companies from accounting periods beginning January 2027.
- IFRS S2· Climate-related Disclosures
- The global baseline standard. 36 jurisdictions have adopted or are finalising adoption of the ISSB Standards, together representing approximately 57% of global GDP. Requires disclosure of scope 1, 2, and 3 emissions calculated to the GHG Protocol.
The standards we sit on top of.
We are not trying to write the standards. The standards already exist and are being released and consolidated through 2026. torch0 is the system that takes whatever framework applies — CSRD/ESRS, ISO 14067, GHG Protocol, IFRS S2, PACT, ISO 14064-3 — and makes it operationally trivial for a supplier to produce numbers that comply.
- GHG Protocol· Greenhouse Gas Protocol
- The de facto global accounting standard for corporate emissions, distinguishing scope 1 (direct), scope 2 (purchased energy), and scope 3 (everything else in the value chain). Scope 3 typically accounts for around 75% of an organisation’s total carbon footprint, rising to around 90% in many companies. The receipt rolls up into the buyer’s scope 3 line.
- ISO 14067· Carbon footprint of products
- The international standard for quantifying the carbon footprint of a product across its life cycle. The methodology underneath each torch0 receipt aligns with the principles in ISO 14067 — process-level inputs, location-specific grid intensity, equipment amortisation.
- PACT· Partnership for Carbon Transparency
- The existing global convention, hosted by the World Business Council for Sustainable Development, for exchanging verified product carbon data across value chains. Either constrains what the receipt format can look like, or is the format we explicitly align with.
- ISO 14064-3· Verification and validation of GHG statements
- The international standard for the verification of emissions claims. Third-party verifiers — SustainCERT, UL Solutions, and others — verify product carbon footprints against this standard. torch0 receipts are built to be verifiable under it.
Why this is infrastructure, not a standard.
A measurement claim is only as defensible as the methodology underneath it. The receipt that goes in the buyer’s disclosure has to come with calculation assumptions an auditor can verify independently. That rules out closed-box vendor numbers. It also rules out asking suppliers to write their own standard from scratch.
torch0 is the infrastructure layer. The methodology underneath each receipt is published openly. The signature is traceable to source. Each input carries a confidence score so the buyer sees where the calculation rests on measured ground truth and where it leans on modelled defaults. Any auditor can verify the calculation; any third-party verification body (SustainCERT, UL Solutions, and others) can validate the receipt against ISO 14064-3.
The commercial layer is hosted services on top: instrumentation support, integration, audit-grade reporting. Suppliers pay for the service. The methodology stays open.
Long term: a full-stack carbon accounting firm — measurement infrastructure across datacentres, power plants, manufacturing plants, and semiconductor fabs. The same fundamental problem of replacing spend-based estimates with auditable, process-level, confidence-scored receipts generalises across all of them.