Real Estate Investments - Scope 3.13 vs. Scope 3.15

Dear Community,

especially when having a look at the latest Draft for the second version of the Short-Term Standard one thing is very unclear to me.

  • It is stated in Fi-C16 that “FIs shall set targets on all “Required Activities” in the Required
    Activities and Methods Table (Table 5.2)”
  • Looking at this table I find the sub-asset class “Direct investment in real estate assets” (for own use or investment purposes) What those exaclty are is not closely defined (as far as I can see)

The following questions appear to me:

  1. Do Real Estate assets of FIs which are used for their own business operation fall under this category? (According to GHG Protcol they would fall under Scope 1+2)
  2. Do Real Estate Assets of FIs which are fully owned but leased to others fall under this category? (According to GHG Protocol they would fall under Scope 3.13 Leased Assets)

In my understanding, both of the above to not fall under Scope 3.15 and do therefore not qualify for this asset class. However, if this is correct, I do not see how "Direct Investments in real estate assets (for own use) could fall under Scope 3.15.

I would highly appreciate if you could clarify my questions or if you could provide any additional information regarding this topic.


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The pilot test version 2.0 of the Near-Term Criteria and Recommendations for FIs clarifies that these would need to be covered if not already covered by scope 1+2 and/or scope 3 categories 1-14 targets. The intention is that they do not fall through the cracks and are not covered by targets anywhere.

Thank you very much for your reply. I do agree that it should be mandatory to set targets for such buildings.
However, it is not clear to me in what manner exactly such targets should be set.

“Direct Investments in real estate assets (for own use)” should probably use the SDA approach. However, since those assets not covered by S1+2 or S3.15 would mostly be classified as S3.13 would it be allowed under the new methodology to set S3.13 targets for just the assets without setting targets for other S3.1-3.14 categories?

Thank you very much!

They could be placed with the s3c15 targets and covered by an SDA target. For s3c1-14 targets, the scope 3 criteria for corporates (e.g., minimum coverage) would need to be followed.