Why tenant energy data is important for your Scope 3 reporting.

Measuring tenant energy data is critical for accurate Scope 3 reporting for commercial real estate companies. Now, you may be wondering whether your tenant’s energy consumption falls under Scope 3, and if it does, are you even required to report this data?

Lots of questions! So, let’s break it down in this article to help you understand the importance of measuring accurate energy consumption data from your tenants.

The current state of Scope 3 reporting

Environmental, social, and governance (ESG) reporting asks for more data – and more accurate data – than most property companies are used to collecting. A lot of admin work, but well worth it.

Scope 3 – the indirect emissions in your value chain – has mostly been voluntary to report. For a while, that looked set to change. The EU's Corporate Sustainability Reporting Directive (CSRD) requires Scope 3 where it's material, and it was going to reach around 50,000 companies.Then the 2026 Omnibus package narrowed the CSRD to companies with more than 1,000 employees and more than €450 million in net turnover – both, not either. Plenty of property companies now sit below that line.

Other governments are moving the same way – California, Australia, and the UK among them. And even where it's voluntary, a company's climate targets are incomplete without Scope 3.

The data gap is another big issue when it comes to both upstream and downstream emissions of a company. The data is often obtained from external parties and lacks verifiability. Even worse is that many companies simply base data on industry averages, which can result in wild discrepancies – imagine having to waste time estimating emissions data for the sake of keeping up with legislation – not fun!

Which Scope does tenant energy consumption fall under?

It depends on two things: how you draw your reporting boundary, and what kind of lease it is. How much of the building you own doesn't decide it.

Most property companies use what the GHG Protocol calls the operational control approach. Under it, the energy your tenants control is Scope 3 – even in a building you own outright. It sits in the downstream leased assets category. The energy you control yourself, like common-area lighting or a central boiler, stays in your Scope 1 and 2.

If you use the financial control approach instead, it flips: on an ordinary operating lease, your tenants' energy counts as your own Scope 1 and 2. And if you're a lender or a fund investor rather than the landlord, the building's emissions show up under investments – what the finance world calls financed emissions.

Do you have to report it? Only if a rule or someone you answer to asks. Under the CSRD, companies in scope report Scope 3 where it's material. The voluntary SME standard doesn't ask for Scope 3 at all. But lenders, investors, and certification schemes increasingly do – which is the real reason to get the data in order.

How tenant energy data can help reduce Scope 3 emissions

Collecting data on tenant energy consumption is important for real estate or finance companies investing in buildings that pay through rental income. It’s no longer optional, at least not in the EU. So, even if the energy consumption in an owned or controlled property is indirect, you must collect and report this data.

Even where no rule requires it, someone is increasingly likely to ask for your tenants' energy data – your lender, your investors, or a certification scheme. And the data earns its keep in other ways too. Here's how:

Increase energy efficiency

Data from tenant energy consumption can give insights into adopting solutions for greater energy efficiency. You can implement energy-saving technologies inside properties to reduce consumption. You can also add on-site renewables like solar panels to cut what the building draws from the grid.

Demonstrate climate action

Measures taken based on tenant energy data showcase a commitment to climate action. For real estate companies, it can help demonstrate commitment to existing and potential investors, increasing their confidence in the investments.

Accurate target setting

Accurate data can be empowering when setting goals for decarbonisation and ESG policy. The energy use data from leased buildings can help companies set realistic targets, especially in line with guidance from the Science Based Targets Initiative (SBTi) for finance and buildings sectors.

Engagement with tenants

Personal choices can influence energy consumption. Collecting and analysing tenant energy use can help building owners and managers engage with tenants and encourage efficient energy use. That, in turn, can help them reduce Scope 3 emissions while improving service to their tenants.

Based on the data, you can create green reward systems for tenants that encourage efficient use of energy and heating.

Collecting tenant energy data

Depending on various factors, tenant energy data may or may not be so easily available. For instance, if you’re a company that invests in properties managed by another, getting data on energy consumption for every unit or tenant may be difficult.

Where actual data is unavailable, you’ll need to use estimates. But the thing about estimates is that there’s always a generous room for error. The data accuracy will be low if you use industry benchmarks based on floor area or number of occupants.

Today, it’s easy to collect actual, reliable data on energy usage from properties with the right technology. comundo helps building owners and managers collect accurate tenant energy data and improve carbon accounting.‍

With comundo, you can get tenant energy data going back up to three years – so you can see how far a building's energy efficiency has actually come. It also turns your Scope 3 figure into a measurement rather than an estimate, whether you report under the CSRD, the voluntary SME standard, or to a lender.

Use it to set targets and plan the next round of reductions. Cut your tenants' consumption and you cut their footprint along with yours – two footprints, one set of measures. With the climate crisis where it is, we'll take that.

Finally, certification. DGNB's scheme for buildings in use scores you higher for complete, measured consumption data for the whole building – tenants included. And its Climate Positive award is decided on a full year of meter readings. Estimates won't get you there.

FAQs

How do real estate companies measure and verify the accuracy of the tenant energy data they collect?

Start with where the data comes from. Meter-level consumption from a named source beats estimates based on industry averages or floor area – and it's what you'll need if anyone checks the figure. comundo gives you real-time emissions data based on actual consumption, calculated with local emission factors rather than national averages.

Is it illegal not to report tenant energy data?

For most companies, no. Since the EU's 2026 Omnibus package, the CSRD only applies to companies with more than 1,000 employees and more than €450 million in net turnover – and even they report Scope 3 only where it's material. The voluntary SME standard doesn't ask for Scope 3 at all.

If you are in scope, penalties are set by each EU country and apply to your sustainability report as a whole, not to one line of it. For most property companies, the bigger risk isn't a fine. It's a lender or investor asking for data you can't produce.

How do tenants typically react to collecting their energy data, and how does this impact their privacy or leasing agreements?

Some will ask, and they're right to. Energy data from residential tenants counts as personal data under EU data protection rules, so you need a lawful basis before you collect it. Commercial tenants are mostly companies, where it's less of an issue – though a sole trader is still a person. Either way, be upfront about what you're collecting and why. The data is there to cut energy use and costs, and that's usually an easy conversation to have.