Scope 3, Greenwashing, and the Coming Storm for Infrastructure Projects

Public infrastructure projects across Europe are entering a new phase—one defined not by voluntary ESG commitments but by legally enforceable carbon reporting requirements. At the centre of this shift is Scope 3 emissions: the indirect emissions generated by supply chains, transport, subcontractors, and material usage.

With the Corporate Sustainability Reporting Directive (CSRD) now in force and enforcement mechanisms ramping up across EU member states and the UK, organisations relying on estimates or static spreadsheets are on a collision course with regulation.

Scope 3 Is No Longer Optional

For years, companies have reported Scope 1 and 2 emissions with varying degrees of accuracy, while Scope 3 has often been overlooked or approximated. That’s changing rapidly. CSRD and national policies are making it clear: full value chain emissions must be disclosed, verified, and traceable.

For infrastructure projects, where material movement and logistics represent a large portion of the carbon footprint, this is a fundamental compliance issue—not a “nice to have.”

Regulatory Momentum Across Europe

France

• Monetary fines of up to €18,750 for failing to publish sustainability reports

• Public procurement exclusion for non-compliant companies

• Criminal penalties up to €375,000 and 5 years in prison for obstructing audits or failing to appoint an auditor

Germany

• Under the Supply Chain Due Diligence Act, companies must assess environmental and human rights risks across their entire supply chains

The Netherlands

• National ESG policy is fully aligned with CSRD

• Scope 3 reporting is a baseline expectation

Nordic Countries (e.g. Sweden, Denmark)

• Long-established mandatory climate reporting regimes

• Strong enforcement of Scope 3 transparency

United Kingdom

• In 2024, the Supreme Court ruled that Scope 3 emissions are material to planning decisions

• This sets a legal precedent for deeper accountability in future infrastructure approvals

Implications for Government-Funded Infrastructure

EU Member States are required to submit National Energy and Climate Plans (NECPs), which detail how they will reduce greenhouse gas emissions by 55% by 2030. These plans create cascading obligations for publicly funded and regulated infrastructure projects.

Scope 3 emissions are now relevant to:

• Public procurement documentation

• Tender evaluation criteria

• Environmental impact assessments

• EU and national funding eligibility

• Verification and audit readiness

For public bodies, this means developing systems that capture full value chain data. For contractors, it means that failing to track Scope 3 emissions could directly impact their ability to win contracts or receive funding.

Why Greenwashing Is No Longer Tolerated

Most infrastructure players are still relying on disconnected spreadsheets, outdated emissions factor charts, and unverifiable assumptions. These approaches no longer meet the standard.

They expose organisations to:

• Procurement penalties

• Legal challenges

• Funding disqualification

• Public and investor backlash

The Path Forward

Solutions exist. Hub360, for example, provides real-time tracking of material movement and associated CO₂ emissions—by project, load, truck, or subcontractor. It offers traceability and audit-grade reporting that meets CSRD, GHG Protocol, and NECP compliance standards.

As public scrutiny grows and enforcement tightens, the question facing infrastructure stakeholders isn’t whether Scope 3 matters—but whether they’re equipped to track it properly.

The age of soft targets is over. The infrastructure sector must now meet hard obligations, with hard data.