Why Project Owners Must Take Responsibility for Emissions Data

Since 2022, under the Corporate Sustainability Reporting Directive (CSRD) and supported by the EU Sustainable Finance Disclosure Regulation (SFDR), the legal obligation to ensure the accuracy of sustainability disclosures—including Scope 1 and Scope 3 emissions—sits squarely with the project owner. That means government agencies, developers, and investors are now directly accountable for the quality, traceability, and audit-readiness of emissions data across their projects.

It is no longer acceptable to shift this responsibility onto third-party contractors, hauliers, or suppliers. If the data used for reporting is incomplete, estimated, or unverifiable, it is the owner entity, not the subcontractor, that will be held liable under law.

Why This Matters Now

From 2025 onward, full compliance with CSRD becomes mandatory across many jurisdictions. Scope 3 emissions—particularly those relating to transport, subcontractors, and procurement—must be measured and reported with the same accuracy and transparency as financial data.

For infrastructure, housing, and logistics-heavy projects, this presents a significant challenge. Without proper systems in place to track real-world emissions, many publicly funded or ESG-labelled projects will fall short of compliance.

The Problem: Inaccurate and Outdated Tracking

Despite the tightening of legislation, many projects still rely on flawed reporting practices, including:

• Generic emissions factors – Broad industry averages are applied instead of actual usage data

• Assumed fuel consumption – Fails to reflect real variables like load weights, terrain, or idling

• Manual data entry – Leaves room for error and lacks audit trails

• No traceability – Emissions cannot be linked to individual jobs, subcontractors, or project phases

These outdated practices not only undermine environmental credibility—they also expose project owners to legal and financial risk under CSRD and the GHG Protocol.

The Legal Obligation Is Clear

Under CSRD and EU taxonomy rules:

• The project owner is legally responsible for the integrity of Scope 1 and 3 emissions data

• Auditable, source-level records must be available to demonstrate compliance

• Greenwashing penalties and investor withdrawal are increasing for non-compliance or unverifiable data

It is not sufficient to rely on emissions figures provided by third-party operators unless those figures are backed by verifiable systems. Ownership of the data—and the risk—remains with the lead entity.

What Needs to Change

Project owners must now move away from informal reporting and adopt systems that offer:

• Real-time emissions tracking across transport and subcontracted activities

• Project-specific traceability linking carbon data to exact jobs, vehicles, and suppliers

• Automated, verifiable reports that meet the standards of financial-grade audits

Platforms like Hub360 are enabling exactly this, by integrating with vehicle telematics and material workflows to generate CSRD-ready emissions data—broken down by load, journey, or subcontractor.

Final Thought

The law is unambiguous: it is the owner’s duty to ensure emissions data is accurate, auditable, and fit for reporting. As scrutiny around ESG claims intensifies, relying on generic estimates or third-party assurances is no longer acceptable.

For any organisation delivering or funding major infrastructure, this is the time to act—not just to comply, but to lead.