On October 5, ISDA responded to the Joint Research Centre (JRC) of the European Commission (EC) survey, drawing on input from five member firms across the banking, exchange and market-data sectors. The response highlighted broad support for internationally recognized carbon accounting frameworks, particularly the Greenhouse Gas Protocol and International Organization for Standardization standards. Respondents reported ongoing efforts to simplify reporting through harmonized internal processes, digital tools and ‘one-to-many’ reporting models that enable a single dataset to support multiple reporting obligations.

Participants identified fragmentation across carbon accounting frameworks as the principal challenge, citing duplicated reporting requirements, inconsistent methodologies, differing emissions boundaries and rapidly evolving regulations. Scope 3 emissions (indirect greenhouse gas emissions that occur across a company’s value chain but are not directly owned or controlled by the company), allocation methodologies and the lack of interoperability between frameworks were highlighted as key obstacles to comparability, efficiency and decision-useful reporting.

The response calls for greater international harmonization, including common emissions factor databases, interoperable digital reporting standards, automated mapping tools and mutual recognition of assurance processes. Respondents also supported an ‘audit once, report many’ approach to reduce compliance costs and improve consistency for globally active firms.