Property businesses are asked about carbon by public sector clients, by investors and lenders, and by tenants who want the emissions of the space they occupy. Most of the difficulty is deciding whose emissions are whose. Once you have a clear rule for that, the data is mostly energy bills.
Who asks for it
- Central government and the NHS, when you bid for estates, facilities or property management contracts above £5 million a year.
- Councils and housing associations, which often ask managing agents and maintenance contractors for a Carbon Reduction Plan on smaller contracts.
- Corporate tenants, who need the energy of the space they occupy for their own reporting, especially where you buy the energy and recharge it.
- Your annual report, if you are a quoted company or a large company or LLP under SECR.
Landlord or tenant: whose emissions are they?
| Situation | For the landlord | For the tenant |
|---|---|---|
| Common parts, lifts, shared heating and car parks the landlord runs | Scope 1 and 2 | Scope 3, if the tenant chooses to include its share |
| A let unit with its own meters in the tenant's name | Scope 3, category 13 | Scope 1 and 2 |
| A let unit where the landlord buys energy and recharges it | Scope 3, category 13 under operational control, or Scope 1 and 2 if you choose to report all energy you buy | Scope 1 and 2, using the landlord's kWh figures |
| Residential lettings where tenants pay their own bills | Scope 3, category 13 | Not a business footprint |
| Your own head office and branch offices | Scope 1 and 2 | Not applicable |
A PPN 006 plan requires Scope 1, Scope 2 and Scope 3 categories 4, 5, 6, 7 and 9, so tenant energy in category 13 is not required. Many investors and tenants will still ask about it, so it is worth measuring where you have the data.
Where your own emissions come from
| Source | Scope | What to collect |
|---|---|---|
| Gas or oil for landlord-controlled heating and hot water | Scope 1 | Landlord supply bills in kWh or litres |
| Refrigerant leaks from landlord-maintained air conditioning | Scope 1 | Service records: gas type and kilograms topped up |
| Vans for maintenance teams and company cars | Scope 1 | Fuel cards in litres, or mileage by vehicle |
| Electricity for common parts, lifts, lighting and offices | Scope 2 | Landlord supply bills in kWh |
| Waste from common areas, if you arrange the collection | Scope 3, category 5 | Waste contractor reports |
| Property managers' and surveyors' travel between buildings | Scope 3, category 6 | Mileage claims and expenses |
| Staff commuting and homeworking | Scope 3, category 7 | A staff survey |
Which government conversion factors apply
Use the DESNZ UK electricity factor for landlord supplies, Fuels for gas and oil, Heat and steam if a building takes heat from a district network, and Refrigerant & other for air conditioning leaks. For tenant electricity you report in Scope 3, DESNZ publishes a separate Managed assets- electricity factor, which is classed as Scope 3 so it stays out of your Scope 2 total. Travel uses the Passenger vehicles, Delivery vehicles and Business travel tabs.
EPCs and minimum energy efficiency standards
Minimum energy efficiency standards (MEES) are not carbon reporting, but they drive most of the reduction projects a landlord can put in a Carbon Reduction Plan. In England and Wales:
- Homes. A privately rented home needs at least EPC E to be let, unless an exemption is registered. The government confirmed in January 2026 that the standard will rise to EPC C by 1 October 2030, with a cost cap of £10,000 per property.
- Commercial property. The current minimum is EPC E. In June 2026 the government said it intends buildings over 1,000 square metres to reach EPC B from 2031 where cost-effective, dropped the earlier proposal for an EPC C milestone in 2027, and said smaller buildings should stay at EPC E. Legislation is still to follow.
Scotland has its own rules for rented property, so check separately for Scottish buildings.
Common mistakes
- Changing the boundary between years. If you move recharged tenant energy from Scope 1 and 2 to Scope 3, restate your baseline the same way, or the change looks like a reduction.
- Vacant units. Energy in empty units is the landlord's while they are empty. Include it.
- Buildings bought or sold in the year. Count each building only for the months you held it, and explain it in your plan.
Reductions buyers recognise
- LED lighting with sensors in common parts and car parks;
- heat pumps in place of gas boilers in landlord-controlled heating;
- building management system tuning and out-of-hours setbacks;
- solar panels on roofs, with power supplied to common parts or tenants;
- a renewable electricity tariff for landlord supplies;
- green lease clauses that share energy data between landlord and tenant.
How Carbon Recycling handles it
Add each building as a site and import landlord supply bills from a spreadsheet. Every line uses the matching DESNZ factor and feeds your PPN 006 Carbon Reduction Plan and SECR report. Tenant electricity can be recorded against the DESNZ managed assets factor and tagged to Scope 3 category 13, so it is kept apart from your own Scope 1 and 2. Site-level figures let you give a tenant or buyer the numbers for one building.
Check SECR with the SECR checker, convert landlord supplies with the kWh to CO2e calculator, download the free Carbon Reduction Plan template, or see prices.