After years of preparation, 2025 marked a turning point in sustainability reporting with the arrival of Scope 3–driven regulations such as the EU’s Corporate Sustainability Reporting Directive and California’s SB 253. While organizations anticipated these changes, many underestimated the operational demands required to meet them.
Scope 3 reporting has always been complex. What has changed is the urgency. Regulatory timelines have accelerated expectations for transparency, auditability and broad value chain coverage. Sustainability is no longer a standalone function. It is operational, cross-functional and time-sensitive.
Leaders must now coordinate across procurement, finance, product and operations while engaging suppliers beyond the enterprise. Expectations have shifted from “measure what you can” to “demonstrate comprehensive coverage supported by evidence.”
Scope 3 reporting has entered a decisive phase of execution. Planning has given way to delivery. Yet confidence remains uneven. As disclosures expand and scrutiny intensifies, many organizations still report limited assurance in their Scope 3 data.
To better understand how companies are navigating this shift, we surveyed more than 1,000 sustainability leaders across 15 industries in EMEA, APAC and the Americas for the 2026 Sphera Scope 3 Report. The findings reveal both progress and pressure.
- 59% report increased sustainability budgets
- 73% continue voluntary disclosures beyond compliance requirements
- 80% say regulatory changes have accelerated overall sustainability reporting
- 75% say regulations have specifically accelerated Scope 3 efforts
- 89% plan to expand Scope 3 reporting in the coming year
Organizations are not retreating in the face of complexity. They are moving forward.
At the same time, resources remain constrained. Twenty-seven percent operate with sustainability teams of 10 or fewer people. Only 14% report into a dedicated chief sustainability officer. Many teams sit within legal (20%), strategy (17%) or finance (10%), embedding Scope 3 accountability within broader corporate functions. Notably, 45% lack full confidence in the accuracy of their Scope 3 data. As mandatory disclosures take effect, these gaps move from operational concern to potential compliance risks.
What distinguishes this moment is not simply new regulation, but converging expectations across jurisdictions. While CSRD and California SB 253 follow different paths, both are accelerating the shift from strategy to execution. Organizations must scale reporting methods quickly while maintaining credibility across regions and business units.
Technology will play a role. Forty-seven percent plan to apply AI to supply chain risk assessment. Yet 45% express concern about data quality, underscoring that technology is only as effective as the data behind it. Sustainable progress requires more than tools. It demands an operating model that connects data, clarifies ownership and supports informed decision-making at scale.
Our research reinforces a broader reality: confidence no longer comes from ambition alone. It comes from disciplined execution. Organizations that succeed will translate regulatory pressures into operational rigor and embed sustainability into everyday business decisions. High-quality Scope 3 data strengthens investor confidence, enhances supplier collaboration and improves risk management.
I invite you to explore the full 2026 Sphera Scope 3 Report to see how your peers are moving from planning to performance. The path forward is defined. The question is how quickly organizations can operationalize it.
— Paul
