With no factory or vehicle fleet of its own, the carbon footprint of a consultancy, a law firm, an agency or a software company concentrates in three places: the electricity and climate control of its offices (scope 1 and 2, and often scope 3 too if the building is leased), business travel and staff commuting (scope 3), and cloud services and supplier purchases (also scope 3). The most common mistake is treating scope 3 as optional because there is no factory to justify it: in a services business, it is usually by far the largest part of the inventory.
Why the boundary looks different from an industrial company's
The GHG Protocol does not define the three scopes differently by sector, but the relative weight of each one changes radically once there is no production process. In a professional services firm, scope 1 is usually small to none (a company vehicle here and there, maybe a backup generator), scope 2 is limited to office electricity, and almost everything that actually matters sits in the fifteen scope 3 categories: travel, staff commuting, cloud services, office supplies, and to a lesser extent the end-of-life of IT equipment.
This has a practical consequence: if the team building the inventory only measures what shows up on a direct invoice (electricity, and little else), it ends up with a small fraction of the real footprint, and that is exactly the part a large client in a tender, an investor or Spain's RD 214/2025 will ask to see completed.
Where the footprint actually is: boundary by source
| Source | Scope | Where the data comes from | Typical materiality |
|---|---|---|---|
| Office electricity | Scope 2 | Utility invoices, with or without a guarantee of origin | Medium, unless the company runs its own data centers |
| Climate control with company-owned refrigerant equipment | Scope 1 | Air-conditioning maintenance service reports | Low in small offices, relevant in buildings with centralized climate control |
| Business travel (flights, trains, hotels) | Scope 3, category 6 | Travel agency, expense management system, corporate cards | High for consultancies and agencies with clients away from the office |
| Staff commuting | Scope 3, category 7 | Employee survey on commute mode and distance | High where many employees drive alone |
| Cloud services (SaaS, hosting, AI) | Scope 3, category 1 | Sustainability reports or calculators from the cloud provider | Growing, especially in software and companies with heavy AI use |
| Office supplies and general purchasing | Scope 3, category 1 | Purchasing accounts by category | Low to medium |
| Remote work | Scope 3, category 7 | Survey or standardized estimate per day worked from home | Medium, with limited primary data available |
Leased offices: getting the data without your own meter
Most services companies do not own their building, and the lease rarely includes an energy breakdown for the whole property. Three approaches work in practice:
- Individual office meter. If the company has its own supply contract and gets a direct invoice, the data already exists and just needs to be centralized.
- Allocation by floor area or headcount. When electricity is paid by the landlord or the building's community and passed through in rent, ask the landlord for the building's total consumption and apply a documented, consistent allocation criterion (occupied square meters or number of desks) year after year.
- Default estimate as a last resort. If neither of the above is available, a reference consumption figure per square meter and office type can be used, explicitly flagged as an estimate, with a plan to replace it with real data.
For multiple sites at once, centralizing this site-by-site allocation is where most of the time gets lost; we cover it in detail in the guide on centralizing emissions data across multiple sites.
Cloud services: what to ask the provider for
Cloud computing services fall under scope 3 category 1 (purchased goods and services), and calculating them has three levels of data quality, from lowest to highest precision: estimating from the provider's invoice spend, using the emissions calculators some large cloud providers offer their customers (which allocate a data center's actual consumption across workloads), or requesting the provider's own emissions intensity figure directly when it publishes one in its sustainability report. Before using any figure a cloud provider publishes, check the report's date and exactly what it covers (only the data center, or also hardware manufacturing), because not every provider measures the same thing under the same label. This category is worth watching closely in software and AI-heavy businesses, where cloud spend, and the emissions tied to it, tends to grow faster than headcount, and where a provider's own emissions intensity figure can shift materially between one annual report and the next as new capacity comes online.
What Spain's RD 214/2025 requires if it applies to you
RD 214/2025 requires calculating the carbon footprint of scopes 1 and 2 (scope 3 is voluntary under this specific rule) and having a reduction plan with a five-year horizon and quantified targets, for companies with more than 250 employees that are public-interest entities, or that exceed, for two consecutive years, €20 million in assets or €40 million in turnover. For a services company that meets these thresholds, the mandatory part of the calculation (scopes 1 and 2) is usually the smallest and easiest to close; the real challenge is scope 3, even though the rule does not require it yet, because that is exactly what a client in a tender or an investor will ask for afterward.
Per MITECO's clarifying note from December 2025, the footprint and reduction plan must be published within six months of the fiscal year's close, and the calculation can cover any consecutive 12-month period. Registration in MITECO's carbon footprint registry remains voluntary for private companies.
What tenders and large clients ask for, beyond the law
In practice, much of the pressure on services companies does not come from a rule that directly obliges them, but from their own clients: a large company reporting its category 1 scope 3 emissions needs data from its suppliers, and a consultancy, agency or law firm billing that company becomes part of someone else's scope 3. It is increasingly common for a public tender or a private client's supplier questionnaire to ask, at minimum, for a calculated scope 1 and 2 footprint, and often for a scope 3 estimate with material categories identified too. Having the calculation ready before it is asked for saves weeks in the award process.
A boundary template by source
To kick off a services company's first inventory, a minimal boundary template covers these blocks, with an internal owner for each data point:
- Electricity for each site, with the admin team member who manages the supply contract.
- Refrigerants in company-owned climate control equipment, sourced from the maintenance contractor.
- Business travel, sourced from the travel agency or the expense management system.
- Staff commuting, based mainly on an annual survey.
- Cloud services and software, with the technology department responsible for collecting the provider's data.
- General purchasing, owned by the admin or procurement department.
Closing this boundary in writing before requesting a single data point avoids the most common mistake: starting to collect information without having decided what is in scope, and having to redo the exercise halfway through. It also gives every owner in the list a clear deadline and a clear deliverable, rather than a vague request to "send whatever you have," which is usually what turns a first inventory into a months-long chase for missing spreadsheets.
Frequently asked questions
Does a small consultancy need to measure its carbon footprint?
Legally, only if it exceeds RD 214/2025's thresholds. In practice, more and more clients and tenders ask for it as a commercial requirement, even when the rule does not.
Is scope 3 mandatory for a services company in Spain?
Not under RD 214/2025, which only requires scope 1 and 2. A client, a tender, or a voluntary standard the company chooses to adopt can require it.
How do you calculate the footprint of an employee working from home?
With a survey that captures days worked remotely and a standardized estimate of the home energy consumption attributable to that workday, always documenting that it is an estimate, not a direct measurement.
Which scope 3 categories can be left out of a first inventory?
Those that, after an initial screening, are clearly not material against the total, such as end-of-life office equipment in a small workforce. You need to document why they are excluded, not simply leave them out silently.
Can I use the landlord's electricity invoice if it is not in my company's name?
Yes, as the basis for applying a floor-area or headcount allocation criterion, as long as the building's total consumption and the criterion used are documented.
Centralizing these scattered sources into a single inventory, with the source document behind every data point, is exactly what our carbon footprint solution does for companies without an industrial process.
