The short answer
An industrial park's ESG programme starts with a clean control boundary. Infrastructure the operator supplies and manages itself (energy, water, treatment, common areas, landlord-controlled tenant space) becomes the operator's Scope 1 and 2; what tenants control sits in Scope 3. From the 2026 GRESB update, landlord-controlled tenant-space emissions moved from Scope 3 into Scope 1 and 2. Solid practice pairs two years of metered data with tenant data schedules and climate lease clauses.
Key takeaways
- Base the park's carbon inventory on operational control, not legal ownership: shared grids, utilities and landlord-controlled tenant space map to the operator's Scope 1–2, while tenant-controlled operations sit in Scope 3.
- The 2026 GRESB Real Estate Standard reclassifies emissions from landlord-controlled tenant spaces from Scope 3 to Scope 1 and 2, and requires location-based Scope 2 with market-based as an option.
- The SBTi 'whole building' approach covers all operational energy and fugitive emissions regardless of who controls the building's energy use, so parks must collect tenant data to set credible targets.
- GHG Protocol treats energy consumed by tenants in leased space as Scope 3 'downstream leased assets' (Category 13) for the lessor.
- Reliable reporting depends on submetering shared utilities, a tenant-by-energy-type register, and climate clauses in leases.
- In Russia, the Association of Clusters, Technoparks and SEZs, supported by the Ministry of Economic Development, has run an ESG rating of special economic zones since 2023 as a national benchmark.
- Document boundary changes and estimation rules each year: auditors and benchmarks reward traceable, like-for-like data over broad averages.
Start with the control boundary, not the legal entity
The first decision for an industrial park is not "who owns the asset" but "who controls the consumption." The International Framework for Eco-Industrial Parks developed by the World Bank, UNIDO and GIZ treats a park as a managed territory whose sustainability performance spans park management, environmental, social and economic requirements integrated into siting and operation.
In practice the park controls the shared spine: substations, boiler or district-heating rooms, water intakes and pumps, treatment plants, outdoor lighting and roads. Everything the park supplies and runs itself is its direct and energy-indirect emissions.
Residents operating their own processes are separate economic actors. Their consumption enters the park's Scope 3 (as leased-downstream activity), while each resident separately reports its own Scope 1 and 2. Without a boundary and responsibility map at every metering point, the park's ESG report is arbitrary rather than auditable.
- Map each asset: who owns, maintains and operates every substation, boiler house, network and meter.
- Define shared-services, common-area and leased zones for every building.
- Codify boundaries in the lease and in each unit's technical passport, not only in internal rules.
Accounting for shared resources: energy, water, heat, waste
Shared resources — electricity for the park's own needs, heat, water for landscaping and fire suppression, waste from common grounds — must be measured separately from leased areas. GRESB's Scope 1–3 guidance maps fuel, electricity and district heating/cooling in landlord-controlled zones (shared services, common areas, exterior areas and even tenant spaces controlled by the landlord) to the operator's Scope 1 and 2.
Submetering is the core instrument. Without it, common-system consumption is often averaged across all residents, distorting both residents' Scope 3 and the park's own Scope 2. Where actual data is only partly available, GRESB permits estimates under defined conditions, but estimate-heavy reporting lowers the data-coverage score.
Industrial symbiosis — one resident's heat, steam, treated water or by-products used by another — adds value but complicates accounting. Treat such flows as real measured transfers across boundaries; otherwise two companies may double-count or omit emissions. The transfer needs an act with meter readings so both inventories stay correct.
- Install submeters by energy type and by zone group (common, leased, exterior).
- Record heat, steam and water transfers between residents with signed, metered acts.
- Separate location-based and market-based electricity factors (location-based is mandatory for Scope 2).
Tenant emissions: the changing scope rules and Category 13
The most consequential change in recent years is the reclassification of tenant-space emissions. GRESB's 2026 Standard moves emissions from "tenant spaces — landlord controlled" from Scope 3 into Scope 1 and 2: when the landlord supplies and regulates energy in a space it controls, the landlord carries those emissions directly.
In parallel, the SBTi 'whole building' approach requires accounting for all operational energy and fugitive emissions of a building regardless of who controls energy use, and it pushes owner-lessors to set targets across their portfolios, including a public commitment not to install new fossil-fuel heating, cooking, power or hot-water equipment from 2030.
Where the resident genuinely controls the space, its consumption belongs to the park's Scope 3 — in GHG Protocol terms, Category 13 "downstream leased assets," which covers assets the reporting company owns and leases to others that operate them. The same floor area can therefore be the operator's Scope 1–2 or its Scope 3 depending on who actually manages the equipment.
- Classify each leased zone as landlord-controlled or tenant-controlled.
- Verify who controls ventilation, lighting and heating inside a tenant's space.
- Recalculate a two-year series whenever the control mode changes, or like-for-like trends become meaningless.
Choosing a reporting route
There is no single "one standard": the right route depends on your audience. The GHG Protocol Corporate Standard is the baseline inventory methodology — seven Kyoto gases and two Scope 2 methods — and underpins most corporate reporting programmes worldwide. GRESB is an investor benchmark for real estate: it asks for two consecutive years of emissions by Scope at asset level, data coverage, and like-for-like change over comparable floor area.
For parks seeking science-based targets, the SBTi Buildings Criteria are the reference: whole-building coverage, reduction of in-use operational and upfront embodied emissions, no new fossil-fuel installations from 2030, and a recommendation to retrofit inefficient buildings.
In Russia, international benchmarks are partly inaccessible, but a national practice exists: since 2023 the Association of Clusters, Technoparks and SEZs, supported by the Ministry of Economic Development, has run an ESG rating of special economic zones that scores how actively management companies adopt environmental initiatives, social standards and governance transparency. A park that keeps clean boundary-based records can populate such questionnaires quickly.
- Anchor on the standard your audience reads: investor (GRESB), value chain or regulator (GHG Protocol, SBTi).
- Set up data in a two-year rolling format from day one rather than reconstructing later.
- Maintain both Scope 2 methods: location-based (required) and market-based (for RECs and PPAs).
Leases, data collection and tenant engagement
A park's report depends on data only residents can supply. The reliable mechanism is green and climate language in leases: an obligation to provide meter readings, keep separate accounting, allow data access, and consent to aggregated transfer into the park inventory.
Large industrial logistics owners embed such conditions in new contracts and steer shares of "green leases" toward targets, applying the same logic to shared systems they manage. The practical payoff is predictable data completeness and far less manual chasing.
Engagement is two-way: residents who raise capital or sell into supply chains need data from the park too, such as the generation mix of purchased electricity. Building a reciprocal exchange turns ESG from an administrative burden into a competitive advantage for the site.
- Add submetering and meter-read timing obligations to the lease.
- Secure consent for aggregated, non-attributable transfer of data into the park's report.
- Reconcile boundaries and control modes with residents at least annually.
Limitations and common mistakes
The classic errors are reporting "everything to residents" or "everything to the park," mixing two-year periods after a boundary change, and presenting estimates as measured data. Standards move quickly: GRESB changed its Scope rules for 2026, and SBTi issued Buildings Criteria updates v1.1 (2025) and v1.2 (2026).
Before publication, verify current versions and deadlines on the organisers' official sites, since benchmarks, submission windows and data rules can shift. For questions touching law, tax or mandatory reporting in a specific jurisdiction, this article is general guidance and not a substitute for professional advice.
- Do not apply park-wide average factors where submeters exist.
- Keep a methodology-and-boundary change log for traceability in audits.
- Track standard versions: GRESB 2026 and SBTi v1.2 already altered some requirements.
Practical asset: the boundary and data checklist
The checklist below sequences a park ESG inventory in one cycle: boundary map, source register, zone classification, data collection, completeness checks and tenant liaison. Each item should close with an owner and a document reference so the submission stands up to external review.
It complements, but never replaces, the underlying standards and their current versions.
Put it into practice
Industrial park ESG boundary and data audit checklist
A sequential audit before you build or refresh your report. Work left to right, assigning an owner and a source document to each line; the completed register feeds GRESB, GHG Protocol, SBTi or a national ESG rating.
- Asset map: owner, maintainer and operator recorded for every substation, boiler house, network and meter.
- Zone inventory: shared services, common areas, exterior areas and leased spaces per building.
- Control mode for each leased space: landlord-controlled or tenant-controlled.
- Submeter register by energy type, water and heat, with calibration and readability status.
- Scope 2 methodology: location-based grid factor for the region and, where applicable, market-based factors for renewable contracts.
- Resident data-transfer agreements and consent for aggregated figures.
- Two-year emissions series by Scope 1, 2 and 3, broken out by floor area and source.
- Metered acts for heat, steam or treated-water transfers between residents.
- Boundary and control-mode change log with dates, for like-for-like comparability.
- Register of climate and green-lease clauses with a plan to expand their coverage.
Questions people ask
Which scope covers a space where the landlord heats and lights the leased unit itself?
If the owner genuinely controls energy supply to a leased unit — supplying and regulating heat and managing lighting — the 2026 GRESB rules place those emissions in the operator's Scope 1 and 2, not Scope 3 as before. Where the resident manages its own energy use, the consumption falls in the park's Scope 3 and, in GHG Protocol terms, under Category 13 "downstream leased assets."
What is the difference between Scope 1, 2 and 3 for an industrial park?
Scope 1 covers direct emissions from burning fuel in the park's boilers, back-up generators and fleet. Scope 2 covers emissions from purchased electricity, heat, steam and cooling consumed by the park's shared systems and own needs; location-based accounting is required and market-based optional. Scope 3 is indirect value-chain emissions — for a park, mainly energy consumed by tenants in spaces they control.
Is ESG reporting mandatory for an industrial park?
Internationally there is no universal mandate; obligations arise from investor benchmarks such as GRESB, value-chain requests, finance covenants or jurisdictions like the EU CSRD when material. In Russia, since 2023 the Association of Clusters, Technoparks and SEZs, supported by the Ministry of Economic Development, has run a voluntary ESG rating of special economic zones. Check the governing documents of your specific programme; this answer is general information, not legal advice.
What does the SBTi 'whole building' approach mean in practice?
It means accounting for all operational energy and fugitive emissions of a building — such as refrigerant leakage — regardless of who controls the energy use. For an industrial park this implies that targets cannot stop at shared systems: you must obtain resident data and negotiate emissions reductions across leased buildings, and commit publicly to avoiding new fossil-fuel installations from 2030.
How do we avoid double counting emissions between the park and its tenants?
Double counting arises when the same energy volume is claimed by both the park and the resident. The remedy is a strict control boundary: for each leased zone, record who operates the equipment. Landlord-controlled area enters the operator's Scope 1–2; tenant-controlled area enters the park's Scope 3 and the resident's own Scope 1–2. Fix the split in the lease and reconcile it annually.
Why install submeters when tenants already pay on a master meter?
Without submeters you cannot separate shared systems (the park's Scope 1–2) from leased areas (Scope 3). A single master meter forces you either to average costs across everyone, distorting both inventories, or to charge everything to the park. Submeters by energy type and zone give measured rather than estimated data coverage, which directly supports GRESB scores and audit confidence.
Sources and further reading
Sources were checked when this page was generated. Confirm changing dates, rules and prices with the original publisher.
- Eco-Industrial Parks 2.0: Building a common global frameworkWorld Bank Group
- GRESB GH1: Scope 1-3 Emissions, Real Estate AssessmentGRESB
- Buildings sector resources — SBTi Buildings CriteriaScience Based Targets initiative (SBTi)
- GHG Protocol Corporate Accounting and Reporting StandardGHG Protocol (WRI/WBCSD)
- Scope 3 Category 13 Explained: Downstream Leased AssetsASUENE
- Итоги ESG-рейтинга особых экономических зон РоссииМинэкономразвития России
- АКИТ РФ и GPIPC укрепляют сотрудничество в сфере "зелёных" индустриальных парковАссоциация кластеров, технопарков и ОЭЗ России (АКИТ РФ)