Do bank charges, loan processing fees and insurance premiums count in our Scope 3?

Yes, in principle. Bank fees, loan processing charges and insurance premiums are payments for services, so they belong in Scope 3 Category 1. For most MSMEs they are small and can be estimated spend-based. Interest on loans is a financing cost, not a service, and most companies leave it out; say which way you went.

What goes in

• Bank charges, processing fees, guarantee commission and letter of credit charges.
• Insurance premiums for property, stock, transit, vehicles and staff health cover.
• Payment gateway and card acquiring fees.

What stays out

• Interest on loans and overdrafts: a cost of money, not a purchased service. Many companies exclude it; if you include it, state that clearly.
• GST charged on the fees: a tax, not part of the service value.
• Your bank's financed emissions. When a bank lends to you, it reports a share of your emissions in its own Category 15. That does not add anything to your inventory.

How to estimate

There are no activity units for a bank fee, so spend-based is the method: fees net of GST times a financial services factor from the dataset you use for other spend, adjusted for currency and the dataset's price year. Label the result spend-based.

Is it worth including

Run a quick estimate. If it is a small share of Scope 3, you can exclude it with a one-line justification under the Scope 3 Standard's relevance test. If a buyer asks for a complete Category 1, keep it in.

What Senseible does here

Senseible reads purchase and service invoices; where only spend is available it gives a spend-based estimate, labelled as spend-based with wider uncertainty.

• Spend-based Scope 3: GST, inflation, currency
• Can we exclude a Scope 3 category
• Spend-based or activity-based Scope 3

Sources: GHG Protocol Scope 3 Standard, Category 1 purchased goods and services

Last reviewed 2026-10-20.