Our hotel is owned by one company and run by a management company: who reports its Scope 1 and Scope 2 emissions?

It depends on the consolidation approach each company picked. Under operational control, whoever has full authority to introduce and implement operating policies at the hotel reports all of it, whatever it owns. Under equity share, each reports by economic interest. Read the management contract against those tests.

What the Greenhouse Gas (GHG) Protocol Corporate Standard tests

• Operational control: the company, or one of its subsidiaries, "has the full authority to introduce and implement its operating policies at the operation". It then accounts for 100% of that operation's emissions.
• The Standard adds: "It is expected that except in very rare circumstances, if the company or one of its subsidiaries is the operator of a facility, it will have the full authority to introduce and implement its operating policies and thus has operational control."
• Financial control: the company "has the ability to direct the financial and operating policies" of the operation "with a view to gaining economic benefits from its activities", and usually has the right to the majority of the benefits.
• Equity share: emissions follow the company's share of economic interest, the extent of its rights to the risks and rewards of the operation.

Reading a management contract (our reading, not the Standard's)

The Standard does not mention hotels, hospitals or management contracts. It says control does not require authority over every decision: big capital investments will likely require the approval of "all the partners that have joint financial control", yet "operational control does mean that a company has the authority to introduce and implement its operating policies". For joint operations, it says that where a company has joint financial control but not operational control, the company would need to look at the contractual arrangements to see whether any one partner has the authority to introduce and implement operating policies. It does not address management contracts, so applying that to an owner and operator is our reading.

• If the operator sets staffing, bookings, air conditioning hours and fuel purchases, and the owner only approves budgets and capital spending, the contract points to the operator for operational control. This is our reading.
• If the owner keeps the right to set those operating policies and the operator only carries out its instructions, the contract points to the owner. This is our reading.
• The Standard says that in most cases, whether an operation is controlled "does not vary based on whether the financial control or operational control criterion is used", so check the answer under the other control test too.

What the party that does not report does

The Standard says the chosen approach is also applied to leased assets, outsourcing and franchises, and that if the equity or control approach does not apply, the company "may account for emissions" from them "under scope 3". Whether an owner puts a hotel it has handed to an operator in Scope 3, and in which category, is a judgement. Settle it with your buyer or verifier and record it.

Keep it consistent

• The Standard says companies "shall" account according to either the equity share or the control approach, and that once chosen, the policy "shall be applied to all levels of the organization".
• The Standard says that if companies in the same operation use different approaches, the emissions could be double counted. That may not matter for voluntary reporting with clear disclosure, but must be avoided in trading schemes and mandatory reporting. Where you can, agree the approach and who reports what in writing (our suggestion).
• Put the data duty in the management agreement: monthly electricity bills, diesel and liquefied petroleum gas (LPG) purchases, refrigerant top-ups.

One hotel, three answers (example figures)

• Electricity: 1,200,000 kilowatt hours (kWh) x 0.675 kilograms (kg) of carbon dioxide (CO2) per kWh (financial year (FY) 2025-26 grid factor) = 810,000 kg
• Standby generator diesel: 20,000 litres (L) x 2.645 kg CO2 per L = 52,900 kg
• Hotel total: 810,000 + 52,900 = 862,900 kg, which is 862.9 tonnes
• Owner owns 100%, operator holds no equity and is paid by the owner to run the hotel. Operational control with the operator: operator reports 862.9 tonnes in Scope 1 and 2 (52.9 diesel in Scope 1, 810.0 electricity in Scope 2); owner reports 0 in Scope 1 and 2 from this hotel and decides whether to show it in Scope 3.
• Same hotel under equity share: owner reports 862.9 tonnes in Scope 1 and 2, operator 0 in Scope 1 and 2.
• Under financial control, the party that directs the financial and operating policies for economic benefit reports it. The contract decides which.

Quantities are an example. The totals do not change, only which company carries them in Scope 1 and 2. Use your own bills and the factors for your year.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. Once the management agreement settles whose bills they are, the operator or owner can upload them. Senseible does not decide control for you; that is a reading of your contract.

• Operational control or equity share
• Financial control approach explained
• Hotel carbon per occupied room night
• Free calculators

Sources: GHG Protocol Corporate Accounting and Reporting Standard, Chapter 3 (control and equity share) and Chapter 4 (leased assets, outsourcing)

Last reviewed 2026-11-06. Quotes are from Chapters 3 and 4 of the Corporate Standard. The management contract reading is ours. Re-check against the contract and any buyer rule on the approach to use.