# Which of a lender's or investor's holdings does the Greenhouse Gas Protocol require in Category 15, and which are optional?

Canonical: https://senseible.earth/answers/category-15-which-loans-are-required-or-optional

Required: equity made with your own capital, debt with a known use of proceeds, and project finance. Optional: debt with no stated use of proceeds, managed investments and client services, and other instruments such as insurance contracts. For general corporate debt, your share is your part of the investee's equity plus debt.

## Required in Category 15

Equity emissions are shared out by your equity share. Debt with a known use of proceeds and project finance are shared out by your share of total project costs, equity plus debt.

- Equity investments made with the company's own capital and balance sheet, including subsidiaries, associates, joint ventures and small stakes, where not already in Scope 1 or 2 (a threshold is allowed for small stakes).
- Debt investments with a known use of proceeds, such as a loan or bond for a specific power plant.
- Project finance, as sponsor or lender.

## Optional in Category 15

- General corporate purposes debt, where the use of proceeds is not specified.
- Investments managed for clients with their capital, such as funds, plus underwriting, issuance and advisory services.
- Other instruments such as pension funds, securitised products, insurance contracts, credit guarantees and credit default swaps.

## General corporate debt

For general corporate debt, the guide says to use the equity methods, with your share worked out as your proportion of total equity plus debt. It adds that these methods apply to long-term debt, and that short-term debt such as revolving credit facilities raises accounting problems the guidance does not address.

## Screen first

Because a lender may have many investments, the guide recommends a screening with the average-data methods first, to find the investments with the highest emissions and focus primary data collection on those.

## Insurers

Insurers are in this too: the guide treats premiums as the insurer's own capital, so equity investments made from premiums are required, with a threshold allowed, while accounting for insurance contracts is not required.

## A term loan with no named project, with example numbers

- Loan: rupees (Rs) 5 crore (50 million). Borrower's total equity plus debt: Rs 50 crore. Share: 5 / 50 = 10%
- Borrower's Scope 1 and 2 for the year: 12,000 tonnes of carbon dioxide equivalent (CO2e)
- Optional Category 15 line: 12,000 x 10% = 1,200 tonnes CO2e
- If the same loan were for a named plant, the share would instead be your debt over that project's total cost, equity plus debt

The loan, balance sheet and emissions figures are our example numbers. The rule that the share is your part of total equity plus debt is from the guide's Box 15.2.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not calculate Category 15 or hold investee data.

- [Shareholdings in Category 15, with threshold](https://senseible.earth/answers/equity-investment-specific-method-and-small-stake-threshold)
- [Project finance as sponsor or lender](https://senseible.earth/answers/lender-project-finance-emissions-category-15)
- [Fixed deposits and mutual funds](https://senseible.earth/answers/company-fixed-deposits-and-mutual-funds-scope-3)
- [December 2025 changes to financed emissions rules](https://senseible.earth/answers/ifrs-s2-category-15-financed-emissions-relief)

Sources: [Greenhouse Gas Protocol Technical Guidance for Calculating Scope 3 Emissions, Category 15 (Tables 15.1 and 15.2, Box 15.2)](https://ghgprotocol.org/sites/default/files/2022-12/Chapter15.pdf)

Last reviewed 2026-11-05. Required and optional lists follow Tables 15.1 and 15.2 of the guide, which are taken from the Scope 3 Standard.