If you are a facility manager trying to understand your Scope 3 ESG obligations, you have almost certainly encountered three acronyms that sound similar but operate very differently: GRESB, CDP, and SB 253. Each one creates real obligations for FM operations — but they apply to different organizations, require different data, and serve different audiences. This article maps the landscape so you can determine which frameworks govern your program and what each one specifically requires from your contractor data collection.
GRESB: The Asset-Level Framework
GRESB (the Global Real Estate Sustainability Benchmark) is an investor-driven ESG assessment framework for real estate portfolios. It is primarily used by property owners, REITs, and real estate investment managers who need to demonstrate sustainability performance to institutional investors.
Who it primarily affects: BOMA-type property owners and real estate investors. If you are an FM at a corporate occupier — a company that uses its buildings for operations, not as investment assets — GRESB is typically your asset manager’s problem, not yours.
What it asks about contractors: GRESB’s Real Estate Assessment includes questions about green building certifications, energy performance, and sustainability policies for construction and renovation projects. It does not currently have a Scope 3 contractor data requirement comparable to GHG Protocol Category 1. However, GRESB is evolving its framework to incorporate more supply chain data as investor pressure increases.
IFMA relevance: Low to medium, unless your corporate occupier organization owns its real estate portfolio and participates in GRESB as both occupier and investor. In that case, GRESB and GHG Protocol obligations overlap.
CDP: The Voluntary Disclosure Framework
CDP (formerly the Carbon Disclosure Project) operates a global disclosure system that allows companies to report their environmental data to investors, purchasers, and the public. CDP’s Supply Chain program specifically requests Scope 3 data from suppliers — which means your organization may receive CDP questionnaires from your own customers asking about the emissions associated with the services you provide to them.
Who it primarily affects: Companies that participate voluntarily in CDP disclosure, and companies whose corporate customers require supplier CDP responses. CDP is used by many large corporate occupiers as a sustainability disclosure mechanism.
What it asks about contractors: CDP’s corporate questionnaire includes Scope 3 Category 1 disclosure. If your organization reports to CDP, you are expected to include Category 1 emissions from your contractors — including restoration vendors — in your response. CDP accepts activity-based and spend-based estimates; it also tracks year-over-year improvement in data quality.
IFMA relevance: High for FM teams at organizations that participate in CDP or whose parent companies have signed CDP commitments. CDP is often the first Scope 3 reporting pressure FM teams experience, because it is voluntary but publicly visible — investors and customers can see whether your organization reports and how complete your data is.
SB 253: The Mandatory Disclosure Framework
California SB 253 — the Climate Corporate Data Accountability Act — is mandatory, not voluntary. It requires companies with over $1 billion in annual revenue doing business in California to disclose Scope 1, 2, and 3 emissions on a phased schedule: Scope 1/2 starting in 2026 (for fiscal year 2025 data), Scope 3 starting in 2027 (for fiscal year 2026 data). Reports must be independently verified by a CARB-registered third-party auditor.
Who it primarily affects: Any company doing business in California with over $1 billion in annual revenue. This is a wide net — it captures many large corporate occupiers regardless of headquarter location.
What it asks about contractors: SB 253 uses GHG Protocol methodology, which requires reporting all material Scope 3 categories. Category 1 (contractors and suppliers) is a mandatory category under the GHG Protocol for most organizations. Restoration contractors are a Category 1 source. SB 253’s independent verification requirement means your auditor will scrutinize the quality of your Category 1 data — spend-based estimates will be accepted but flagged as lower quality than activity-based data.
IFMA relevance: High for FM teams at large corporate occupiers doing business in California. This is the framework with the hardest deadline and the most compliance consequence.
EU CSRD: The European Mandatory Framework
For completeness: the EU Corporate Sustainability Reporting Directive (CSRD) applies to large EU companies and, in some cases, non-EU companies with significant EU operations or revenue. CSRD requires disclosure under the European Sustainability Reporting Standards (ESRS), which include Scope 3 under ESRS E1. Like SB 253, it requires third-party verification and covers supply chain emissions.
IFMA relevance: High for FM teams at multinational corporate occupiers with European operations. CSRD and SB 253 overlap in their Scope 3 requirements, meaning data infrastructure built for one framework largely serves both.
The Framework Decision Matrix
| Framework | Voluntary or Mandatory | Who It Applies To | Contractor Scope 3 Required? | IFMA FM Priority |
|---|---|---|---|---|
| GRESB | Voluntary (investor-driven) | Real estate owners and investors | Not directly — asset-level focus | Low (unless dual occupier/investor) |
| CDP | Voluntary | Companies disclosing to investors | Yes — Category 1 in corporate questionnaire | Medium-High (if your org participates) |
| SB 253 | Mandatory | >$1B revenue, does business in CA | Yes — GHG Protocol Category 1 | High (if threshold met) |
| EU CSRD | Mandatory | Large EU companies + some non-EU | Yes — ESRS E1 Scope 3 | High (if European operations) |
What This Means for Contractor Data Collection
If your organization is subject to SB 253, or participates in CDP, or both — you need Category 1 contractor data. The specific data points required are the same across all three frameworks because they all use GHG Protocol methodology as their basis. Building a contractor data collection process that satisfies GHG Protocol Category 1 requirements will satisfy SB 253, CDP, and CSRD simultaneously.
The Restoration Carbon Protocol is designed to produce exactly that data. Its output — the per-job RCP Carbon Report — maps to Category 1 inputs for all three frameworks. FM teams that implement RCP-compliant vendor requirements do not need to build separate data collection processes for each framework.
Frequently Asked Questions
If my company participates in GRESB, do I still need to collect contractor Scope 3 data?
GRESB’s current framework focuses on asset-level energy and water performance rather than supply chain Scope 3 data. However, if your organization also participates in CDP or is subject to SB 253 or CSRD, those frameworks require contractor Category 1 data regardless of GRESB participation. Check which frameworks your sustainability team is reporting to.
Can I use one dataset to satisfy multiple frameworks?
Yes. Because GRESB, CDP, SB 253, and CSRD all use GHG Protocol methodology as their technical basis, data collected to satisfy one framework’s Scope 3 Category 1 requirements is compatible with the others. Build the data collection process once; use it across all frameworks your organization reports to.
Part of the IFMA Scope 3 series on tygartmedia.com. Sources: GRESB, CDP, California Air Resources Board / SB 253, GHG Protocol.
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