When the sustainability conversation turns to Scope 3 emissions, property owners and facility managers are often lumped together. Both manage buildings. Both hire contractors. Both face regulatory pressure from California SB 253, CSRD, and investor frameworks like GRESB and CDP. But the obligations, the data gaps, and the strategic levers are fundamentally different depending on which side of the lease you sit on.
BOMA members — building owners, asset managers, and property managers — occupy a distinct position in the Scope 3 landscape. You own or control the asset. Your tenants generate Scope 3 emissions inside your buildings under Category 13 (Downstream Leased Assets). Your contractors generate Scope 3 emissions during capital projects and maintenance under Category 1 (Purchased Goods and Services). And your investors increasingly require you to disclose both — through GRESB assessments, CDP supply chain requests, and emerging mandatory frameworks.
The Core Distinction: Asset Owner vs. Building User
IFMA’s membership is primarily the corporate occupier — the facility manager who runs operations inside a building their employer leases or owns for non-real-estate purposes. Their Scope 3 exposure is Category 1: what they buy, including the contractors they hire for restoration, maintenance, and capital projects.
BOMA’s membership is the asset side of that equation. As a property owner, your Scope 3 inventory is more complex:
- Category 1 (Purchased Goods and Services): Contractors you hire — restoration companies, mechanical contractors, janitorial services, construction firms during capital improvements
- Category 13 (Downstream Leased Assets): Your tenants’ energy consumption and operations inside your building — the hardest Scope 3 category to measure and the one GRESB scrutinizes most closely
- Category 11 (Use of Sold Products): For REITs and developers who sell or transfer properties
The tenant emission problem is uniquely a BOMA problem. Your tenants control the space. They set the thermostat, they bring in their own contractors, they determine actual energy consumption. But under GHG Protocol rules for property owners, their emissions may appear in your Scope 3 inventory — and GRESB will ask about them.
The Contractor Data Gap: Where BOMA and IFMA Converge
Here is where BOMA and IFMA face the same structural problem: restoration contractors, mechanical service firms, and specialty trade vendors who perform work on your properties have no standardized mechanism for reporting their Scope 3 emissions data back to you.
When a water damage event triggers a restoration project — emergency extraction, structural drying, mold remediation — the contractor mobilizes equipment that burns diesel, deploys materials with embedded carbon, and generates waste. All of that falls under your Scope 3 Category 1. And almost none of it gets captured in any formal emissions inventory.
The Restoration Carbon Protocol (RCP) is an emerging industry self-standard designed to fix this. It gives restoration contractors a structured methodology for calculating and communicating Scope 3 emissions data to their property owner clients — in a format that maps directly to GHG Protocol Category 1 reporting requirements.
GRESB and the Asset Manager Accountability Stack
For BOMA members managing assets in institutional portfolios, GRESB is the primary accountability mechanism. The GRESB Real Estate Assessment scores assets on environmental, social, and governance performance — and Scope 3 supply chain data is an increasingly weighted component.
GRESB participants who cannot provide contractor Scope 3 data leave points on the table. More importantly, as GRESB scoring evolves to align with TCFD and ISSB frameworks, the absence of supply chain data will increasingly flag as a material gap to institutional investors.
Green Leases: The BOMA Lever IFMA Doesn’t Have
One strategic lever available to property owners that IFMA FMs typically lack is the lease itself. Green lease clauses — requirements embedded in tenant agreements around energy reporting, contractor ESG standards, and waste management — give asset managers a contractual mechanism to drive Scope 3 data collection that facility managers simply cannot replicate.
The Institute for Market Transformation’s Green Lease Leaders program and BOMA’s own sustainability frameworks both provide templates. The opportunity is to extend the same logic to contractor agreements — requiring vendors like restoration companies to provide RCP-compliant emissions data as a condition of contract.
What This Series Covers
This BOMA Scope 3 series on Tygart Media examines the Scope 3 challenge specifically through the property owner and asset manager lens. We cover GRESB reporting obligations, green lease strategy, SB 253 and CSRD compliance for real estate entities, and the contractor data gap that sits at the intersection of both the BOMA and IFMA worlds.
The RCP thread runs through all of it — because whether you are a corporate occupier FM or a property owner, the restoration contractor showing up after a loss event is generating Scope 3 emissions that belong in someone’s inventory. This series is about making sure yours is complete.
Frequently Asked Questions
Does GRESB require Scope 3 Category 1 contractor data?
GRESB’s Real Estate Assessment includes supply chain and contractor emissions as part of its environmental data collection. While the specific weighting evolves annually, institutional investors using GRESB increasingly expect property owners to demonstrate Scope 3 supply chain visibility. Gaps in contractor data weaken your GRESB score and signal portfolio risk to asset managers.
How is a property owner’s Scope 3 different from a tenant’s?
Property owners report Scope 3 from the asset ownership perspective — including downstream tenant emissions (Category 13), upstream contractor supply chain (Category 1), and capital project emissions. Tenants report from the occupier perspective — primarily Category 1 for their own purchased services. The same building can appear in both inventories under different Scope 3 categories.
What is the Restoration Carbon Protocol and why does it matter to BOMA members?
The Restoration Carbon Protocol (RCP) is an industry self-standard that gives restoration contractors a structured framework for calculating and reporting the Scope 3 Category 1 emissions associated with their work. For BOMA members, RCP-compliant contractors provide the data needed to close the contractor gap in your GHG inventory — supporting GRESB reporting, CDP responses, and SB 253 compliance.
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