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India's Scope 3 roadmap: what a new study proposes for 90 million small suppliers
India's move towards value-chain emissions reporting could leave more than 90 million micro, small and medium enterprises (MSMEs) struggling to keep up. That is the warning in a study from the Chintan Research Foundation (CRF), reported on 12 November 2026, which sets out a three-phase roadmap for Scope 3 accounting in India.
What does the study find?
The study, "Building India's Scope 3 Architecture: A Phased Roadmap for Credible, Interoperable, and Equitable Emissions Accounting", by Shagun Mamgain and Sandra V. Kurian, looks at India's readiness as top-listed companies prepare for mandatory disclosures under SEBI's BRSR Core framework. It argues that disclosure rules have moved quickly while the infrastructure for reliable emissions accounting has lagged.
- About 27% of major Indian companies already disclose value-chain emissions, against a global average of 15%.
- More than 9 crore (90 million) MSMEs could face significant compliance challenges.
- Companies use a mix of frameworks, including the GHG Protocol and GRI Standards, with no unified national baseline.
- India has no nationally validated emission factor database and no standard reporting boundaries, which makes real decarbonisation hard to tell apart from a change in method.
Why are small suppliers the most exposed?
MSMEs sit inside the supply chains of large companies, so their emissions feed their customers' Scope 3 figures. As those customers report, suppliers will be asked for data and expected to cut their own Scope 1 and 2 emissions. Many small firms already juggle several regulatory obligations and have no dedicated staff for greenhouse gas accounting.
The study warns that sudden requirements could raise costs for small firms and push some out of corporate value chains, and it calls for support mechanisms. Some large companies already run supplier capacity-building programmes. How buyers can keep the ask manageable is covered in our post on supplier survey fatigue.
What roadmap does the study propose?
- Methodology. Standardise boundary protocols, identify the material Scope 3 categories for each sector cluster, build a national emission factor database and make reporting work across frameworks.
- Capacity building. Formalise supplier engagement led by anchor firms, create targeted support for MSMEs and expand the pool of trained third-party auditors.
- Enforcement. Introduce mandatory third-party verification and legally binding disclosure requirements, and integrate reporting with emerging carbon markets.
The sequence puts common methods and support for smaller firms ahead of mandatory verification and enforcement.
