ESG SDDS Wiring-Guide

Actual operational energy consumption (based on consumption from smart/manual meter readings or invoices) for the proportion of portfolio that is in landlord’s control. The term 'actual' refers to energy consumption that is not estimated. A landlord controlled area is the one for which the landlord is determined to have “operational control” where operational control is defined as having the ability to introduce and implement operating policies, health and safety policies, and/or environmental policies. If both the landlord and tenant have the authority to introduce and implement any or all of the policies mentioned above, the area should be reported as landlord controlled (ref: GRESB). 
 

To calculate actual energy consumption under landlord control, report the actual operational energy used within the areas over which the landlord has operational control, expressed in kilowatt hours (kWh) per year.
 
Only actual data should be included in this indicator. Actual data means consumption derived directly from verifiable sources such as utility invoices, smart meter outputs, or manual meter readings, and excludes any estimated or modelled values (ref: GRESB). If no actual data is available, report under the relevant estimated indicator (ESG3.1.3).

The indicator includes all forms of energy used in landlord-controlled areas, covering both renewable and non-renewable energy consumption, such as:
    •  Electricity (from grid or on-site generation)
    •  Fuel (natural gas, oil, diesel)
    •  District heating and cooling (DH&C), excluding transmission and distribution (T&D) losses (ref: CRREM).

Note 1: Actual data derived from verifiable sources (e.g. invoices, meters) aligns with PCAF data quality scores 1 and 2, which represent the highest quality levels. This supports consistency for managers also reporting in line with PCAF.
Note 2: Fugitive emissions (e.g. refrigerant leaks from HVAC or cooling systems) are not considered energy consumption but are classified as Scope 1 (ESG3.3) under the GHG Protocol.
Note 3: Landlord-controlled areas may include common areas, shared services (e.g. lifts, HVAC), outdoor lighting, or single-let buildings where the landlord manages operations. In line with GRESB, energy data is classified by control type as follows:  

• Whole Building – Landlord Controlled: Owner fully controls the building (e.g. single-tenant or vacant).
• Shared Services – Landlord Controlled: Owner controls shared areas (e.g. lighting, HVAC in corridors, lifts).
• Tenant Controlled: Data provided voluntarily or estimated for tenant spaces.
• Whole Building – Landlord Controlled: Owner fully controls the building (e.g. single-tenant or vacant).

Note 4: Where the landlord procures energy on behalf of tenants but does not have the ability to influence or manage how much energy is consumed within tenant-demised areas, this consumption should be classified as tenant-controlled and reported under ESG3.1.1. In line with the operational control approach of the ESG SDDS (consistent with GRESB, CRREM, PCAF), this energy use should be reported as Scope 3 emissions of the landlord. By contrast, CSRD/ESRS applies a financial control perspective. If, for regulatory reasons, the user is required to report under financial control, this should be agreed with investors and transparently disclosed by including a clear statement or comment.
Note 5: If an asset was acquired or disposed of during the reporting year, the reported consumption should correspond only to the period during which the asset was owned by the reporting entity. For example, if an operational asset is acquired on 30 September 2023 and the entity reports on a calendar-year basis, consumption should reflect 1 October to 31 December 2023, unless the participant chooses to report performance data for the period prior to acquisition. In that case, the reported figure should align with the full period of performance data provided (ref: GRESB).

This indicator supports the accurate reporting of actual energy use under direct operational control, which is essential for accurate GHG emissions accounting and energy performance monitoring.