What makes Scope 3 disclosure in Malaysia mostly modelled rather than measured?

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Scope 3 Emissions in Malaysia Remain Largely Modeled Due to a Lack of Standardised Localised Carbon Accounting Frameworks

The disclosure of Scope 3 emissions within Malaysia's construction sector is predominantly based on modelled data rather than direct measurement. This situation stems from the absence of a localised carbon accounting framework specifically for the Malaysian construction industry, a lack of standardised protocols for quantifying on-site emissions, and no mandated methodology for how these figures should be derived. Consequently, even when companies report Scope 3 emissions, these are often estimates generated through modelling tools, such as those offered by Bursa Malaysia's CSI platform, which are explicitly identified as estimates and not audited data.
Absence of a Standardised Localised Framework for Carbon Accounting

Malaysia's construction sector currently lacks a comprehensive, locally developed carbon accounting framework. While the National Sustainability Reporting Framework (NSRF) mandates sustainability reporting, it does not specify the emission factors to be used, the on-site activities that need to be accounted for, or the precise methodologies for calculating carbon figures. This gap means that two construction firms with similar operations could produce vastly different carbon figures while still being compliant with current reporting requirements, highlighting a fundamental lack of methodological consistency.
Limited Data and Scope of Existing Embodied Carbon Inventories

The Construction Industry Development Board (CIDB) Embodied Carbon Inventory serves as a primary reference for the sector, consolidating emission factors from various sources. However, its current database contains approximately 600 material records, which is insufficient for a sector with thousands of specifications. Crucially, when local data is unavailable, the inventory defaults to international figures calibrated to foreign manufacturing conditions and energy mixes, introducing potential inaccuracies. Furthermore, this inventory does not encompass carbon emissions from on-site construction activities, such as fuel combustion from machinery and waste disposal, which globally constitute 37% of the industry's total carbon footprint.
Challenges in Quantifying On-Site Construction Emissions

A significant portion of the construction industry's carbon footprint originates from on-site activities, including the operation of heavy machinery like excavators and cranes, waste management, and temporary works. Despite their substantial contribution, there is no standardised quantification mechanism in Malaysia to accurately measure these emissions. The NSRF's mandate for disclosure does not provide guidance on how to address these on-site emissions, leaving a critical component of the sector's carbon footprint unaddressed through consistent measurement.
The Transition from Modeled Estimates to Verified Data

The current reliance on modelled Scope 3 emissions is a consequence of the underdeveloped data infrastructure. While platforms like Bursa Malaysia's CSI offer useful tools for generating estimates, they explicitly state that the data is not audited. As regulators across the Asia-Pacific region, including in Australia and Singapore, move towards requiring verifiable disclosures, Malaysian construction firms that continue to present Scope 3 estimates as measurements risk facing credibility issues. A move towards primary supplier data and assurance requirements is necessary, but the necessary standardised, localised data and methodologies are still in development.

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What makes Scope 3 disclosure in Malaysia mostly modelled rather than measured?

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