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Accounting for AI Inference in Corporate GHG Inventories: A Four-Tier Methodology for Scope 3 Category 1 Reporting

arXiv 2606.10660 ↗First posted 9 Jun 2026cs.CY cs.AIcited by 0

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Abstract (arXiv)

AI inference services -- API subscriptions, enterprise chat tools, and SaaS products with embedded AI features -- fall unambiguously within Scope 3 Category 1 under the Corporate Sustainability Reporting Directive (CSRD), which requires disclosure for fiscal years starting January 2024. Yet no standardised methodology exists for including them in corporate GHG inventories. Current practice either omits the category entirely or applies a generic economic input-output (EEIO) factor calibrated to the ICT sector as a whole, overestimating AI inference emissions by 10-40x relative to physically derived alternatives. We propose a four-tier framework that matches estimation precision to the data organisations can realistically obtain, progressing from direct token-based physical estimation -- using GPU energy benchmarks and regional grid carbon intensities -- down to a spend-based EEIO fallback for services where no usage data exists. Emission factors are derived from peer-reviewed GPU energy benchmarks (ML.ENERGY Leaderboard v3), confirmed grid carbon intensities (EPA eGRID 2023; Ember 2023), and published water use effectiveness data (Li et al., 2025). Applied to a 200-person European firm, the framework yields a total below 1 tCO2e, illustrating that the compliance challenge is methodological rather than magnitude-driven. We further document a water-carbon trade-off that current ESG tools do not surface: Sweden's hydro-dominated grid delivers the lowest carbon intensity in our dataset but the highest water footprint, with direct implications for data centre location strategy.

Key facts. No citing papers in the map yet (data through 14 Oct 2026). Builds on 3 of its 15 references that are in the map. First posted on arXiv 9 Jun 2026.

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References · 3

  1. 2019Energy and Policy Considerations for Deep Learning in NLPcited by 1,254
  2. 2021Carbon Emissions and Large Neural Network Trainingcited by 567
  3. 2019Energy Usage Reports: Environmental awareness as part of algorithmic accountabilitycited by 44

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