Upstream, Downstream and Everything In-Between: Developments in Assessing Scope 3 Emissions in the UK

March 9, 2026
Penelope Gane
Alina Holzhausen
Madeleine Lynch
Clare Rothwell-Hemsted

Over the past year and a half, there have been significant legal and policy developments in how the UK assesses downstream scope 3 emissions — the emissions created from burning the oil and gas they produce — for offshore oil and gas projects. So what do these developments mean for the UK and for other countries that are wrestling with how to factor in the true environmental cost of fossil fuel production?

Following the UK’s Supreme Court Finch judgment, the UK Government published new Supplementary Guidance for the environmental impact assessment (EIA) process for offshore oil and gas projects. Companies seeking drilling permission are now required to include not only the emissions from extracting reserves, but also the vastly larger scope 3 emissions from burning the extracted oil and gas. This allows the Government to weigh a project’s real climate impact and make informed decisions on whether the public interest is served by it.

To move from court rulings to real-world impact, regulators and fossil fuel companies must develop credible methods for calculating scope 3 emissions, integrate these assessments into the approval process, and ensure transparency so that the full climate consequences of fossil fuel projects are understood and addressed.

A new report by Uplift highlights key recommendations and the elements of the UK Government’s Supplementary Guidance that are critical for ensuring a robust and credible approach to assessing scope 3 emissions in any jurisdiction. By situating the UK experience within a broader international context, the report draws lessons for regulators, developers, and decision-makers seeking to align project appraisal with climate science and legally binding climate targets. 

To read the report in full click here.

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