Building Internal Capability for Emissions Reporting: Roles, Responsibilities and Team Upskilling

‍In short: Emissions reporting is not one person's job. It is shared across the board, finance, operations, sustainability, risk and site teams, with one named owner for every data source. Hiring a sustainability professional helps, but on its own it is not enough. The organisations that cope build capability deliberately, decide the right mix of in-house skills, tools and outside advice, and record who owns what in a data management plan so the work does not fall over when one person leaves.

This article builds on our pillar guide, how to build an emissions data management plan. If you are starting from scratch, read that first.

Why is emissions reporting a whole-of-organisation job?

The most common reason emissions reporting stalls is not the measurement. It is that no one owns it, or one person owns all of it. Both fail in the end.

Climate reporting touches almost every part of a business. The energy data sits with facilities, the fuel and waste data sit with operations, the travel data sits with finance, the supplier data sits with procurement, and the disclosure itself has to satisfy risk, legal and the board. No single person has line of sight over all of that, which is why treating it as the sustainability team's private project sets the team up to fail.

The standard itself assumes this. The governance pillar of AASB S2 asks an entity to describe how it decides whether it has people with the right skills and competencies to oversee climate strategy, or whether those skills need to be developed. 

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Who needs to be involved, and what does each role do?

Reporting works when the load is spread across the functions that already hold the data or the accountability. In practice that looks like this.

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You do not need all of these as separate hires. In a smaller organisation, one person may wear several of these hats. 

Does hiring a sustainability manager solve it?

Hiring helps, but it does not solve the problem on its own.

Purpose Bureau's People and Systems report found that around 74 percent of Group 1 organisations employed at least one dedicated sustainability professional by the start of mandatory reporting, and that the industries with the highest share of such professionals were roughly 50 percent more prepared than those with the lowest. So having someone clearly matters, but beyond that first hire, headcount is not a reliable indicator of readiness. 

In Utilities, Energy and Renewables, for example, 85 percent employed a sustainability professional, yet only 30 percent were both framework-aligned and audit-ready. The lesson is that capability is necessary but not sufficient.

What separates the prepared from the rest is not the number of people, it is whether accountability is distributed and whether the systems underneath are any good. 

The same report found that organisations using a dedicated reporting platform were more prepared than spreadsheet-heavy ones more than half the time. People and systems together, not people alone.

How do you map data ownership?

The practical tool for distributing accountability is a simple ownership map. Many teams use a RACI-style approach, applied not to the project as a whole but to each emission source.

For every source, you decide who is:

• Responsible (R). The person who actually does the work of collecting or entering the data. For electricity, that might be a named site manager.
• Accountable (A). The one person who owns the outcome for that source and answers for its quality. Often the sustainability lead or, increasingly, finance.
• Consulted (C). The people whose input you need, such as procurement for a supplier data request.
• Informed (I). The people who need to know the result, such as the board or the CFO.

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Table above: each organisation tailors owners to its own structure. Exactly one Accountable owner per source (here the sustainability lead for data quality), while overall disclosure accountability sits with the board and finance increasingly owns the reporting process.

The single most important rule here is the one that comes straight from a good data management plan: name a person, not a team. "The sustainability team handles it" is exactly the answer that unravels under assurance, because it means no one in particular does. A source with a named owner gets done. A source owned by everyone gets done by no one.

Ready to assign an owner to every source? Download our free Emissions Data Management Plan template and map responsibility across your team in one place.

What if you are a team of one, or none?

Not every organisation has a sustainability team. Plenty are doing this with one stretched person, or with someone in finance or operations who picked it up on top of their day job. If that is you, the answer is not simply "hire someone" or "learn everything yourself." It is to get the mix right across three levers.

• In-house capability. Decide the minimum you genuinely need to hold internally. Usually that is enough understanding to own the boundary, the methodology and the relationships, so you are directing the work rather than outsourcing your own judgement.
  
• Tools and systems. This is where the right platform earns its place, because it lowers the specialist knowledge required to keep reporting running. When data entry is a form or a bulk upload rather than a modelling exercise, a site manager or an accounts clerk can own a source without being a carbon expert. Systems let you distribute the work without distributing the expertise.
  
• External advice. Bring in specialists for the parts that genuinely need them, such as materiality assessment, assurance readiness, or a complex Scope 3 category, rather than for the whole job. Used well, advisory fills specific gaps and transfers knowledge back to your team, instead of becoming a permanent dependency.

The organisations that manage this well are the ones that made a deliberate choice about what to hold, what to systematise, and what to buy in.

How do you build capability and remove key-person risk?

The danger in emissions reporting is that sometimes all the knowledge lives in one person’s head. When that person goes on leave, or leaves altogether, reporting grinds to a halt and the next person starts from scratch. This is key-person risk, and it is very common.

Building capability is how you defuse it, and it is more about culture and systems than about training courses. A few things help: 

1. Bring other functions in early, so the knowledge is shared from the start rather than hoarded by necessity. 
2. Document as you go, so the method is written down rather than remembered. 
3. Treat capability as something you grow across the business, including at site level, rather than something that lives with a single expert.

The AICD's guide for directors makes a similar point at board level: organisations are having to build climate skills deliberately, through training and through embedding ownership across teams, not by assuming the capability already exists. What is true for the board is true all the way down.

Case study: Morris Group

At Morris Group, a multi-site operator, the COO described the real challenge as working out who should drive the work: finance, operations, head office, or the individual businesses. Rather than answer that all at once, they made what she called "a conscious decision to focus on some key parts of the business first," then shared the roles out from there instead of piling everything on one desk. Capability, in other words, was something they built deliberately and in stages.

How does the data management plan make roles explicit?

All of this stays theoretical until it is written down somewhere. That is what the data management plan does. 

The plan lists every emission source and, alongside each one, a named owner and how the data is collected. It tells an auditor exactly who stands behind each number. And it means that when someone leaves, the reporting does not leave with them, because the ownership was documented rather than remembered.

It also makes the distribution visible. When you can see every source and its owner in one place, the gaps and the pile-ups become obvious. If one person's name is against thirty sources, you have found your key-person risk. If a source has no name at all, you have found the thing that will go missing at year-end.

The board sets the mandate for all of this. If you want to go deeper on the board mandate above the day-to-day work, read our article on governance. But the mandate only means something when the work beneath it is owned, and the plan is where that ownership lives.

FAQ

Whose job is emissions reporting? It is shared. The board owns oversight and sign-off, finance increasingly owns the reporting process, the sustainability lead owns methodology and coordination, and operations, procurement, risk and site teams own the data sources they hold. One named person should be accountable for each source.

Do we need to hire a sustainability manager? It helps, but it’s only one step of many. Around 74 percent of Group 1 organisations had at least one sustainability professional, and having one is associated with better preparedness. Beyond that first hire, headcount alone does not predict readiness. Distributed ownership and good systems matter more than team size.

What if we only have one person, or no one, on sustainability? Get the mix right across three levers: hold the essential judgement in-house, use tools to lower the specialist knowledge needed so others can contribute, and bring in external advisers for specific gaps like materiality or assurance readiness rather than the whole job.

How do we avoid key-person risk? Distribute ownership, document the method as you go, and build capability across functions rather than relying on one expert. A data management plan with a named owner for every source is what keeps reporting running when someone leaves.

How does a data management plan help with roles and responsibilities? It records a named owner and a collection method for every emission source, which makes accountability explicit, transferable to new staff, and visible enough that you can spot where the work is piling up on one person.

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Ready to assign an owner to every source? Download our free Emissions Data Management Plan template below.