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

Guillermo Llopis

cs.CYJun 9, 2026

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

Authors: Guillermo Llopis

Organizations: SOMA AI, Barcelona

Abstract

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.

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