Tenant or landlord: who reports the electricity?

The boundary question, not just an accounting one

Before any kWh gets multiplied by a grid factor, a more basic question has to be answered: whose emissions are these? The GHG Protocol gives organizations a choice of boundary approach — operational control, financial control, or equity share — and for the overwhelming majority of SMEs, the practical default is operational control: report the emissions from operations you direct the day-to-day running of, whichever name is on the utility account.

That single rule resolves most tenant-landlord confusion in one line: if your staff occupy the space and you decide how the electricity gets used, it is your Scope 2, even though your landlord's name is on the bill and your landlord's contractor reads the meter. The commercial arrangement (who pays whom) and the reporting boundary (who is operationally responsible) are two separate questions, and only the second one decides whose Scope 2 line it is.

For the general Scope 1/2/3 mapping this sits inside, see Scope 1, 2 and 3, explained in 10 minutes; for the Singapore-specific grid factor referenced throughout this guide, see the Singapore grid emission factor guide.

The four tenancy scenarios, in order of data quality

1. You hold the retail electricity contract directly. The simplest case: your name is on the SP Group or retailer bill, the kWh is stated each month, and you calculate Scope 2 the same way any building owner would. No allocation needed.

2. You have a dedicated sub-meter, but the landlord holds the retail contract. Common in serviced or managed buildings. The landlord bills you monthly based on your sub-meter reading. Ask for that reading in kWh, not just the dollar amount charged — most landlords already have it, because it is how they calculated your bill in the first place.

3. Electricity is bundled into a single service charge with no sub-meter. The hardest case, and unfortunately a common one for smaller tenancies. There is no tenancy-specific kWh reading at all — only a dollar figure covering electricity alongside cleaning, security and maintenance. See "getting kWh from a reluctant landlord" below.

4. Shared common-area load — lobby, lifts, shared aircon plant. Present in almost every multi-tenant building regardless of which of the first three scenarios applies to your own unit. This load sits outside any individual tenancy and needs its own allocation, covered separately below.

Getting kWh from a landlord who won't share

Three things tend to work, roughly in order of effort:

1. Ask for the number, not the invoice. A landlord unwilling to change billing practice will often still hand over a kWh figure on request, because their own building management system already tracks it for internal purposes — the resistance is usually to changing the billing format, not to disclosing the reading. Frame the request as "the kWh figure for our tenancy for [period], for our own emissions reporting" — specific and low-effort for them to answer.
2. Use the lease's own floor-area percentage. Most commercial leases already state a tenant's proportionate share of the building for service-charge purposes. That same percentage, applied to the building's total electricity consumption (which a landlord is generally more willing to disclose than a tenant-specific breakdown), gives a defensible allocated estimate: your share % × building kWh for the period.
3. Request a sub-meter at lease renewal. If the tenancy is due for renewal, ask for a dedicated electricity sub-meter as a lease term. It converts every future reporting cycle from an estimate to a measurement, and it is a low-cost ask for most landlords compared with other lease negotiation points.

Whichever route produces the number, write down which one you used. A reviewer reading "allocated by lease floor-area share, landlord unwilling to sub-meter" understands exactly how firm the figure is; a bare number with no note reads as more precise than it actually is.

Common areas and shared aircon

Lobby lighting, lift motors, and building-wide chiller plant serving shared aircon are typically metered once, for the whole building, and never broken down by tenant. The standard treatment: allocate that shared load by floor area, the same way most leases already allocate the service charge itself.

Your allocated common-area kWh = (your floor area ÷ total leasable floor area) × building common-area kWh for the period

Add that figure to your own direct or sub-metered kWh before applying the grid factor. If your lease already states a common-area cost-sharing percentage for the service charge, using that identical percentage for the emissions allocation keeps the two consistent and easy to explain to anyone who asks why the numbers use different weightings for different purposes — they should not.

Worked example: an SG office tenant

A 15-person professional-services firm occupies 800 sqm in a Raffles Place tower with 20,000 sqm of total leasable area.

Direct tenancy electricity. The tenancy has its own sub-meter. For the 2024 data year, the sub-meter shows 48,000 kWh.

48,000 kWh × 0.4020 kgCO₂e/kWh = 19,296 kgCO₂e

Common-area allocation. The building's shared chiller plant and common areas used 900,000 kWh for the same period. The tenancy's floor-area share is 800 ÷ 20,000 = 4%.

900,000 kWh × 4% = 36,000 kWh allocated

36,000 kWh × 0.4020 kgCO₂e/kWh = 14,472 kgCO₂e

Total Scope 2, location-based.

19,296 + 14,472 = 33,768 kgCO₂e ≈ 33.8 tCO₂e

Note that the common-area share (14.5 tCO₂e) is nearly as large as the tenancy's own direct consumption (19.3 tCO₂e) here, purely because a building-wide chiller plant is a heavy shared load spread across many tenants by floor area — a reminder that skipping the common-area allocation can understate a tenant's real Scope 2 by close to half. You can run the direct-consumption half of this calculation yourself with the Singapore business electricity calculator, substituting your own sub-meter or allocated kWh figure.

What changes under market-based reporting

Everything above describes location-based Scope 2 — the default for tenants and the number most Singapore questionnaires and SGX-linked disclosures ask for first. Market-based reporting substitutes a different rate for the same kWh, but only where you hold the paperwork:

• If you hold a retail electricity contract with a green tariff or hold RECs directly, your market-based figure can differ from the grid average — but the contractual evidence needs to be yours, not the landlord's.
• If the landlord holds RECs or a green tariff for the building's supply and you are billed through a shared meter or service charge, you generally cannot claim that instrument as your own market-based figure unless the landlord has formally passed the environmental attribute through to tenants in writing — a rarer arrangement, and one to confirm rather than assume.
• Most tenants without their own electricity retail contract have no market-based adjustment available and should report location-based only, which is exactly what the worked example above does.

Why this matters beyond your own reporting

A tenant's electricity figure rarely stays internal for long. It is exactly the number a customer's procurement team asks for when their own Scope 3 disclosure needs your Scope 2 — see how to answer a customer's carbon questionnaire for how that request typically arrives and what a defensible first answer looks like. Getting the tenant-landlord allocation right once means the same figure holds up whether it feeds an internal report, an SGX-linked customer's supply-chain disclosure, or a CDP-style questionnaire.

What this boundary approach doesn't cover

• It assumes operational control, the default most SMEs use. A parent company consolidating group emissions under equity share or financial control applies different rules for which entities' electricity gets counted — check which approach your organization has adopted before assuming operational control applies group-wide.
• It is Scope 2 only. On-site fuel combustion — a landlord's backup diesel genset that you don't operate, for instance — stays out of your boundary entirely if you don't control it; a tenant's own equipment, such as supplementary aircon units you installed and run, is your Scope 1 regardless of the electricity question.
• Allocation by floor area is a reasonable default, not a universal rule. Some leases allocate common-area costs by headcount or by usage hours instead. Use whatever basis your lease already applies for consistency, and say so.
• A calculation is not assurance. These figures show their working — factor, source, allocation method — but remain your organization's estimate, prepared from the evidence available, not an externally verified figure.

One habit that prevents every dispute

Whatever split you land on, write it down as a one-page boundary memo: which meters are yours, which allocation method applies to shared areas, who holds the source documents, and which reporting year convention you follow. Date it, store it with your evidence, and re-confirm it whenever the lease changes hands. Nearly every tenant-landlord emissions disagreement we see traces back to two parties applying different, unwritten assumptions to the same building — a memo costs ten minutes and settles the argument before it starts.

Sources

• GHG Protocol — Corporate Standard, Chapter 3 (organizational boundaries: operational control, financial control, equity share): ghgprotocol.org
• GHG Protocol — Scope 2 Guidance (location-based vs market-based methods): ghgprotocol.org
• EMA — Singapore Energy Statistics (grid emission factor, Singapore Open Data Licence): ema.gov.sg
• SGX RegCo — sustainability reporting requirements: sgx.com/regulation