Buried on page 35 of Indian Oil Corporation Limited's (IOCL) latest BRSR filing is a number that changes how you think about the company's climate impact: 353.88 million tonnes of CO2.
That's not Indian Oil's operational emissions. Those are 22.5 million tonnes — the CO2 from running its 11 refineries, the furnaces, the flares, the process units. The 354 million tonnes is something else entirely. It's what happens after the fuel leaves the refinery gate.
It's the petrol burned in cars. The diesel in trucks. The jet fuel in planes. The LPG in kitchens. Every litre of fuel Indian Oil refines and sells eventually gets burned, and that burning produces CO2. The GHG Protocol calls this Scope 3, Category 11: “Use of Sold Products.”
Indian Oil, to its credit, reported this number. Most Indian oil companies don't.
Indian Oil (IOCL): What the Net Zero Target Covers
FY 2024-25. Verified by TUV India (reasonable assurance). Million tonnes CO2e.
Covered by net zero 2046 target
Not covered by any target
Source: IOCL BRSR FY2024-25, Principle 6 Q7, page 35. Scope 1 = 21.24 Mt (CO2: 20.94 + CH4: 0.10 + N2O: 0.20). Scope 2 = 1.29 Mt. Scope 3 = 353.88 Mt. Standalone basis. Reasonable assurance by TUV India Private Limited.
Look at that chart. Indian Oil's Scope 3 is 15.7 times its operational emissions. For every tonne of CO2 its refineries produce, the products those refineries make generate nearly 16 tonnes more when customers use them.
Indian Oil reported 354 million tonnes of Scope 3 — more than NTPC's entire operational footprint, more than India's verified steel and cement sectors combined. And its net zero target doesn't cover a single tonne of it.
A Quick Primer: Why Scope 3 Matters for Oil & Gas
For most industries, Scope 1 and 2 capture the bulk of emissions. A steel plant's biggest source of CO2 is the blast furnace it operates (Scope 1). A cement kiln's biggest source is the chemical reaction inside it (Scope 1).
Oil and gas is different. A refinery's operations are a small fraction of its total climate impact. The vast majority comes from what happens downstream — when customers burn the fuel. This is why Scope 3 is not optional context for this sector. It is the story.
The Three Scopes, Explained
Scope 1 — Direct Emissions
Emissions from sources the company owns or controls. For a refinery: the furnaces, flares, and process units on site.
Scope 2 — Purchased Energy
Emissions from electricity, steam, or heat the company buys from the grid. Usually small for oil & gas since refineries generate their own power.
Scope 3 — Value Chain (incl. product use)
Everything else: raw material extraction, transport, and — for oil & gas — the emissions when customers burn the petrol, diesel, and jet fuel the company sells. For a refiner, this is typically 80-95% of its total climate footprint.
Scope 3 reporting is voluntary under India's BRSR framework (SEBI). The GHG Protocol, which defines these categories, considers Scope 3 “Category 11: Use of Sold Products” mandatory for a complete carbon footprint.
Who Reports Scope 3 — and Who Doesn't
We track 15 oil and gas companies. Only five disclose Scope 3 emissions in their filings. The pattern is revealing.
Who Reports Scope 3 — and Who Doesn't
Scope 3 reporting is voluntary in BRSR. Only 5 of 15 oil & gas companies in our tracker disclose it.
| Company | S1+2 | Scope 3 |
|---|---|---|
| IOCL80.6 MMTPA | 22.5 Mt | 353.9 Mt |
| HPCL23.8 MMTPA | 5.8 Mt | 137.4 Mt |
| MRPL15 MMTPA | 5.7 Mt | 50.4 Mt |
| ONGCUpstream | 9.4 Mt | 22.7 Mt |
| Oil IndiaUpstream | 1.4 Mt | 17.8 Mt |
| Reliance68.2 MMTPA | 37.9 Mt | Not reported |
| BPCL35.3 MMTPA | 10.5 Mt | Not reported |
| GAILGas T&D | 3.9 Mt | Not reported |
Source: BRSR filings. Reporting years differ (noted in FY column above). ONGC's lower Scope 3 ratio reflects upstream operations (extraction, not refining). MRPL is an ONGC subsidiary; HPCL is majority-owned by ONGC. Reliance operates the world's largest single-site refinery complex (Jamnagar, 68.2 MMTPA) but does not disclose Scope 3 in its BRSR. Full rankings
Indian Oil's 354 Mt is the largest Scope 3 figure in our entire database across all sectors. HPCL follows at 137 Mt — a ratio of 23.8x its operational emissions (the highest ratio in the sector). MRPL, an ONGC subsidiary, reports 50 Mt.
Then there's the gap. Reliance Industries operates the world's largest single-site refinery complex at Jamnagar (68.2 MMTPA combined capacity) and reports 37.9 Mt of operational emissions — but does not disclose Scope 3 in its BRSR. BPCL, India's third-largest refiner at 35.3 MMTPA, also does not report it.
To be clear: Scope 3 reporting is voluntary under SEBI's BRSR framework. Companies that report it — Indian Oil, HPCL, ONGC, MRPL, Oil India — deserve credit for the transparency. The question is what happens when that transparency meets the net zero targets.
The 6% Problem
Every oil and gas company in India with a net zero target scopes it to Scope 1 and 2 only. Not one includes Scope 3.
Net Zero Targets: What They Actually Cover
Every oil & gas net zero target in India covers only operational emissions (Scope 1+2). None include the emissions from burning the fuel they sell.
Zero oil & gas companies in India have SBTi-validated targets. Coverage % calculated as Scope 1+2 / (Scope 1+2 + reported Scope 3). Companies without Scope 3 disclosure cannot have coverage calculated. BPCL, Oil India, and others have targets but are not shown due to incomplete data.
The arithmetic is simple. Indian Oil's total reported emissions (Scope 1 + 2 + 3) are 376.4 Mt. Its net zero target covers 22.5 Mt. That's 6% of its actual footprint.
HPCL is even more striking. Its Scope 3 (137 Mt) is 23.8 times its operational emissions (5.8 Mt). Its net zero 2040 target covers less than 4% of its total reported footprint.
ONGC, as an upstream producer (exploration and extraction), has a lower Scope 3 ratio (2.4x) because the downstream burning happens at the refineries that buy its crude. But it holds majority stakes in both HPCL and MRPL — whose combined Scope 3 is 188 Mt.
Indian Oil's net zero by 2046 covers 6% of its reported climate footprint. HPCL's net zero by 2040 covers less than 4%. These are not net zero targets. They are operational efficiency targets with a different label.
What the Data Shows
Three things stand out from the filings:
Scope 3 dwarfs everything else for oil & gas.
Indian Oil: 15.7x. HPCL: 23.8x. Oil India: 12.3x. For this sector, reporting only Scope 1 and 2 is like measuring a hospital's impact by its electricity bill. The real footprint is in the products.
India's biggest refiner doesn't disclose Scope 3.
Reliance Industries runs the world's largest single-site refinery complex and targets net carbon zero by 2035. It reports 37.9 Mt of Scope 1+2 but does not disclose Scope 3 in its BRSR filing. Without that number, the target's coverage cannot be assessed.
Zero SBTi validation in the sector.
Not one Indian oil and gas company has submitted its climate targets to SBTi for independent validation. Net zero years range from 2035 (Reliance, GAIL) to 2046 (Indian Oil) — all self-declared, all Scope 1+2 only, with no external body testing the credibility of the path to get there.
A note on double counting
Scope 3 emissions from oil companies overlap with Scope 1 emissions of their customers. When Indian Oil reports 354 Mt of Scope 3, some of that is the diesel burned in power plants already counted in NTPC's Scope 1. This is by design — the GHG Protocol intentionally allows this overlap so that each company in the value chain sees its full footprint. You cannot add Scope 3 across companies without double counting. But you can — and should — use it to evaluate whether a single company's climate target covers the emissions it is responsible for.
India's oil and gas companies collectively reported over 580 million tonnes of Scope 3 in their filings. That's the number no net zero target in the sector covers. And the biggest refiner in the country doesn't report it at all.
Methodology Note
All figures are from BRSR filings submitted to BSE/NSE or sustainability reports filed with exchanges. Where marked “verified,” we confirmed each number against the original PDF, the specific page, and Principle 6 Q7. Scope 3 figures are as reported by each company; we have not independently calculated product-use emissions. Reporting years differ across companies (noted in each chart). The 580 Mt aggregate is the sum of all reported Scope 3 figures (IOCL 353.9 + HPCL 137.4 + MRPL 50.4 + ONGC 22.7 + Oil India 17.8 = 582.2 Mt, rounded). Net zero target scopes are from company sustainability pages and BRSR climate commitment sections. Full methodology
Indian Oil, Reliance Industries, BPCL, HPCL, and ONGC were contacted for comment prior to publication. Any responses received will be incorporated into this analysis.
Corrections: If any figure in this story is wrong, email hello@sustainabilityforyou.com with the correct number and the source filing. We will verify, fix, and credit you in our public corrections log.
Analysis #3
Published October 4, 2026 · Sustainability For You