8 questions from the RFI stage, free
These come from the module as sold. The workbook adds follow-ups, a response format, a weight and a score column to each.
1. Do you publish a third-party verified greenhouse gas (GHG) inventory covering Scope 1, 2, and 3 emissions? If yes, provide: a) the most recent reporting year; b) the verification standard (e.g., ISO 14064-3); and c) the level of assurance (e.g., limited, reasonable).
Why it matters. Buyers subject to disclosure regimes (e.g., CSRD, California SB 253, ISSB-based national regimes) need reliable, verified vendor emissions data for their own Scope 3 reporting. Unverified or incomplete data creates a significant reporting gap and diligence burden for the buyer.
- States 'Yes' and provides all requested details (reporting year, standard, assurance level)
- Inventory covers Scope 1, 2 (both methods), and all material Scope 3 categories
- Verification is conducted by an accredited third party to a recognized standard (e.g., ISO 14064-3, ISAE 3410)
- States 'No' or provides an unverified inventory
- Scope 3 is omitted or marked 'in progress' indefinitely
- Verification is self-attestation or by a non-accredited party
2. What percentage of the electricity consumed by your operations and the infrastructure delivering this service is matched with renewable energy, and how is that matching verified?
Why it matters. Renewable energy matching directly affects market-based Scope 2 emissions. The instrument used (PPAs, unbundled RECs, GOs) and the granularity of matching (annual vs. hourly) materially change the credibility of the claim.
- Stated percentage with the matching boundary clearly defined (e.g., including data centers)
- Mix of instruments disclosed (PPA, REC, GO, on-site generation)
- Geographic matching to consumption regions is demonstrated
- Percentage stated without instrument breakdown or verification method
- Reliance on unbundled, low-cost RECs from distant markets with no grid connection
- No geographic correspondence between generation and consumption
3. Which ESG or sustainability reporting frameworks do you currently report against (e.g., ISSB IFRS S1/S2, GRI, CSRD/ESRS), and when was your most recent report published?
Why it matters. Framework choice determines what data the buyer can extract and how it maps to the buyer's own disclosure obligations.
- Lists specific frameworks used
- Provides a URL to the report for the most recently completed reporting year
- Provides a mapping or index showing disclosures across multiple frameworks (e.g., ISSB + GRI)
- Framework named but no actual published report available
- Most recent report does not cover the most recently completed reporting year, and no publication date is given for it
- Only a 'sustainability page' on the website with no structured disclosure
4. Do you have a published Human Rights policy aligned to the UN Guiding Principles on Business and Human Rights, and is it accompanied by a human rights due diligence process?
Why it matters. Emerging supply-chain due diligence laws (e.g., EU CSDDD, German LkSG) push human rights diligence obligations up the value chain. Buyers need to know that vendor commitments are operationalized through a formal due diligence process, not just published as policy.
- Confirms 'Yes' and provides a public policy aligned to the UNGPs
- Describes a documented due diligence process (risk assessment, mitigation, tracking, reporting)
- Identifies salient human rights issues relevant to its operations and value chain
- Policy exists but no due diligence process is in place
- No identification of salient issues specific to the tech/AI industry
- No grievance mechanism or one that is not accessible to external parties
5. Have you set a science-based emissions reduction target, and is it validated by the Science Based Targets initiative (SBTi)?
Why it matters. Validated science-based targets distinguish vendors with a credible decarbonization trajectory from those making aspirational claims. Buyers with their own SBTi commitments need supplier-base alignment to meet their Scope 3 supplier-engagement targets.
- Confirms an SBTi-validated near-term target
- States target base year and target year
- Targets cover Scope 1, 2, and (where material) Scope 3
- Target announced but not yet submitted to or validated by SBTi
- 'Net zero' claim without a documented SBTi-aligned reduction trajectory
- No Scope 3 target despite material Scope 3 emissions
6. For services hosted on third-party cloud or colocation providers, how do you account for and pass through the renewable energy attributes of the underlying infrastructure without double-counting?
Why it matters. Many AI services run on third-party infrastructure whose sustainability claims are made at the hyperscaler level. Buyers need to know whether vendor claims are distinct from, and not double-counting, attributes that the hyperscaler has already claimed.
- Names the cloud or colocation provider(s) and references their public sustainability disclosures
- Explains how attribute boundaries are drawn to avoid double-counting
- Distinguishes vendor's own procurement from inherited cloud-provider procurement
- Conflates the cloud provider's renewable claims with the vendor's own
- Does not disclose underlying infrastructure provider
- Cannot demonstrate that attributes are not double-counted
7. Are you (or your group parent) in scope for mandatory climate and sustainability disclosure regimes such as the EU Corporate Sustainability Reporting Directive (CSRD), California's climate laws (SB 253/261), or national regimes based on ISSB IFRS S1/S2 (e.g., Australia's mandatory climate reporting)? If so, specify which apply and your first reporting year.
Why it matters. Buyers globally need to understand which mandatory reporting frameworks their key vendors fall under, as this dictates the availability and format of data for the buyer's own value chain reporting. A vendor unaware of its obligations is a significant risk.
- Clear in-scope / out-of-scope determination with rationale for major regimes (CSRD, CA, ISSB-based regimes)
- First reporting year and standards being applied are identified
- Double materiality assessment completed or in progress for CSRD
- Unaware of applicability of major disclosure regimes
- In scope but has no documented readiness plan
- No double materiality assessment despite in-scope CSRD status
8. Do you publish a Modern Slavery Statement (under UK, Australian, or other regimes)?
Why it matters. AI vendors have specific supply-chain exposure through GPU/hardware sourcing and data-labeling vendors.
- Confirms 'Yes' and attaches an annual statement compliant with relevant jurisdictions
- Statement is board-approved and signed by a director
- Boilerplate statement with no risk-specific content
- No statement covers the most recent financial year for which the regime requires one
What the audit changed
A language model drafted these questions and a second model critiqued them. Three audit passes followed and made 116 changes. Three examples:
Wrong or outdated citation
Draft: (e.g., CSRD, SEC climate rules)
Now: (e.g., CSRD, California SB 253, ISSB-based national regimes)
The SEC climate rule (Release No. 33-11275) was stayed by the SEC on April 4, 2024, never required Scope 3, and on May 29, 2026 the SEC proposed rescinding it (Release No. 33-11421, Federal Register June 3, 2026; https://www.federalregister.gov/documents/2026/06/03/2026-11091/rescission-of-climate-related-disclosure-rules). The rescission was not final as of October 5, 2026. California SB 253 requires Scope 1 and 2 reporting from 2026 and Scope 3 from 2027. CARB first set August 10, 2026 for the first Scope 1 and 2 report, then on June 24, 2026 proposed moving it to November 10, 2026, pending Office of Administrative Law approval (https://www.mayerbrown.com/en/insights/publications/2026/08/california-climate-disclosure-laws-carb-finalizes-its-initial-rulemaking-resets-the-2026-deadline-and-previews-the-2027-framework). (Source corrected in pass 2.)
Wrong or outdated citation
Draft: (e.g., FTC Green Guides, EU GCD)
Now: (e.g., FTC Green Guides, EU Directive (EU) 2024/825 on empowering consumers for the green transition)
The EU Green Claims Directive has not been adopted: on June 20, 2025 the Commission announced that it intended to withdraw the proposal, and trilogue talks stopped. Directive (EU) 2024/825 applies from September 27, 2026 (Art. 4) and adds Annex I point 4c to the Unfair Commercial Practices Directive, banning a claim, based on offsetting, that a product has a neutral, reduced or positive GHG impact (https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng). (Source corrected in pass 2.)
Wrong or outdated citation
Draft: (e.g., via CDP Water Security questionnaire)
Now: (e.g., in the water security section of its CDP response)
CDP merged its climate change, water security and forests questionnaires into one corporate questionnaire in 2024; it still scores water security separately (https://www.orrick.com/en/Insights/2024/06/The-New-CDP-Reporting-Process-Key-Changes-Insights-and-Action-Items).
