Credible climate action requires regulators to disprove business claims that accurate carbon reporting is impossible. When money is involved, even the most tangled supply chains are traceable. Treat acquiring emissions data with the same seriousness, and problem solved…right?

This article argues the key ‘problem’ businesses cite to justify inaction on accurate Scope 3 emissions reporting is neither intractable nor technological. It’s ‘just’ a matter of taking it as seriously as they treat money, and showing good faith in evolving an accurate, free, open-source and transparent carbon reporting ecosystem.

Status quo: money matters, emissions don’t

This article presumes the following – if they appear to be stating the obvious, that’s the point:

1. Businesses take money a lot more seriously than they do greenhouse gas emissions.

If you disagree, congratulations! You’ve solved the problem of having another planet to live on.

2. Businesses give as little of their money to governments as possible.

If you disagree, you’re either not in business or have some very unhappy shareholders.

3. To extract money from businesses, governments must strictly enforce detailed rules.

This could be the job description for any ‘Taxman’. 

We’ve so normalised these three notions that we’ve lost sight of the fact they can only work in the context of a complex, comprehensive, rigorously-enforced global rule-based system.

These rules shape what ‘we’ (as a species/nation states/business sectors/cultures/societies) permit businesses to do, and not to do.

We spend so much time focusing on the marginal 1% minutiae of the global business rules that don’t obey rules – tariff wars, tax rates, cartels, financial fraud etc. – it’s easy to neglect the big picture.

For the 1% of tiny tweaks to matter, the other 99% must work.

Big pictures and details, details

Arguing about tiny differences instead of celebrating vast commonality is, for better or worse, human nature. 

Most news headlines highlight conflicts between states, within states or within communities. The actual points of contention, however, are often minor, compared to the things both sides have in common.

As religious wars have demonstrated over millennia, and domestic arguments on a daily basis, this is not a new human trait. Our willingness to obsess about a minor detail, rather than step back to appreciate the big picture, remains undiminished.

Social media’s business model depends on it. Our Silicon Valley Overlords design algorithms to optimise binary conflict over any issue, and monetise amplifying them. We’ve been happy to let them profit from stimulating our outrage, so far. 

This is why, when it comes to global heating, we’re bickering about whose turn it is to empty the bins while the house is burning down. If we’re not doomed to burn alive as we live-stream our outrage at being expected to sort the recycling, where’s the exit? 

Switching metaphors, how can we stop marching along the rut to an environmental abyss, and instead take a path to a sustainable future?

Despair and hope in the financial system

There’s cause for hope, in the same place that’s cause for despair. 

Our 200-odd nation states, by and large, follow common rules when it comes to financial accounting. Given the amount of conflict in our headlines, we should remind ourselves of the remarkable degree of consensus our financial system demands. 

In order to get along, America, Russia, China, Mozambique, Papua New Guinea, Honduras and Turkmenistan all follow identical accounting rules. Unless we all agree what constitutes a profit, loss, liability, asset or debt, the global financial system would collapse.

Our prioritisation of money (something we made up 5,000 years ago) over carbon (something all life has been made of for billions of years) might baffle an alien visitor. Indeed, this prioritisation probably the biggest single obstacle to carbon drawdown.

But it also demonstrates our ability to rise above petty conflicts, when we perceive mutual benefit.

So, to fix the climate crisis, we just need to apply the same degree of seriousness and detail we direct to bank loans and business invoices. House fire extinguished, we can all get back to bickering about who takes out the trash.

Simple, right? 

But of course, in the ‘real world’, our flawed species is driven by more complex motivations, that defy rational self-interest and logic.

Take carbon reporting. To get businesses to reduce their emissions, we first need to get them to report them, accurately and publicly – just like their financial statements. 

But instead of incorporating carbon reporting into the existing globalised, interconnected financial structures, businesses are fighting like hell to avoid any ‘extra red tape’.

How would you explain this to a smart kid?

A market metaphor

A smart kid might be unfamiliar with the production processes behind, say, the T-shirt they’re wearing, but they’ve almost certainly seen eggs being cooked and played with a Yo-yo.

So here’s a way of explaining the corporate carbon reporting problem in a way they might grasp. 

There once was a Governor in charge of a market.

The Governor’s job was to make the market run smoothly and safely.

Businesses ran the market stalls, selling us all kinds of things.

Some Businesses sold necessary things, like food. Others sold fun things, like toys.

But we started getting sick. 

Scientists said there was something being sold in the market that was making us ill.

We complained to the Governor, saying he should do something about it. 

The Governor told the Businesses ‘Give me a list of all the things you use to make your food and toys. I can then work out what’s making everyone sick, fix things, and we can all go back to how it was before’.

The Businesses told the Governor, ‘We’d love to help, but can’t. Making things is really complicated. Tracing all the things that go into our products is impossible – like  unmaking an omelette’.

Ask the smart child what’s wrong with this story, and they’ll likely be able to explain why global greenhouse gas emissions continue to rise.

Before discussing The Omelette Gambit tactic, we should understand Business’s broader strategy.

Business Inaction: strategy and tactics

What do the three premises that started this article predict businesses will do when Governments ask them to do something new?

They’ll try to avoid it. 

Any new rule or regulation, even if it doesn’t require businesses to pay the government money, gets in the way of them making more money, or as businesses put it:

• Just leave us to get on with it
• Stability is important
• Uncertainty and novelty is destabilising

Or, for short, ‘Business As Usual’.

Even businesses that started out as ‘disruptors’ to business-as-usual end up singing the same laissez-faire chorus, once they benefit from the status quo and risk becoming disruptees.

So much for the strategy: what about the tactics? 

The playground tactic of shouting ‘Shan’t!’, waggling hips and sticking tongues out sometimes works. Some mega-businesses, confident they’ve wrested sufficient power from governments, or are sufficiently global to dodge the levers of power, adopt this tactic.

More often, businesses don’t want to advertise their aversion to regulation, or contempt for regulators, too obviously. 

This requires them to come up with plausible excuses for inaction. The more plausible-sounding, the more effectively it will:

• Keep customers onside
• Reassure investors
• Paint themselves as reasonable, and the regulators as unreasonable

There are many different plausible-sounding inaction excuses, but the one currently being used by big businesses facing new carbon reporting regulation, like the EU’s Corporate Sustainability Reporting Directive (CSRD), is the Omelette Gambit.

The Omelette Gambit

It goes like this:

‘We’d love to help, but can’t. We’d love to comply with your request to report all our carbon emissions, including ‘Scope 3’ indirect emissions coming from our supply chain, but we can’t because making things is really complicated. Tracing all the things that go into our products is impossible – like unmaking an omelette. We’re all adults here. Let’s just forget about it. Or delay it. Or relax the rules. Or negotiate using these lowball guesses instead?’

Key pointers: 

• Irreversible is not the same as untraceable. Omelette ingredient suppliers leave a paper trail, unless they deliver products under cover of night for free.
• Businesses flagged with bad credit ratings find it hard to prevent customers from knowing. Why do we not have the same system for bad carbon footprints?
• We criticise people for allowing addicts or toddlers to just do whatever they want, in case they harm themselves or others. When are rules necessary, and when not?

You won’t find the phrase ‘Omelette Gambit’ in any official documentation, discussion or reporting. 

Once you know how to spot it, however, you’ll find it everywhere greenwashing meets governance. 

COPs: Where greenwashing meets governance

For two weeks every year, governments gather to pretend they mean business when it comes to regulating business to reduce emissions. 

After 30 of them, we’re now used to ‘COP’ meetings discussing climate action – or more often, justifying climate inaction. Each new COP confirms the failings of the previous ones, as emissions continue to rise.

Still, there’s what we’ve got. Governments may spend the intervening 50 weeks demonstrating the opposite, but for a fortnight a year, we hear them assert that addressing climate change is their ‘top priority’.

This makes COPs a rich environment for variations of The Omelette Gambit. Seasoned omelette-spotters recognise them in declarations of ‘victory for common sense’. They’re  often approvingly described by businesses as reflecting the ‘real world’, even when the only ‘real’ outcome is that emissions will continue to rise. The laws of atmospheric physics are less forgiving than those of governments or regulators.

Our smart kid might not understand all their talk of carbon trading, carbon offsetting, tipping points and climate justice. Instead, they might ask:

‘But why is it like ‘unmaking an omelette’? You must know who supplies your eggs, butter, salt and pepper? Don’t you have to pay them?’.

Maybe it’s the same kid from the Emperor’s New Clothes.

Tracing the emissions from your supply chain isn’t impossible. However complicated it is, the businesses concerned know who to contact, because money exchanges hands at every transaction. The tax-collecters use this to keep track of money. Give the carbon-regulators the same tools, and they could do the same for emissions.

Only much more easily. Calculating carbon footprints, while not a perfect science, is way simpler than any financial regulation, because it’s governed by the laws of physics, not abstract human constructs of money.

With the Omelette Gambit being played so often, a response that doesn’t involve shoulder-shrugging capitulation is required.

The Yo-yo Counter

After demolishing The Omelette Gambit, the smart kid came up with the Yo-yo Counter.

‘Isn’t it more like a Yo-yo maker giving you information about his wood and string suppliers? 

If they pay their suppliers, they must know who to ask’.

Globalisation has made supply chains much more complicated, but all the parties involved still pay each other.

Winemakers know where their grapes come from. Bakers can trace who grew their flour.  Coffee chains and chocolate-makers are already supposed to know the provenance of their beans. Airplanes and cars may have more components than a Yo-yo, but all kinds of other regulations require them to be responsible and accountable for every single screw, circuit, knob and nut. Hence, getting carbon footprint data from a business’s entire supply chain:

• Is not a logistical impossibility. The entire supply chain is traceable via invoices.

• Is not an overwhelming methodological challenge. Calculating carbon footprints may be an imperfect science, but it has long-established, well-understood protocols, standards and methodologies, like the Greenhouse Gas Protocol (GHGP).

• It does not require a massively complex IT solution – carbon data is much more limited than the financial data required for tax returns. No personal or financial data is required, and calculation involves addition and multiplication.

In short, it’s nothing like unmaking an omelette. We know this, because if it involved money, they’d find a way to unscramble the Omelette Gambit.

It is, however, much more like a Yo-yo maker asking his wood and string suppliers a few simple questions, hence the Yo-yo Counter. 

The Yo-Yo Counter reveals the true nature of the arm-wrestle between business and regulators to be a battle of wills between the forces of:

• climate inaction (Business As Usual) 
• climate action (governments concerned their legitimacy is threatened if they don’t do anything to stop global heating).

Armed with this understanding, how does this play out in the ‘real world’? 

Omelette Gambit: Case Study

Let’s return to the EU’s attempts to get big businesses to accurately report their carbon emissions.

By the time Brussels delivered its ‘Green Deal’ legislation to reduce EU emissions, big business had already done its best to strangle it at birth, deploying the standard Lobbying Playbook: 

• Whine (‘red tape will strangle entrepreneurs’)
• Threaten (‘red tape will raise prices and cost jobs’) 
• Plead (‘let’s negotiate a reasonable alternative’)

Business and their lobbyists managed to delay implementation, negotiating delays to give them time to prepare for the EU’s onerous new carbon reporting rules. 

But as the Jan 2026 deadline for the expiry of these grace periods approached, instead of working out how to comply, they chose to deploy The Omelette Gambit. 

It ‘worked’, as it so often does, in the sense that Brussels backed down and agreed to dilute, postpone or fudge most of the requirements of the law they passed. 

Specifically, businesses claimed the tools didn’t exist to comply with the ‘Scope 3’ reporting requirements, covering the indirect emissions of their supply chains.

If ‘Scope 3’ sounds like a minor bureaucratic detail, it’s not.  

Making Scope 3 reporting compulsory was the whole point of the EU’s new rules. 

Typically, supply chain emissions account for around 80% of most businesses’ actual carbon footprints. The EU was fed up with self-regulated ‘voluntary’ reporting, where businesses could make up their own rules, which generally involved:

• only counting Scope 1 and 2 emissions (i.e. emissions from their own operations and the energy required to power them)
• cancelling them with elaborate, but ineffective and often fraudulent, ‘carbon offsetting’ schemes
• Claiming to be ‘carbon neutral’, defying the laws of physics and common sense.

So Scope 3 reporting was no small-print quibble. Removing, diluting, or postponing it would undermine the whole spirit, and purpose, of the Green Deal legislation.

Choices, choices

It suits most businesses to present all new regulations as stifling, bureaucratic constraints, ‘tieing them up in red tape’. In truth, the comfort zone in which they operate is marked out with red tape.

Regulation is not inherently bad, but bad regulation is not great, and no regulation even worse.

It’s the job of governments to make choices about which regulations they should keep, which they should tweak, and which they should introduce. 

Good businesses, once their efforts to maintain the status quo have been defeated, adapt. Bad businesses go bust.

Different government choices produce different outcomes, when it comes to traceability, accountability, and granular detail. 

Take health care. When Americans are discharged from American hospitals, they receive a long invoice, with pages and pages itemising the cost of every injection, test, dressing and pill.

When Brits are discharged from a UK hospital, they might be given a few pills to take home, at a standard charge, or a firm handshake.

Yet both hospitals can account for every purchase made from their supply chain, and the regulations determining how they operate, and covering the procedures they perform and drugs they dispense are all heavily regulated.

We don’t talk about America having a Yo-yo health system, and Britain’s National Health Service being an Omelette system.

So why do we allow businesses to treat money and carbon reporting as if they were different?

There are many ways to set up and enforce a meaningful carbon reporting regime. 

If governments really wanted quick results for the most rapid emission reduction, they could choose to deploy the full arsenal of state power against non-compliance:

• Financial penalties and fines
• Criminal charges and imprisonment
• Public censure 

In other words, the same weapons they’ve chosen for activities deemed as being ‘serious’, like speeding, fly-tipping or protesting.

The least onerous, cheapest, and least invasive would be to support an ecosystem like See Through Carbon. 

Choices, choices.

Money vs Stories: the hope bit

This tale of governments capitulating to the interests of capital may seem bleak.

A foe as implacable as atmospheric physics is indifferent to hope and despair, but humans aren’t. Hope is what impels us to action; despair is what drags us into inaction.

Let’s take another big step back, and view the big picture again.

What do COPs, greenwashing, and elaborate carbon offsetting schemes have in common?

They exist.

Like dictators who feel the need to hold elections, both governments and businesses understand the importance of appearances. They hold many weapons unavailable to ordinary people, principally vast amounts of money, yet they still go to great lengths – and expense – to seek our approval and demonstrate they’re acting in our interests.

This performative grandstanding is why, for a while, Big Oil invested single-digit amounts in renewable energy, and plastered their advertisements and annual reports with images of solar farms and wind turbines. 

They’ve quietly stopped doing both, but – here’s the point – they’ve done it quietly. It’s why next-stage greenwashing isn’t ‘emissions-bragging’, but ‘greenhushing’. 

Businesses could have shouted ‘Shan’t’, waggled their hips and stuck out their tongues outside the COP compounds, yet they didn’t. It would ‘make them look bad’. 

Instead, they flood COP meetings with paid lobbyists and PR shills, bent on subverting meaningful action, tasked with ‘changing the story’, and ‘controlling the narrative’.

COP attendees range from oil-producing nations or those captured by Big Oil vested interests, who have no intention of interrupting business as usual, to countries threatened with extinction as a result of rising sea levels, and everything in between.

There’s asymmetry between the forces of effective climate action and the vested interests clinging on to business as usual, but it works in both directions.

Big Oil is rich in money, but impoverished in stories. The stories their lobbyists and PR shills whisper in corridors, smoke-filled rooms and expensive restaurants all require suspension of disbelief at best, and lying at worst.

Those seeking a path to a sustainable future have little money, but are blessed with story riches, because the stories they tell are true, and backed by science.

We know Big Oil finds this asymmetry threatening because they go to such lengths to discredit, ignore, diminish and deflect stories that might require them to change. So great is their fear of slippery slopes, thin ends of wedges, and pebbles precipitating avalanches, they deploy their full arsenal even to retard the requirement to be honest and transparent about the size of their carbon footprint, like the EU’s CSRD.

Why? Because they know that once their real carbon footprint is publicly visible, the public will expect to see it diminish year or year.

This vulnerability is climate activists’ most powerful weapon in taking on the Three-Headed Beasts of Government, Business and Media, united below the neck by power and money.

Better stories, and the disinfectant of sunlight.

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To learn more about the See Through Carbon ecosystem, visit www.seethroughcarbon.org