Last week, the Greenhouse Gas Protocol (GHGP) announced significant developments in its multi-year update of the corporate greenhouse gas accounting standards that underpin many voluntary and mandatory climate reporting frameworks. Along with the release of a Summary of Feedback from its Scope 2 public consultation, GHGP announced plans to work with the International Organization for Standardization (ISO) to develop a single, harmonized global GHG accounting standard. The initiative is intended to consolidate GHGP's Corporate Standard, Scope 2 Guidance, Scope 3 Standard, and forthcoming Actions and Market Instruments standard with ISO 14064-1, with an integrated public consultation currently planned for the second quarter of 2027.
The Scope 2 consultation generated nearly 1,100 responses from stakeholders in 56 countries. The GHGP summarized the principal areas of agreement and disagreement that will inform the Technical Working Group's continuing deliberations before any revisions are finalized. The Summary identifies several recurring themes that emerged across stakeholder feedback, including:
- Broad support for improving the accuracy, consistency, and credibility of Scope 2 accounting, while differing on how best to achieve those objectives.
- Continued debate regarding proposals to require hourly matching and deliverability for the market-based method, with differing views as to whether those changes would improve scientific integrity and support ambitious climate action or instead create unnecessary implementation burdens.
- Significant concern regarding implementation complexity, data availability, assurance implications, administrative burden, and interoperability with existing reporting frameworks, particularly for smaller organizations and jurisdictions where more granular electricity data may not be readily available.
- Differing views regarding the appropriate balance between improving the decision usefulness and environmental integrity of Scope 2 reporting and maintaining comparability, feasibility, and reasonable implementation costs.
The Executive Summary describes two competing theories of how the market-based method should promote climate action. Some respondents favored more rigorous requirements, such as hourly matching and deliverability, to strengthen the relationship between reported emissions and electricity actually consumed. Others argued that additional complexity could discourage participation in voluntary renewable electricity markets and undermine the market-based method's effectiveness by increasing costs and implementation burdens.
Informed by a Working Group experienced in-house counsel, sustainability professionals, and advisors, the Society responded to the consultation in January 2026. Among other recommendations, the Society urged the GHGP to preserve the existing conceptual distinction between the location-based and market-based methods, avoid changes that could undermine established renewable electricity procurement mechanisms, carefully consider implementation feasibility and reporting burden, and maintain interoperability with existing reporting and assurance frameworks. Many of these themes are reflected throughout the GHGP's Summary.
The GHGP’s release does not include proposed revisions to the Scope 2 Standard itself. Rather, the GHGP states that the consultation feedback will be used to inform further development by its Technical Working Group and subsequent review by the Independent Standards Board as the Scope 2 revision process continues.
The Society will continue to monitor the Scope 2 revision process and participate in future consultations as appropriate. Members interested in participating in the Society' s GHG Protocol Working Group should contact Randi Val Morrison.
See “Vast Majority of Companies Oppose Tougher GHG Protocol Scope 2 Reporting Proposals” (ESG Today) and “GHG Protocol adjusts standards update timelines” (Trellis).
This post first appeared in the weekly Society Alert!