GHG Protocol Scope 2 Revision: What the Latest Consultation Feedback Means for Companies

The GHG Protocol asked the market whether it should require companies to match renewable energy purchases to the hour and location of consumption. The market answered, and the answer was no.

Of 909 respondents on hourly matching, 70 per cent gave little or no support. Among companies specifically, only 12 per cent were in favour and 82 per cent indicated low or no support. On the deliverability proposal, 59 per cent of 875 respondents were opposed.

That is an unusually clear result, and the GHG Protocol has already signalled that it will change direction rather than press ahead. The consultation drew nearly 1,100 responses from 56 countries, the Technical Working Group is reconvening to reconcile them, and the organisation has said it will explore whether offering multiple reporting approaches, reflecting different theories of change, could better respond to the range of views.

Its own characterisation of the feedback is worth noting alongside the percentages, because it differs in emphasis. The GHG Protocol describes broad general support for stronger Scope 2 accounting, with divergent views pointing to a need to balance accuracy, consistency and credibility against implementation burden and regional data availability. Both readings are defensible from the same dataset, which tells you how contested the redraft will be.

For sustainability teams, this means the Scope 2 revision is now genuinely unsettled in a way it was not six months ago. Here is what was proposed, what came back, and what to watch.

What Was On The Table

The GHG Protocol launched its corporate standards revision in November 2022. Scope 2 reached public consultation on 20 October 2025, following recommendations from the Scope 2 Technical Working Group and approval by the Independent Standards Board. The consultation ran to 31 January 2026 after an extension.

Three market-based changes carried most of the weight.

Hourly matching. Unless exempt, energy attribute certificates would need to come from the same hour in which the electricity was consumed. Current practice permits annual matching, so a company can buy certificates generated in June against consumption in December and report zero emissions for that electricity.

Deliverability. Certificates would have to come from generators connected to the buyer via an electrically linked grid. Where no clear market boundary exists, price-based indications of available transmission capacity between adjacent grids could serve as evidence.

A marginal impact method, intended to capture the emissions consequences of procurement decisions rather than attribute existing generation.

The location-based method was also in scope, with proposals for an updated emission factor hierarchy, a requirement to use the most precise emission factors accessible, and a new definition of accessible data meaning publicly available, free and from credible sources.

Around those sat feasibility provisions: load profile approaches, exemption thresholds targeted at smaller consumers, a legacy clause protecting investments made under existing rules, and phased implementation with staged effective dates.

Two further elements are easy to miss. Residual mix definitions would be updated, with fossil-only rates applying where residual mix data is unavailable. And a standard supply service provision would let companies claim their pro-rata share of the grid supply mix.

What The Feedback Said

The results, published this summer, show opposition concentrated precisely on the two headline proposals.

On hourly matching, 909 respondents produced 70 per cent little or no support, 22 per cent in favour, 7 per cent neutral. Filtering to companies alone sharpens it further: 12 per cent support against 82 per cent low or no support.

On deliverability, 875 respondents produced 59 per cent opposition, 30 per cent support, 11 per cent neutral. Among companies, 19 per cent supported it and 71 per cent indicated low or no support.

The split by respondent type is the more interesting finding. Nonprofit organisations and academic representatives divided roughly evenly on hourly matching, with support and opposition at similar levels. So this was not a straightforward case of everyone rejecting a stricter standard. It was corporate reporters and their advisers pushing back hardest, while the research and advocacy community remained genuinely divided.

The GHG Protocol's chief executive has characterised the overall picture as a plurality of respondents wanting a more rigorous standard, which sits somewhat awkwardly against the headline percentages and tells you something about how contested the interpretation of this feedback will be.

Why Companies Objected

The objections were substantive rather than reflexive, and they cluster into four arguments worth understanding because they will shape the redraft.

Long-term contracts get harder to justify. Power purchase agreements and virtual PPAs are how new renewable projects get financed, because they de-risk development by guaranteeing offtake. Respondents argued that hourly matching and deliverability requirements together make those contracts less valuable to the buyer, more expensive and riskier, which weakens the primary mechanism driving new capacity.

Narrower market boundaries push investment away from where it helps most. The deliverability proposal restricts procurement to electrically linked grids. Objectors argued this discourages investment in regions with the greatest decarbonisation potential, because those regions may not be connected to where large corporate buyers consume power.

Voluntary participation could fall. Several respondents warned that increased reporting burden and cost would discourage participation in voluntary schemes such as RE100. A standard that is technically more accurate but drives companies out of renewable procurement altogether is a poor trade.

Data simply is not available everywhere. In its response, EFRAG raised the point that granular emission factors are not universally available, that a one-size-fits-all approach places disproportionate burden on smaller entities and less mature electricity markets, and that new definitions such as physically connected to the value chain lack clear technical criteria and risk inconsistent application across jurisdictions. EFRAG also questioned the cost against the benefit of a mandatory stricter hierarchy for emission factor selection, and recommended gradual introduction with pilot studies before any mandatory adoption.

A recurring theme across responses was not outright rejection but a request to make granular matching optional rather than mandatory, broaden exemptions, strengthen legacy protections and extend phase-in periods.

The Detail Lost In The Argument

One technical point deserves attention because a good deal of the alarm rests on a misreading.

The draft does not require 100 per cent hourly coverage to comply. A company achieving 70 per cent hourly matched coverage reports 70 per cent. It does not fail. The proposal changes how the number is calculated and reported, not what score a company must achieve.

That distinction matters for planning. The initial shift is to carbon accounting rather than to procurement targets. Nothing in the Scope 2 revision itself moves a corporate renewable energy target, and nothing would require a specific hourly matching level next year. Target-setting bodies decide that, separately.

The GHG Protocol has been explicit on this division of responsibility. Reporting actions separately from Scope 2 does not determine whether or how they count toward specific goals. Those determinations remain with disclosure and target-setting bodies that use the accounting standards.

What Is Not Changing

Amid the argument, several things in the proposal were not contested and are worth stating plainly.

Dual reporting stays. Companies would continue to report Scope 2 emissions under both the location-based and market-based methods. The structure of the framework is unchanged.

Scope 2 remains attributional. The revisions are explicitly grounded in an attributional value chain inventory. Consequential metrics, meaning estimates of the emissions impact of a decision rather than attribution of existing emissions, require separate methodologies and separate reporting.

That second point produced one of the clearer governance outcomes. The marginal impact method proposed by the Technical Working Group will not advance in its current form under the Scope 2 process, following an Independent Standards Board vote of seven against to four in favour. Work on avoided emissions and consequential accounting moves instead to the cross-sectoral Actions and Market Instruments workstream. A separate consultation on electricity sector consequential accounting ran alongside the Scope 2 one.

The Development Getting Least Attention

The Scope 2 results did not arrive alone. On 29 July 2026 the GHG Protocol published a package of three updates: the Scope 2 consultation results, preliminary feedback from its Request for Information on the Actions and Market Instruments workstream, and confirmation that it will combine its corporate carbon accounting standards with those of the International Organization for Standardization.

The third is the structurally largest. Building on a strategic partnership signed in September 2025 and identified as a milestone in the COP30 action agenda, the two organisations will publish a single co-branded corporate standard. It consolidates the GHG Protocol's Scope 1, Scope 2, Scope 3 and Actions and Market Instruments standards with ISO 14064-1, the international standard for greenhouse gas quantification and reporting. A two-part structure is envisaged, with general requirements and the physical inventory in Part 1 and Actions and Market Instruments in Part 2. An integrated public consultation on the complete draft is planned for the second quarter of 2027, with final publication estimated for the fourth quarter of 2028.

This ends a long-standing split between the framework most companies use for corporate reporting and the one commonly used for verification, which has forced internationally active companies to reconcile two similar but non-identical systems.

Two practical points. Existing standards remain in effect until the co-branded standards are published, with transition periods still to be defined, so nothing changes for reporters in the near term. And the Actions and Market Instruments workstream is being synchronised with the Scope 2 revision, with both feeding into the consolidation, which means the Scope 2 outcome is no longer a standalone question.

The Timeline As It Stands

The Technical Working Group reconvenes to reconcile consultation comments, and the draft will be revised with the Independent Standards Board. A second public consultation on Scope 2 topics is expected during 2026. Final publication of the revised standard has been anticipated for 2027, with some observers suggesting 2027 to 2028 given the scale of redrafting now required.

Implementation would then phase in over multiple years, with staged effective dates giving organisations, data providers, utilities and service platforms time to adapt, and early adoption encouraged.

Two dependencies sit on top. Reporting frameworks including the science-based targets initiative, CDP and CSRD will apply their own transition periods, so the date a company actually has to comply is not the date the standard publishes. And the science-based targets initiative has already made hourly matching optional under its new corporate net-zero standard, for now, which is a meaningful signal about where the ecosystem is landing.

What Sustainability Teams Should Monitor

Watch for the multiple approaches question. The GHG Protocol's stated intention to explore offering several reporting approaches reflecting different theories of change is the most consequential signal in its response. If it lands there, companies may face a choice of method rather than a single mandatory one, which changes preparation entirely and raises comparability questions for users of the data.

Track the exemption thresholds. The proposals contemplate exemptions for smaller electricity consumers. Where those thresholds land determines whether granular matching is your problem at all.

Follow the legacy clause closely. If you hold long-term PPAs or VPPAs signed under current rules, the eligibility and duration terms of any legacy protection directly affect the value of contracts already on your books. This is the provision with the most immediate financial consequence.

Do not renegotiate contracts on the basis of a consultation draft. The proposals have not been adopted, the feedback was strongly negative, and the drafters have signalled they will change course. Making procurement decisions now against rules that may not survive is a genuine risk.

Start improving data granularity anyway. Whatever the final requirements, the direction across every part of the GHG Protocol revision is toward more temporally and geographically specific data. Hourly consumption data, better emission factors and clearer documentation of certificate provenance are useful under the current standard and every plausible version of the new one.

Keep both methods clean. Dual reporting is not in question. If your location-based figure receives less attention than your market-based one, that gap will be exposed by the proposed emission factor hierarchy changes.

The honest read on where this stands is that the GHG Protocol proposed a significant tightening, the market rejected the two central mechanisms by wide margins, and the organisation has acknowledged it needs to reconsider. Companies should expect the final standard to be meaningfully softer than the consultation draft, probably with optionality, broader exemptions and longer phase-ins. What they should not expect is for the direction to reverse. Every signal across carbon accounting points toward more granular data, and the argument now is about pace and mandate rather than destination.

Monitoring Checklist

1. Note that the consultation closed on 31 January 2026 and results published this summer showed 70 per cent little or no support for hourly matching and 59 per cent opposition to deliverability.

2. Treat all proposals as drafts, since the Technical Working Group is reconvening to reconcile nearly 1,100 responses from 56 countries.

3. Watch whether the redraft offers multiple reporting approaches rather than a single mandatory method.

4. Track exemption thresholds for smaller electricity consumers, which determine whether granular matching applies to you.

5. Follow the legacy clause terms if you hold PPAs or VPPAs signed under current rules.

6. Diarise the second public consultation expected during 2026 and plan to respond.

7. Do not renegotiate procurement contracts against unadopted proposals.

8. Remember that partial hourly coverage is reported as a percentage rather than treated as failure.

9. Continue dual reporting under both location-based and market-based methods, which is not in question.

10. Improve hourly consumption data and certificate provenance documentation now, since the direction of travel is settled even if the requirements are not.

11. Monitor how the science-based targets initiative, CDP and CSRD apply their own transition periods on top of the standard.

12. Track the planned co-branded corporate standard with the International Organization for Standardization, consolidating Scope 1, 2, 3 and Actions and Market Instruments with ISO 14064-1, with consultation in the second quarter of 2027 and publication estimated for the fourth quarter of 2028.

Position as of August 2026. The Scope 2 revision is at draft stage, no proposals have been adopted, and the GHG Protocol has indicated the consultation draft will be revised in response to feedback. Confirm current status against the GHG Protocol and take professional advice for your circumstances.

Sources

Greenhouse Gas Protocol, International Organization for Standardization, ESG Dive, Carbon Herald, Greenhouse Gas Protocol Scope 2 Guidance 2015, Scope 2 Technical Working Group and Independent Standards Board, European Financial Reporting Advisory Group, Science Based Targets initiative, Argus Media, ESG Today, Trellis, PwC, Ever.green, Renewabl, Generation Impact Global

This article is intended for general professional information and does not constitute legal, financial, or investment advice.