GHG Protocol Opens Consultation on First Scope 2 Guidance Update Since 2015

The GHG Protocol announced public consultations on proposed updates to its Scope 2 Guidance and consequential accounting methods for electricity sector actions, marking the first major update to the Scope 2 framework since its publication in 2015. A central feature of the proposed update is a new hourly matching and deliverability requirement for market-based emissions reporting, designed to align corporate clean energy claims more closely with actual grid conditions.

Scope 2 emissions represent purchased electricity, steam, heat, and cooling, typically constituting a significant portion of corporate GHG inventories. According to the GHG Protocol, nearly 40% of global GHG emissions can be traced to energy generation, with half of that consumed by industrial and commercial entities. The proposed update introduces new requirements for how energy contracts and instruments such as renewable energy certificates are reflected in GHG inventories, establishes Scope 2 Quality Criteria for contractual instruments used in market-based reporting, and provides guidance on transparent disclosure of energy purchases.

The proposed hourly matching and deliverability requirement is the most significant and potentially contentious aspect of the update. Current practice allows companies to match their renewable energy certificate purchases to annual consumption, regardless of when during the year the clean energy was actually generated. The new requirement would align claimed emissions reductions more precisely with the time and location at which electricity is consumed, reducing the gap between reported and physical clean energy use. This represents a material tightening of corporate renewable energy accounting standards that will affect companies across markets including India.

The consultation also covers consequential accounting methods, which estimate the system-wide impact of corporate clean energy actions beyond an organization's own operational boundaries. GHG Protocol proposes keeping these consequential estimates separate from core inventory reporting to preserve comparability across companies. The consultations remain open through December 19, 2025. The updated Scope 2 Guidance will be incorporated into major frameworks including the ISSB standards and the EU's ESRS, meaning the final update will set the standard for corporate electricity emissions reporting globally.

Key figure — Consultation open through December 19, 2025