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Greenhouse Gas Protocol (GHG Protocol) has taken a significant step forward with the release of its Actions and Market Instruments (AMI) Phase 1 White Paper, opening a 60-day Request for Information (RFI) seeking stakeholder feedback on one of the most anticipated and complex areas of greenhouse gas (GHG) accounting and reporting.
At its core, AMI is an effort to answer a persistent challenge: how should companies account for the real-world impacts of their climate actions – especially those that sit outside existing (physical) Scope 1, 2, and 3 emissions inventories.
Today, companies are increasingly investing in mitigation beyond their direct operations, yet much of this activity is not consistently or credibly captured in existing reporting frameworks. GHG Protocol’s AMI seeks to change this.
The White Paper aims to set out ideas, principles and options, inviting feedback from across the market. It reflects the results of Phase 1 standard development work with the Technical Working Group and responds directly to calls from stakeholders for clearer, more comprehensive guidance.
A Shift to Multi-Statement Reporting
The most significant development proposed in the AMI White Paper is to move to a multi-statement reporting structure.
Historically, GHG Protocol standards have focused on the physical GHG inventory providing a best estimate of the “physical reality” of corporate emissions. While this remains the foundation, AMI proposes to expand beyond this by introducing three additional statements:
- A market-based inventory, capturing emissions linked to contractual and procurement choices beyond existing Scope 2 market-based method for example commodity certificates for low-carbon materials such as steel, cement, chemicals or sustainable aviation fuel;
- A GHG impact statement, quantifying the broader effects of company actions – for example if a company carries out projects to avoid emissions within its value chain. The quantification will be done based on consequential accounting methods that capture how the action changes overall emissions relative to a baseline scenario;
- Non-GHG indicators, tracking key metrics that are not quantified in tons of carbon – for example the portfolio share of low carbon technologies and product such as EV share of an automaker or % green steel sold of a steelmaker as well as financial indicators, e.g., investments in renewable energies.
Why This Matters
Taken together, this signals a step-change in how climate action is reported – based on clear quality criteria and safeguards, ensuring credibility and integrity of the reporting. The goal is not to add complexity unnecessarily, but to better reflect the full picture of corporate climate actions that are increasingly part of decarbonization strategies.
Today, companies are, for example, investing in the green steel or low carbon cement, purchase of sustainable aviation fuel certificates, signing power purchase agreements or buying carbon credits. While these activities can reduce greenhouse gas emissions in the real world, right now, much of that impact is invisible in corporate GHG reporting.
As a result, companies struggle to report these activities consistently, while investors and stakeholders lack clear information that can affect their decision-making, including the ability to differentiate credible and less credible actions and market instruments.
AMI seeks to align reporting more closely with the reality of how decarbonization is happening by making all these contributions visible while avoiding greenwashing through solid quality requirements. It is about unlocking the ability to tell the full story of climate action so companies can demonstrate, standardize and compare the tangible impact of their interventions, not just their operational footprint.
What Happens Next?
The 60-day Request for Information marks the beginning of a critical phase. Stakeholder feedback will help shape the next stage of development, with a full draft standard for public consultation expected in 2027.
For companies, investors and practitioners, this is a key moment to engage and to help shape how climate action is accounted for in a credible way and ultimately, how it is valued.
Respond to the Request for Information here, which is open from March 31 to May 31, 2026. If you have any questions about the RFI, please refer to this document.
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