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On October 20, 2025, GHG Protocol launched two public consultations: one focuses on updates to the Scope 2 Guidance (2015) which addresses inventory accounting, while the other seeks feedback on consequential accounting methods for estimating avoided emissions from electricity-sector actions, which will feed into work underway in the Actions and Market Instruments workstream.
To help stakeholders navigate these proposals and participate effectively, GHG Protocol has compiled answers to frequently asked questions about both the consultation process and the content of the proposals.
All related materials can be accessed here.
Table of Contents
Big Picture Questions
1. Why is GHG Protocol updating its Scope 2 Guidance (2015)?
2. What stays the same in the scope 2 revision proposal - and what is new?
3. How were these proposed changes to the Scope 2 Guidance (2015) developed?
Questions on Consultation Process
Questions on Content of Proposals
8. What are the specific thresholds and criteria for organization exemptions in the proposal?
13. How will scope 2 revisions align with target and disclosure frameworks?
16. How do the proposed revisions describe ‘accessible’ emission factors in my region?
17. Will purchased heat, steam, and cooling still be reported in scope 2 under the proposed revisions?
18. How does the revision consider regions where EACs are sourced from connected market boundaries?
19. How are the revisions describing what qualifies as Standard Supply Service in my region?
Big Picture Questions
1. Why is GHG Protocol updating its Scope 2 Guidance (2015)?
A decade after publishing the Scope 2 Guidance (2015), an update is both timely and necessary. This revision is an opportunity to make improvements based on how the standard has been applied in practice and how power systems have become cleaner, more complex, and more interconnected than ever before. Expectations for credible, investor-grade climate data have grown significantly, underscoring the need for greater accuracy and consistency. Updating scope 2 accounting will help ensure that reported emissions more faithfully reflect today’s evolving electricity markets and data systems, and that companies can report purchased and consumed energy with improved accuracy, comparability, and alignment to financial reporting standards.
2. What stays the same in the scope 2 revision proposal - and what is new?
The proposed scope 2 framework retains the dual location-based and market-based reporting structure that companies know well. What is new are proposed revisions to the location- and market-based methods with the aim of strengthening scientific integrity, support for informed decision-making that advances ambitious climate action, alignment with external reporting frameworks, and feasibility for global users of the Scope 2 Standard.
Key proposed updates include:
- An updated location-based emission factor hierarchy and definition of “accessible” emission factors,
- A requirement to use the most precise location-based emission factors accessible for which activity data is also available,
- The introduction of deliverability requirements for all market-based reporting, and hourly matching requirements for voluntary claims by organizations above a large consumption threshold. Hourly matching would not apply to residual mix reporting,
- Clarified guidance that a reporting entity may not claim more than its pro-rata share of Standard Supply Service (SSS), ensuring that both SSS and voluntary contractual instruments align with the updated quality criteria and are applied in the correct order,
- An updated definition of residual mix and where no residual mix is available, use of fossil only rates, and
- Feasibility measures to ease implementation of proposed revisions.
The proposed revisions seek to keep the familiar framework, but to sharpen it with more accurate and comparable data that supports companies in taking ambitious climate action. Thousands of companies rely on GHG Protocol for both voluntary and mandatory disclosure — ensuring implementation remains feasible is therefore a central priority.
Proposed feasibility measures for public consultation include the use of load profiles for organizations without hourly data, exemptions to hourly matching for organizations under a threshold, consideration of a legacy clause and other transition tools for existing investments and phased implementation timelines to give the market time to adapt.
In addition, the proposed revisions seek to draw clear distinctions between inventory and project accounting, laying the groundwork for the Actions and Market Instruments Technical Working Group to further develop comprehensive reporting frameworks that support both methods of emissions accounting.
3. How were these proposed changes to the Scope 2 Guidance (2015) developed?
The Scope 2 Public Consultation is the product of a rigorous, transparent multi-stakeholder process that reflects GHG Protocol’s long-standing approach to standards development. Every step of the process is designed to be inclusive, credible, and guided by GHG Protocol’s Decision-Making Criteria and Hierarchy (see Annex A), which balance integrity, impact, and feasibility ensuring that the final scope 2 update reflects both technical rigor and practical feasibility for global users.
The scope 2 revision has been shaped by extensive stakeholder input, beginning with the 2022–2023 global survey and proposals process. Since September 2024, the Scope 2 Secretariat has convened a Technical Working Group (TWG) of energy and accounting experts from around the world representing academia, government entities, non-profits, and private sector organizations. The Technical Working Group provided expert input on the specific topics and issues under consideration and jointly developed recommendations. These recommendations were then reviewed by the GHG Protocol Independent Standards Board (ISB), comprised of additional accounting experts with a diversity of perspectives, which provides oversight across the full suite of GHG Protocol standards to ensure neutrality, credibility, and balance across stakeholder interests. The ISB approved the proposed revisions for public consultation.
Questions on Consultation Process
4. Will consultation feedback be made public and attributable to respondents, and will there be an option to submit comments anonymously?
Yes, all feedback will be made public and will be attributed to the respondent, whether a company, association, or individual. All respondents will be required to provide their name, affiliation, and country as part of their submission. In the very exceptional case that full attribution would prohibit a respondent’s ability to participate, respondents may request anonymity by selecting the appropriate option in the demographic portion of the public consultation feedback form. In such cases, name, affiliation, and country will still be collected, but will not be included in the publicly available record of feedback.
5. Are participants required to answer every question, or can they respond only to sections relevant to their organization?
All questions, except those clearly marked in the demographics section, are voluntary. Participants may skip any questions that are not relevant to their organization’s activities, experience, or expertise, and are encouraged to focus their input where they can provide the most insight. Many questions provide the opportunity to give additional feedback on earlier responses.
Questions on Content of Proposals
6. For the proposed revisions, will purchasing Energy Attribute Certificates or “EACs” (e.g., GECs, GOs, RECs, etc.) count towards reducing a company’s scope 2 market-based emissions?
Yes. Under the proposed revisions, EACs will remain a useful tool for allocating emissions from electricity to end users of electricity, through the market-based method. However, under the current proposal, for companies above the exemption threshold, EACs will need to be physically deliverable and time-matched to each hour of electricity consumption.
7. How are existing investments/long term contracts (such as PPAs) being considered in the proposed revisions?
The Scope 2 Public Consultation outlines the spectrum of feedback received on how to treat existing long-term contractual instruments, such as power purchase agreements, that could have their eligibility within a scope 2 inventory affected by updated quality criteria. To address this, two potential transition approaches are presented for feedback in the consultation: one that would apply a “legacy clause” to grandfather existing instruments under current criteria for a defined period, and another that would require all reporters to transition simultaneously to the new requirements after a defined lead time. This issue may be most relevant for financial or virtual power purchase agreements that do not involve direct delivery of electricity to the buyer. Contracts supplying power physically within the reporter’s own grid region, such as physical PPAs, could remain fully countable within scope 2 inventories.
A legacy clause might allow organizations to count contractual instruments from existing arrangements within scope 2 market-based accounting, even when those instruments do not meet the proposed hourly matching and deliverability requirements.
An alternative approach under consideration is a single effective date, where all reporters would transition simultaneously to the new requirements after a defined lead time to give companies time to consider changes to existing arrangements. This approach would be supported by disaggregated disclosure during the transition period.
The Scope 2 Public Consultation contains several questions on the design of a legacy clause as well as on the alternative single effective-date approach, including questions about how each option could affect reporting organizations and users of GHG Protocol reporting data. We encourage active participation in the consultation to inform further development of a legacy clause and provide feedback on the alternative approaches for transition.
8. What are the specific thresholds and criteria for organization exemptions in the proposal?
While the Technical Working Group (TWG) and Independent Standards Board (ISB) both support exemptions to the hourly matching requirement for organizations under a threshold, the specific threshold requires additional input to ensure a balanced alignment with the GHG Protocol’s Decision-Making Criteria and Hierarchy (see Annex A): Integrity, Impact, and Feasibility. Options under consideration include load-based thresholds, based on GWhs of load per market boundary, or SME designations at the corporate level. The Scope 2 Public Consultation contains several questions on exemption thresholds, and we encourage active participation in the consultation to inform further development of the exemption design.
9. If companies want to support clean energy projects outside of their market boundary, where should they report the resulting EACs they get from these projects based on the proposed revisions?
Project development outside deliverable market boundaries can still have significant emissions impact, and the Independent Standards Board (ISB) has affirmed the need for clear accounting and reporting methods to assess and reflect the impacts of these types of actions, recognizing that their effects may vary across different projects and contexts. Since these actions occur outside the reporting organization’s value chain (i.e., outside the deliverability boundary), they do not fall under inventory accounting within the proposed Scope 2 Standard revisions. The Actions and Market Instruments Technical Working Group is advancing work started by a subgroup of the Scope 2 TWG to further develop accounting methods for consequential actions and the Consequential Electricity Sector Emissions Impact Consultation will inform that ongoing work.
10. How will companies be able to implement hourly matching under the proposed scope 2 revisions when the necessary data and grid infrastructure do not yet exist in many regions?
A phased implementation period could allow multiple years between approval of the proposed updates and when they are required to be adopted, allowing time for infrastructure that supports hourly matching to continue to develop. In addition, load profiles can be used to translate annual or monthly electricity data into hourly electricity data to enable conformance with new proposed requirements.
11. My country has limited grid transparency and fragmented renewable energy policies. How will the revisions accommodate companies facing such limitations?
GHG Protocol is a global standard, and ensuring broad participation and applicability are central to the goals for this update. To that end, the Scope 2 Public Consultation includes several questions designed to collect region-specific feedback on feasibility and the impact of the proposed revisions. GHG Protocol welcomes all feedback that can ensure the updated Standards are usable and equitable across all regions of the world.
12. How are the proposed revisions considering costs and administrative burden for companies engaged in voluntary clean-energy procurement?
Ensuring feasibility is central to this update. To that end, the Scope 2 Public Consultation includes several questions designed to collect feedback on administrative and cost impacts of the proposed revisions. GHG Protocol recognizes that improving the accuracy, transparency, and comparability of scope 2 data may require more granular information and new systems, which could increase effort or cost for some reporters. The consultation therefore seeks input on how to best balance the benefits of greater precision and decision-useful information against potential increases in complexity and burden. GHG Protocol welcomes all feedback to help ensure our Standards appropriately balance integrity, impact and feasibility.
13. How will scope 2 revisions align with target and disclosure frameworks?
GHG Protocol is committed to advancing harmonization across the GHG accounting and reporting ecosystem. Observing Entities to the Independent Standards Board (ISB), including the Science Based Targets initiative (SBTi), CDP, the European Financial Reporting Advisory Group (EFRAG), the Global Reporting Initiative (GRI), and the International Sustainability Standards Board (ISSB), participate directly in ISB meetings and deliberations, where they can provide formal input on key issues under consideration. Through this collaboration, the Observing Entities help ensure that proposed updates reflect the needs of major reporting and target-setting systems while maintaining the integrity and independence of GHG Protocol’s decision-making and standard-setting process. GHG Protocol uses this structured engagement to promote alignment across standards, including the Scope 2 Standard, so that its accounting guidance remains interoperable with leading disclosure and target-setting frameworks globally. This goal is enshrined in GHG Protocol Decision-Making Criterion 2B (see Annex A). GHG Protocol is also working with ISO as a part of the recent landmark partnership to ensure standards harmonization.
14. Is it a requirement to match a residual mix emission factor on an hourly basis under the proposed revisions?
No. In the proposed revisions, hourly matching is not required when using a residual mix emission factor. While residual mix emission factors should reflect the highest temporal precision available for the relevant market boundary (e.g., hourly, monthly, or annual), organizations are not required to match electricity use to the residual mix on an hourly basis.
For activity data not matched with voluntary contractual instruments or Standard Supply Service, reporting entities would be able to use annual or monthly electricity consumption data and apply an annual or monthly residual mix factor. Different approaches can be applied within the same reporting year, such as using hourly matching for hours covered by contractual instruments and an annual residual mix for the rest.
15. Under the proposed revisions, is it a requirement to match Standard Supply Service on an hourly basis?
In the proposed revisions, if a reporting entity does not meet an exemption threshold, contractual instruments from Standard Supply Service reported under the market-based method shall match the same hour as the energy consumption to which the instrument is applied. Where hourly Standard Supply Service data is not available load profiles may be used to estimate hourly data.
If a reporting entity meets an exemption threshold, they may match contractual instruments from Standard Supply Service to the same month or year as the energy consumption to which the instrument is applied.
16. How do the proposed revisions describe ‘accessible’ emission factors in my region?
Emission factors are considered “accessible” if they are free, publicly available, and from a credible source. The Scope 2 Public Consultation outlines the core principles for this requirement and seeks stakeholder feedback on whether these principles are appropriate and sufficient for ensuring data integrity and feasibility. While the consultation focuses on confirming these foundational principles, the detailed technical and procedural requirements for emission factor data providers will be developed in Phase 2 of the Scope 2 workstream, as outlined in the Scope 2 Standard Development Plan. GHG Protocol encourages respondents to use their consultation feedback to suggest how the new Scope 2 Standard should define a credible source and share examples of credible sources from their region.
17. Will purchased heat, steam, and cooling still be reported in scope 2 under the proposed revisions?
Yes, purchased heat, steam, and cooling will continue to be reported in scope 2 under GHG Protocol. This topic is scheduled to be addressed as part of phase 2 with a view to providing additional guidance. Please see the Scope 2 Standard Development Plan for more details.
18. How does the revision consider regions where EACs are sourced from connected market boundaries?
The proposed updates to quality criteria 5 refine the market boundary to require that all certificates are sourced from energy generation deemed deliverable. The first option serves as the default approach. If certificates are sourced within the defined market boundary, no further demonstration is needed to show alignment with the deliverability principle. The other two methodologies are optional, more advanced approaches designed to reflect how electricity markets and power grids can operate, recognizing that limited cross-grid delivery does occur and is acknowledged by grid operators and relevant programs. There are three proposed methodologies for demonstrating deliverability:
- Attributes sourced from generating facilities located within the same deliverable market boundary as the demand to which they are applied
- Attributes paired with demonstration of excess transmission capacity via electricity price differentials between adjacent markets
- Attributes paired with contracts or market instruments demonstrating physical delivery from the point of generation to the point of consumption
19. How are the revisions describing what qualifies as Standard Supply Service in my region?
The proposed revisions define Standard Supply Service (SSS) as electricity or energy supplied to consumers through default or regulated service arrangements that are not the result of voluntary procurement. SSS represents energy delivered to end users under public service obligations, such as supply from facilities or resources subject to regulated cost recovery from a supplier, government-mandated clean energy procurement programs (e.g., Renewable Portfolio Standards, Clean Energy Standards, Feed-in Tariffs, etc.), or publicly owned facilities operated under a public service obligation or similar regulatory framework. The intent is to distinguish these shared system resources from those eligible for voluntary claims backed by Energy Attribute Certificates (EACs) under the market-based method. Through the consultation, GHG Protocol invites feedback and region-specific examples to help ensure the definition accurately reflects how default supply operates across different jurisdictions.
20. How does the scope 2 update relate to GHG Protocol’s Actions and Market Instruments (AMI) workstream?
The scope 2 update focuses on how companies measure emissions within their own inventory — a form of attributional accounting that assigns emissions within defined organizational and operational boundaries. In parallel, a separate public consultation includes material on estimating the avoided emissions of electric sector actions using consequential methods. The insights gathered from this consultation will support the work of the Actions & Market Instruments (AMI) Technical Working Group, which is advancing standardized, sector-agnostic requirements for quantifying and reporting impacts such as avoided emissions.
21. How will the proposed scope 2 revisions ensure that market-based claims are not just accurate in time and location, but also aligned with real emissions impact?
The proposed revisions seek to strengthen how market-based reporting reflects the underlying physical and temporal realities of electricity generation and consumption, improving alignment with system-wide emission patterns in aggregate and over time. The updated quality criteria, such as deliverability and hourly matching, aim to ensure that market-based claims more accurately represent when and where low-carbon electricity is actually supplied, rather than only contractual ownership of certificates.
The proposal reflects an evaluation of how updates to the market-based method could better align with the Decision-Making Criteria and Hierarchy (see Annex A), by improving scientific integrity and alignment with accounting principles, supporting companies in taking ambitious climate action and programs, and maintaining feasibility for global reporters. The public consultation seeks input on whether these proposed revisions strike the right balance across these objectives and compared to the status quo.
Note, these proposed updates do not guarantee a quantified emissions impact from every individual procurement but are intended to improve consistency with system-level decarbonization outcomes over time. For more information on the rationale behind the proposed revisions to the market-based method, please review our blog on hourly matching and deliverability. GHG Protocol encourages all interested stakeholders to participate in both public consultations now open, which can be accessed on GHG Protocol’s Public Consultations landing page.