GHG Protocol is currently in the process of updating its corporate suite of standards and guidance, including its Scope 2 Guidance (2015). In the decade since the Scope 2 Guidance was published, there have been significant changes within the GHG emissions accounting and reporting ecosystem, including the development of both voluntary and mandatory disclosure frameworks and the increase in adoption of net-zero emissions targets.  

The scope 2 update aims to strengthen how companies account for emissions from electricity, both by improving how usage is reflected in inventories and by introducing a new way to recognize the broader climate benefits of clean energy. Clearer, more consistent accounting supports better decision-making, reinforces trust in reported data, and helps companies demonstrate meaningful progress while keeping GHG Protocol fit for purpose in a rapidly evolving policy and disclosure landscape.  

To ensure the independence and integrity of the update process, GHG Protocol developed an updated system of governance, including a new Independent Standards Board which provides oversight of the standard development and revisions procedure. Under the standard development procedure, GHG Protocol convenes expert Technical Working Groups to analyze the gaps in the current corporate suite of standards and to develop proposals for updates that will be reviewed and decided upon by the Independent Standards Board. While the process is still ongoing, the Scope 2 Technical Working Group has made significant progress towards developing proposals for how to address existing challenges with the current Scope 2 Guidance. 

Scope 2 Today 

The current Scope 2 Guidance helped scale clean energy procurement and bring transparency to corporate emissions reporting, supporting companies’ climate efforts, during a period of early market development. But with a decade of experience, new data, and higher expectations for credible reporting, the standard must now evolve. One issue under review is that companies can currently claim zero-emissions electricity use based on purchases from generation that isn’t part of the grid system serving the location and time of their consumption. This disconnect has raised concerns about the accuracy, comparability, and credibility of reported scope 2 emissions, defined as the indirect emissions from purchased and consumed electricity.   

For example, consider a company that purchases enough renewable energy certificates (RECs) from a solar project in a different region, one not connected to the electricity grid where the company operates, to match all its annual electricity use. Under the current Scope 2 Guidance, this company could report that it is powered 100% by renewable energy from that solar project. But this can misrepresent how and where electricity is actually used. Electricity must be produced and consumed at the same time and within the same grid system, unless storage is involved. So, if a company uses electricity at night in one region, it cannot plausibly be using solar power generated during the day in another, unconnected region. This mismatch in time and place weakens the accuracy and credibility of reported emissions data and makes it harder to compare inventories across organizations. 

A second concern relates to the gap between reported emissions and real-world climate impact. Today, companies can report zero emissions based on certificates that may not contribute to decarbonizing the electricity grid, raising concerns about how such claims are interpreted and whether they reflect meaningful climate outcomes. While GHG Protocol has long noted that inventory totals don’t directly represent changes in atmospheric emissions, market-based claims are often used in public communications and target-setting. For reported claims to remain consistent with GHG Protocol’s principles and decision-making criteria, particularly scientific integrity and impact, claims under the market-based method should be grounded in actions that measurably contribute to grid decarbonization.  

What’s on the Table: Matching When and Where Power is Used, Plus Separate Emissions Impact Accounting 

The Scope 2 Technical Working Group is developing a proposal for updated inventory rules based on hourly and regional matching, so reported electricity emissions better reflect when and where electricity is actually used. This approach supports more credible inventory reporting and can help create demand signals for a more resilient and diverse mix of clean energy resources that are available when and where they’re needed. While this may shift incentives compared to current practices, especially for actions not directly tied to electricity use, it more clearly distinguishes between electricity use accounting and broader impact. To recognize the emissions benefits of clean energy actions that fall outside these inventory boundaries, such as those not delivered to the same grid or timeframe as a company’s usage, the Technical Working Group is also advancing a complementary metric: Marginal Emissions Impact. 

This new impact-based metric, Marginal Emissions Impact, is designed to reflect how much a clean energy purchase displaces fossil fuel emissions on the grid. For example, imagine a company in one part of Europe purchasing solar energy from another region within the continent. Under current practices, that company may be able to count the purchase toward its scope 2 inventory even if the electricity isn’t used at the same time or isn’t deliverable to their facilities. Under the proposed revisions, that purchase would no longer count toward their scope 2 emissions total because it doesn't match when or where the electricity is used.  

However, if that same company purchased clean energy in a region with a more fossil-intensive grid, the Marginal Emissions Impact of that purchase could be significantly higher because it helps to displace more carbon-intensive electricity. While such a purchase may fall outside inventory boundaries, the impact metric provides a way to more accurately and transparently account for its broader climate benefit. Together with a more accurate inventory, it enables companies to understand both the emissions from their electricity use and how their actions contribute to grid decarbonization globally. 

This combined framework reflects a core principle of the Scope 2 update: 

• Inventory reporting is being refined to ensure consistency, comparability, and scientific alignment in how emissions from electricity use are measured.
• Impact reporting offers a complementary way to account for emissions reductions from clean energy actions that occur outside a company’s direct electricity use.  

Together, these proposed revisions aim to improve the current state by ensuring the rules for electricity accounting are aligned with science, credible, and fit for purpose as climate disclosure and target-setting standards continue to evolve. 

Addressing Feasibility 

GHG Protocol’s revision process includes a decision-making criteria and hierarchy, where feasibility for implementation is a key consideration alongside integrity and impact. Feasibility has been a recurring theme in Scope 2 Technical Working Group discussions, with some members raising concerns directly and also reflecting perspectives heard across the broader stakeholder community. The group as a whole is taking these concerns seriously and has been actively exploring ways to address them. The Marginal Emissions Impact metric is one way of addressing feasibility: it offers companies a meaningful way to demonstrate climate benefit even if their clean energy purchases don’t meet all the new inventory requirements. In addition, the Scope 2 Technical Working Group has proposed several other ways to promote feasibility. This includes discussion of provisions to: 

• Ensure existing renewable energy contracts remain eligible under the update,
• Support the use of estimated electricity use data so organizations can continue relying on their current annual electricity data while applying standard hourly profiles, and
• Potentially exempt smaller, lower-capacity electricity users. 

Companies and the broader ecosystem of data providers, utilities, and service platforms could have time to adapt and develop tools to support implementation, aided by a phased approach and multiple years of advance notice. Ongoing improvements in data infrastructure, software, and energy tracking technologies could also help ease implementation in the next few years. Final publication of the forthcoming Scope 2 Standard is anticipated no sooner than the end of 2027, with implementation expected to phase in over a period thereafter. 

What’s Next and How to Stay Engaged 

The Scope 2 Technical Working Group discussions of these provisions are ongoing and remain subject to further technical review, a public consultation process, and ultimately approval by the Independent Standards Board. A key part of this effort is making sure that organizations with disclosure frameworks or platforms built on GHG Protocol can stay aligned as the standards evolve with future changes to GHG Protocol’s corporate standards. To facilitate this, GHG Protocol has incorporated five partner Observing Entities into the Independent Standards Board, which was announced earlier this year.  

The next key engagement milestone will be a public consultation period later this year. The consultation draft is expected to include proposed updates such as the hourly and regional matching methodology, the Marginal Emissions Impact metric, and associated feasibility provisions such as allowances for estimated data, limited exemptions for smaller users, and treatment of existing contracts, reflecting the Technical Working Group’s effort to balance integrity with practical implementation. Stakeholders will be able to provide input on these elements during the consultation process, and more information about how to participate will be shared in the coming months. 

In the meantime, those interested in staying apprised of updates can review materials in our online document repository and subscribe to receive email updates from the GHG Protocol Secretariat.