The Greenhouse Gas Protocol (GHG Protocol) is the leading methodology for companies calculating their GHG emissions. It underpins major reporting frameworks such as the ISSB’s IFRS 2 standard and California’s SB 253. Back in October of 2025, the GHG Protocol consulted on updates to its standards, which would change how Scope 2 emissions are calculated. Recently, Share Action came out in support of the changes. In their letter to the GHG Protocol, they identify the following areas as necessary changes to the Scope 2 methodology:
“• Hourly matching of renewable energy consumption to production, to ensure the temporal accuracy of reported electricity consumption, and improve the credibility and comparability of reported Scope 2 emissions. Increased temporal granularity is also crucial for enabling widespread deployment of the flexibility and storage technologies needed for supplying clean electricity across all hours of the day.
• Deliverable market boundaries, to ensure that clean electricity claims are based on local generation capacity that can physically and reliably serve a company within the relevant power system. Narrowing market boundaries will help correct current market distortions that funnel clean energy procurement into already abundant, low-cost geographies, rather than regions where grid decarbonization is most needed.
• A phased implementation of the standards to allow companies, data providers, and electricity markets to prepare for and adjust to the updates in an orderly manner.
• Recognition of legacy clean energy contracts, to maintain market trust and policy stability by honoring investments made under prior accounting rules and providing a pragmatic pathway for organizations to transition to the new criteria.”
The letter notes that these areas would tighten rules on the use of Renewable Energy Certificates (RECs), a practice that has become controversial. The letter argues that more stringent standards allow investors to better understand a company’s risk profile and exposure to energy price volatility and carbon pricing.
Our members can learn more about GHG reporting here.
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