Standard-setting group Greenhouse Gas Protocol (GHG Protocol) has published a summary of responses from its public consultation on the scope 2 standard — which covers indirect emissions from purchased energy. The group will consider the feedback ahead of a second public consultation later this year, with the new standard expected to be published in 2027.
The consultation sought views on a range of proposed revisions that would affect the use of renewable energy certificates (RECs), including changes to market and location-based reporting methodologies for companies. A total of 1,072 responses were submitted from 56 countries.
GHG Protocol also confirmed on Wednesday that it will combine its carbon accounting standards with the International Organisation for Standardisation (ISO), following an initial announcement last year. A public consultation on an integrated corporate standard is planned for the second quarter of 2027.
Hourly, grid-based matching largely opposed
Feedback on new scope 2 quality criteria, which proposes hourly-based matching for electricity consumption, was largely unsupportive. Of 909 respondents, 70pc gave little to no support, 22pc were in favour, and 7pc were neutral. Many objectors said hourly matching could discourage participation in voluntary renewable procurement schemes, such as RE100, by increasing reporting burdens and costs. Several respondents also suggested that hourly matching should be optional, rather than mandatory.
The revision also proposed an exemption from hourly matching for organisations meeting certain eligibility criteria, such as having smaller size and total electricity consumption, allowing these organisations to match on a monthly or annual basis. From 748 respondents, 76pc supported the exemption, 14pc opposed it, and 9pc were neutral. Supporters of the proposal said it would provide a more equitable approach to reporting and encourage smaller organisations under a certain threshold to continue voluntary procurement.
With regard to deliverability requirements, the consultation proposed that buyers could only procure RECs from generators connected via an electrically linked grid. In the absence of a clear market boundary, price-based indications of available transmission capacity between adjacent grids could be used as evidence.
Of 875 respondents, 59pc opposed the revision, while 30pc were in support and 11pc were neutral. The main concern among those against was that narrower market boundaries could discourage investment in areas with the greatest decarbonisation potential and make long-term offtakes, such as power purchase agreements (PPAs) less attractive. Several respondents favoured an optional approach, similar to feedback on temporal matching.
Mixed responses to emissions factors hierarchy
Further proposals to the location-based method would require reporting organisations to prioritise the most precise location information, followed by temporal granularity, with more emphasis on import and export data to reflect more accurately the generation feeding into the grid.
The response to the proposal was mixed — 40pc were in favour compared with 44pc against, while 17pc were neutral. Opponents noted that local spatial boundaries may not always accurately reflect how electricity is managed and delivered at scale. But supporters of the proposal said it would enhance the method's relevance.
Uncertainty over subsidised procurement rules
The consultation also sought responses on a new "standard supply service" (SSS) term to account for renewable electricity from publicly funded or mandated resources.
Out of 522 respondents, 49pc were in favour of the introduction of the term, compared with 30pc who were against and 20pc who were neutral. Those in support said that it would prevent procurement of SSS resources from specific, typically larger organisations.
But many expressed concern that classifying any state-supported generation as SSS would remove a significant share of available RECs from the voluntary market. Feedback from Asian markets such as Japan, Taiwan and Malaysia noted that feed-in-tariff programmes account for the majority of available RECs, and their possible reclassification could leave a much narrower pool of eligible contracts for voluntary buyers.
Broad support for a ‘grandfathering' clause
Around 90pc of 801 respondents were in favour of a legacy "grandfathering" clause, which would allow eligible pre-existing contracts to count toward market-based consumption even if they do not meet updated requirements when the updated protocol comes into force.
Respondents said this provision would help maintain market confidence in long-term contracts such as PPAs, and would provide a more equitable approach by ensuring that early adopters of updated scope 2 guidance are not at a disadvantage.
Revised proposals will be discussed with the Independent Standards Board if needed, GHG Protocol added.
