What Triggered the GHG Protocol Scope 2 Revision?
In September 2025, the GHG Protocol officially announced the launch of a 60-day public consultation in October to comprehensively revise Scope 2 (also known as "Category 2") guidance. This is the first major revision since the 2015 version was published, primarily focusing on indirect emissions from corporate electricity use (especially purchased electricity and renewable energy certificates). It is expected to redefine the selection logic and time scales for "electricity emission factors," enabling companies to better reflect actual grid operations when disclosing electricity-related emissions. Another objective is to address international demands for greater transparency in carbon inventory data.
Root Cause: The Global "Green Electricity" Credibility Crisis
Over the past decade, most companies have claimed reduced Scope 2 emissions by purchasing Renewable Energy Certificates (RECs) or signing long-term Power Purchase Agreements (PPAs). However, this "annual settlement system" has gradually raised concerns:
- Was the renewable energy represented by certificates actually generated during the company's electricity consumption period?
- Is the certificate's generation location on the same grid as the company's actual electricity consumption area?
- Are annual average emission factors too crude, masking high-emission phenomena during peak periods?
These issues have challenged the "true carbon reduction value of green electricity."
The EU CSRD, IFRS S2, and US SEC sustainability disclosure regulations are progressively requiring companies to provide higher-resolution energy information. Consequently, the GHG Protocol has initiated this revision, hoping to establish a globally applicable standard that reflects electricity's real-time nature.
Revision Phases and Future Timeline
The current version is still in the "draft public consultation" phase. After the consultation period ends, feedback will be compiled, with final publication expected in the second half of 2027. Officials have also announced a "phased implementation" approach:
- Step 1: Pilot hourly emission estimation at company and data provider levels
- Step 2: Promote updates to electricity certificate and emission factor databases
- Step 3: Full adoption of new standards for disclosure and verification
For companies, this means the next 1-2 years represent a critical transition period for adjusting their inventory practices.
II. What Are the Key Differences Between Old and New Versions?
From "Annual Average" to "Hourly Reality"
The new Scope 2 emphasizes the "hourly matching" concept, requiring companies to calculate electricity emissions using higher temporal resolution emission factors and confirm that green electricity aligns with actual consumption timing. This means:
- Annual average emission factors can no longer simplify calculations
- Renewable energy carbon reduction must occur in the "same time period"
- Companies need continuous monitoring and recording capabilities
In the future, Scope 2 electricity activity data calculations may change from:
Annual electricity consumption (kWh) × National electricity emission factor
To:
Where kWh_t is electricity consumption in hour t, and EF_t is the emission factor for that period.
From "Certificate Purchase" to "Actual Deliverability"
The new version introduces the "Deliverability" principle, stipulating that companies can only claim renewable energy electricity from the same grid that can be actually transmitted. Additionally, the new system advocates prioritizing "consumption-side" data to ensure emission calculations reflect actual responsibility locations.
If companies purchase green electricity across regions or internationally, they need to re-examine whether RECs and PPA contracts meet regional matching requirements. Green electricity strategies will place greater emphasis on geographic and physical feasibility.
From "Immediate Requirements" to "Gradual Implementation"
Considering the varying data capabilities across industries and company sizes, the new version will adopt phased implementation and provide exemptions for SMEs:
- Initially, "load curves (variations in electricity consumption at different times)" or seasonal factors can be used for estimation
- Existing contracts can still be used during the transition period but must disclose their limitations
III. Future Approach: How Can Companies Prepare in Advance?
The new Scope 2 will bring both regulatory and technical changes. Companies that position themselves early during the transition period can not only reduce compliance risks but also strengthen their sustainability competitiveness.
Establish Electricity Data Foundations
- Confirm early whether your electricity supplier can provide hourly or regional emission factors
- If only annual or monthly data is currently available, consider supplementing with "time-based monitoring" or "smart meters"
- Inventory internal energy-consuming equipment data to confirm which facilities or systems can export consumption time records
The key to "hourly emissions" lies in "data continuity." Even if still using annual factors, you should begin establishing data retention systems for rapid future conversion.
Re-examine Green Electricity Strategies
- Check whether existing RECs, PPAs, or green electricity programs are located in the same grid region
- When signing new contracts, include "hourly supply" or "regional matching" clauses
- If green electricity suppliers are far from consumption points, consider alternatives like "regional electricity intermediary platforms" or "local green energy project investments"
The Supporting Value of Digitalization and Automation
As Scope 2 calculations move toward hourly data, data granularity is increasing, making manual inventory increasingly impractical. Implementing carbon inventory or energy management systems helps:
- Automatically integrate electricity supply data to quickly calculate emissions for different periods
- Synchronize with international standard updates on electricity emission factors
- Provide real-time visual reports supporting internal decisions and verification needs
The focus of digitalization is not just time-saving but building "traceable" and "verifiable" data chains. As GHG Protocol, IFRS S2, and CSRD regulations gradually integrate, this will become the foundational capability for companies to pass verification and investment ratings.
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References
Upcoming Scope 2 Public Consultation: Overview of Revisions., Greenhouse Gas Protocol, 2025/09/29
