GHG Protocol September 2025 Update: Three Implications of Scope 2 Revisions for Corporate Electricity Inventories

Updated on 6 October 2026. Updated Scope 2 consultation results, the integrated standards timeline and ISO collaboration, and added a link to electricity emission factors.

What Prompted the GHG Protocol Scope 2 Revision?

Public consultation on revisions to the GHG Protocol Scope 2 Guidance ran from 20 October 2025 to 31 January 2026. This is the first major revision since the 2015 edition, focusing primarily on indirect emissions from corporate electricity use, particularly purchased electricity and renewable energy certificates. It is expected to redefine the selection and time resolution of electricity emission factors so disclosures better reflect actual grid conditions. It also responds to rising international expectations for transparent carbon inventory data.

The Background: A Global Crisis of Confidence in Green Electricity Claims

Over the past decade, most companies could claim reductions in Scope 2 emissions by buying renewable energy certificates (RECs) or signing long-term power purchase agreements (PPAs). But this “annual accounting approach” has increasingly been questioned:

• Was the renewable electricity represented by the certificate generated when the company actually used electricity?
• Was it generated on the same grid as the company's electricity consumption?
• Are annual average emission factors too coarse, obscuring high emissions during peak periods?

These questions challenge the “actual emissions reduction value of green electricity”.

The EU CSRD, IFRS S2 and US SEC sustainability disclosure requirements increasingly call for higher-resolution energy information. GHG Protocol therefore launched revisions to establish a globally applicable standard reflecting the timing of electricity use.

Revision Stages and Future Timeline

Under GHG Protocol's standards development plan dated 29 July 2026, a draft integrated corporate standard is expected to undergo public consultation in Q2 2027, with the revised version expected in Q4 2028. The schedule remains subject to change and is not a confirmed effective date. Companies can prepare in three areas:

• Preparation 1: Assess hourly emissions estimation capabilities internally and among data providers
• Preparation 2: Track updates to electricity certificates and emission factor data
• Preparation 3: Plan disclosure and verification changes based on the final published requirements

The official July 2026 feedback summary recorded nearly 1,100 responses from 56 countries. Views on hourly matching and deliverability remain divided and require further deliberation. Companies should continue using currently applicable standards for inventories. Sources: Integrated Corporate Standards Development Plan, Scope 2 Consultation Feedback Summary.

2. How Do the Proposals Differ from Current Guidance?

From Annual Averages to Hourly Reality

For the market-based method, the revision proposes “hourly matching”, requiring organisations meeting specified thresholds to match contractual electricity instruments with consumption periods. For the location-based method, a more granular hierarchy of available emission factors is being considered. These requirements are not yet effective. Companies can monitor the following:

• Use the final standards and available data to determine whether annual or finer-resolution emission factors apply
• The proposal seeks to match contractual instruments with electricity consumption in the “same time period”
• Companies need continuous monitoring and record-keeping capabilities

Future Scope 2 electricity calculations may move from the current approach:

Annual electricity consumption in kWh × national electricity emission factor

to:

where kWht is electricity consumed in hour t and EFt is the emission factor for that period.

From Certificate Purchases to Actual Deliverability

The proposed principle of “Deliverability” considers whether the electricity represented by contractual instruments can reasonably be delivered to the consumption location. Conditions remain subject to the final standard.

Companies purchasing renewable electricity across regions or borders will need to reassess whether RECs and PPAs meet geographical matching conditions. Green electricity strategies will place greater emphasis on geographical and physical feasibility.

From Immediate Requirements to Phased Adoption

The proposals consider data availability, exemption thresholds and transition arrangements; not all companies are already required to calculate emissions hourly. Feasibility measures under discussion include:

• Using standardised load profiles where hourly data is unavailable
• Transition treatment for existing contracts and phased implementation

3. Looking Ahead: How Can Companies Prepare?

The revised Scope 2 Guidance will bring both institutional and technical changes. Early preparation during the transition can reduce compliance risk and strengthen sustainability competitiveness.

Build a Foundation of Electricity Data

• Confirm early whether electricity suppliers can provide hourly or regional emission factors
• If only annual or monthly data is available, consider time-of-use monitoring or smart meters to fill gaps
• Review internal energy-consuming equipment and identify sites or systems able to export time-specific electricity records

“Hourly emissions” depend on “data continuity”. Even if annual factors are still used, begin establishing data retention processes now to enable a faster future transition.

Review Green Electricity Strategies

• Check whether existing RECs, PPAs or green electricity programmes are located within the same grid region.
• Include hourly supply or regional matching provisions in new contracts.
• If renewable generation and consumption are far apart, consider regional electricity intermediary platforms or investment in local renewable projects.

The Value of Digitalisation and Automation

As Scope 2 calculations move towards hourly data and greater granularity, manual inventories will become increasingly difficult. Carbon inventory or energy management systems can help:

• Automatically connect electricity supply data and calculate emissions for different periods quickly
• Update electricity emission factors in line with international standards
• Provide real-time visual reports for internal decisions and verification

Digitalisation is about more than saving time: it establishes a traceable, verifiable data chain. As GHG Protocol, IFRS S2 and CSRD requirements become more integrated, this will be a foundational capability for verification and investment ratings.

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References

Upcoming Scope 2 Public Consultation: Overview of Revisions, Greenhouse Gas Protocol, 2025/09/29

ISO and GHG Protocol announced their partnership on 9 September 2025 to jointly develop integrated greenhouse gas accounting standards. Official source: ISO Partnership Announcement; for a comparison of the two standards, see Which Corporate Carbon Inventory Standard Should You Use? ISO 14064 vs GHG Protocol.

For Taiwan's annual electricity emission factors and applicable years, see Taiwan's 2025 (ROC Year 114) Electricity Emission Factor Falls to 0.467: Declining Emissions and Energy Transition Results.

GHG Protocol Carbon Inventory