Key Themes from the GHG Protocol Scope 2 Consultation: What Stakeholder Feedback Revealed

The Greenhouse Gas Protocol launched its public consultation on proposed updates to Scope 2 guidance on October 20, 2025. The consultation period closed on January 31, 2026, marking an important milestone in what may become the most significant revision to corporate electricity emissions accounting since the 2015 Scope 2 Guidance was introduced. The standard setter has indicated that a revised draft will be released later in 2026, followed by another public consultation period. While final decisions have not yet been made, the first round of feedback revealed several clear themes. These discussions reflect broader shifts in how companies measure electricity related emissions, how renewable energy claims are evaluated, and how accounting frameworks may align more closely with real world grid conditions.

The Move Toward Hourly and Locational Matching

One of the most widely discussed proposals in the consultation process involves strengthening requirements around temporal and geographic matching between electricity consumption and clean energy procurement. Under current guidance, companies often rely on annual matching of renewable energy certificates to substantiate market based claims. The proposed updates explore whether more granular approaches, including hourly matching and tighter locational criteria, should play a larger role.

To clarify the terminology:

• Hourly matching refers to aligning electricity consumption with clean energy generation on an hour by hour basis, rather than balancing total consumption and procurement over an entire year.
• Locational matching refers to ensuring that the clean electricity attributes claimed are generated within the same grid region or market boundary where the electricity is consumed.
• Annual matching, by contrast, allows companies to match total yearly consumption with certificates regardless of when generation occurred during the year.

Supporters of hourly matching argue that it improves environmental accuracy. Electricity systems operate in real time, and grid emissions intensity fluctuates throughout the day depending on generation mix and demand levels. Matching clean energy procurement to the specific hours when electricity is consumed may provide a clearer representation of actual system impact. Greater locational alignment can also reduce the risk of claims that rely on generation occurring far from the point of consumption.

At the same time, stakeholders raised practical considerations. Not all markets have mature hourly certificate systems. Data availability varies across regions, and companies operating globally face uneven infrastructure. Concerns were also raised about cost implications and potential complexity during implementation. The discussion reflects a balance between increasing methodological rigor and maintaining feasibility across diverse electricity markets.

Market Based and Location Based Accounting Under Review

Another central theme of the consultation involves the continued role of the dual reporting framework. Since 2015, companies have reported Scope 2 emissions using both location based and market based methods. The consultation revisits how these two approaches interact and whether refinements are needed to strengthen transparency and comparability.

To clarify the distinction:

• Location based accounting reflects the average emissions intensity of the grid where electricity consumption occurs, using regional or national grid emission factors.
• Market based accounting reflects emissions associated with the specific electricity products a company has contractually purchased, such as renewable energy certificates or power purchase agreements.
• Location based results indicate exposure to the physical grid mix, while market based results reflect voluntary procurement decisions.

Some stakeholders expressed concern that certain market instruments may not always reflect the underlying emissions profile of the grid at the time of consumption. Others emphasized that market based mechanisms such as renewable energy certificates and power purchase agreements have played a significant role in scaling voluntary clean energy procurement globally. The debate highlights differing perspectives on how best to balance environmental integrity, market incentives, and corporate action.

Importantly, several commenters noted that regardless of accounting treatment, reducing overall electricity consumption remains a direct and durable pathway to lowering Scope 2 emissions. Operational efficiency affects both location based and market based results. Companies that can identify inefficiencies such as excessive peak demand, underutilized equipment, or after hours phantom loads often see measurable reductions in both emissions and energy costs.

Energy management platforms that integrate Scope 1, Scope 2, and Scope 3 tracking can support this broader view. By combining emissions accounting with operational analytics, organizations can move beyond certificate procurement alone and focus on reducing actual consumption. This approach does not depend on the outcome of specific accounting debates, and it aligns with the core objective of lowering emissions at the source.

Feasibility, Data Infrastructure, and Implementation Challenges

The consultation also surfaced practical questions about readiness. Multinational companies frequently operate in markets with differing regulatory environments, grid transparency levels, and digital infrastructure. Implementing higher resolution matching or revised disclosure requirements may require upgrades to metering systems, data integration processes, and internal controls.

Stakeholders highlighted the importance of transition periods and clear guidance to avoid unintended disruption to corporate climate strategies. Many companies have set medium and long term targets based on the current Scope 2 framework. Any substantial revision may require recalibration of baselines, procurement strategies, and reporting systems.

In this context, data quality and automation become critical. Real time monitoring and analytics can reduce reliance on estimates and manual aggregation. Advanced energy management systems can detect peak demand events, support peak shaving strategies, enable load shifting to lower carbon or lower cost hours, and identify phantom load outside operating periods. These operational improvements reduce total electricity consumption, which in turn lowers Scope 2 emissions under both existing and potential future methodologies.

Looking Ahead to the Next Draft and Consultation Phase

With the initial consultation period having run from October 20, 2025 to January 31, 2026, the process now moves into review and revision. The Greenhouse Gas Protocol has indicated that another draft of the updated Scope 2 rules will be published later this year, followed by an additional public consultation period. This staged approach suggests that further refinement and stakeholder input remain central to the standard setting process.

The first round of feedback demonstrates that there is broad agreement on the need to modernize Scope 2 accounting, even as opinions differ on how quickly and how strictly new requirements should be implemented. Themes such as hourly matching, locational accuracy, market instrument integrity, and data feasibility will likely continue to shape the next draft.

For companies, the direction of travel appears clear. Electricity emissions reporting is moving toward greater transparency, higher temporal resolution, and closer alignment with actual grid dynamics. Preparing for this future requires more than high level annual data. It requires infrastructure capable of capturing granular consumption patterns, integrating grid emission factors, and translating operational activity into defensible Scope 2 calculations.

NZero’s platform supports this transition by combining real time energy monitoring with automated emissions accounting across Scope 1, Scope 2, and Scope 3. For Scope 2 specifically, the platform enables:

• High resolution tracking of electricity consumption by facility, meter, and time interval, supporting potential hourly matching requirements.
• Geographic tagging of energy data, allowing companies to align reported emissions with specific grid regions or market boundaries.
• Automated calculation workflows that reduce manual spreadsheet aggregation and improve audit readiness.
• Identification of operational inefficiencies such as peak demand spikes, load imbalance, and phantom load, which directly influence total electricity consumption and associated emissions.

By linking energy usage data with emissions factors in near real time, organizations can model how different accounting scenarios may affect reported Scope 2 results. This enables proactive planning ahead of any final rule changes. Whether hourly matching becomes mandatory, phased in, or remains optional, the ability to quantify when and where electricity is consumed and how that translates into emissions provides both compliance flexibility and measurable performance improvement.

References

• Greenhouse Gas Protocol: Scope 2 Public Consultation Document https://ghgprotocol.org/sites/default/files/2025-10/GHG-Protocol-Scope2-Public-Consultation.pdf
• Trellis: 2 steps CSOs can take regarding Scope 2’s Greenhouse Gas Protocol https://trellis.net/article/2-steps-csos-can-take-regarding-scope-2s-greenhouse-gas-protocol/