The Greenhouse Gas (GHG) Protocol is in the middle of the biggest update to Scope 2 Guidance since 2015. The proposed changes reset what counts as a credible electricity claim, particularly for market-based Scope 2. The new guidelines require more granular data (hourly), tighter boundaries in sourcing, and explicit clarifications in GHG accounting.
Public consultation from stakeholder closed on January 31st 2026, where feedback will be analyzed. The Scope 2 Technical Working Group at Greenhouse Gas Protocol will likely run a second consultation period before we can expect the new standard in 2027.
Evolving Scope 2 Guidelines
In 2015, Scope 2 Guidance was “voluntary best practice.” In 2026, it’s become infrastructure in GHG reduction pathways: used directly or indirectly by widely adopted programs (such as ESRS/CSRD, IFRS-aligned reporting expectations, and California SB 253), plus target-setting strategy and buyer initiatives.
Meanwhile, corporate electricity claims have gained more scrutiny, largely because the gap between what’s contracted and what’s physically powering the grid at the time and place of use has very little limitations. Under current rules, annual matching and market boundaries can allow a company to match consumption in one region with certificates from a different region and a different time of generation, raising concerns about accuracy, comparability, and double counting.
That’s the core driver behind the proposed updates: improve integrity and comparability, reduce double counting risk, and make reported Scope 2 numbers clearer for external stakeholders.
Key Changes
- Moving from annual matching to hourly matching.
The proposal would require companies, when using market-based instruments, to align clean electricity attributes to the hour of consumption, not just “within the same year.” This is often described as “24/7” matching.
Hourly matching changes what “counts”, and newly requires metering and certificate timestamping, and more strategic procurement pathways. Though its noteworthy that GHG Protocol is also discussing feasibility mechanisms—such as considering load profiles and creating exemptions/thresholds for smaller electricity consumers. - “Deliverability” becomes a first-class requirement.
Even if a certificate is legitimate, the revisions push harder on the question: could that electricity reasonably be delivered to serve the load within a defined market boundary?
This scrutinizes the “paper claim vs. grid capacity” and can also constrain buyers with geographically dispersed loads or limited local clean supply. - Cleaner rules for shared or publicly supported electricity, aka “Standard Supply Service.”
Another large piece of the proposal is calling for clearer accounting for electricity tied to publicly funded, mandated, or shared resources that customers contribute to through tariffs or standard service structures (the consultation document refers to this as Standard Supply Service (SSS)). The goal is to reduce interpretation discretion and reduce overclaiming/double counting in market-based reporting.
Corporate strategies that rely heavily on utility programs, green tariffs, default supply mixes, or shared procurement structures will need to assess their energy sources carefully. - Residual mix rules tighten to reduce double counting.
The proposal clarifies that the residual mix should exclude generation energy already allocated through voluntary claims or through SSS, once again, aiming to reduce double counting within market-based accounting.
For many companies, residual mix is the “default” emission factor used to calculate their energy supply mix. Changing its definition changes reported numbers. - The fallback emission factor gets more conservative, becoming “fossil-based” vs. the current “grid-average”.
One of the most consequential proposed shifts: if an appropriate emission factor isn’t available under the market-based method, the default would shift toward a fossil-based emission factor, replacing the current grid-average fallback in that scenario, to avoid counting resources already claimed by others.
This change could materially increase reported market-based emissions for companies operating in regions without robust residual mix factors or high-quality instrument data infrastructure, at least until their data collection systems catch up. - Contract/instrument “quality criteria” and tighter expectations for what counts.
The consultation builds on the idea that contractual instruments must meet quality criteria to be reliable market-based data sources.
Buyers may need to upgrade procurement specs (vintage, boundary, traceability, timestamping, etc.) to keep using instruments for market-based reporting in the future.
Integrity vs. Feasibility vs. Impact
Most stakeholders agree that the direction of more integrity, is the right direction. However, there is concern around implementation reality: data availability, registry readiness, utility infrastructure, cost, and whether tighter rules could unintentionally discourage voluntary clean energy procurement.
That concern is a central theme across commentary from buyers and advisors, who are warning about feasibility challenges and the risk of market disruption if requirements move faster than the systems needed to comply.
Also worth noting: GHG Protocol is signaling some ways to take off the pressure for feasibility, such as exemptions for smaller orgs, load profiles, phased implementation, or legacy/grandfathering concepts, and the specifics are what stakeholders are being asked to weigh in on.
What Renewable Energy Buyers Should Do Now
- Protect your current inventory credibility. This aligns with where the revisions are headed: more precision, clearer data, and higher transparency in reporting.
Even before rules change, start tightening up:- Instrument traceability (registry, ownership, retirement)
- Market boundary rational
- Vintage alignment
- Clear disclosure of both location-based and market-based results
- Map your procurement portfolio against the proposed future tests. Doing a portfolio assessment is the fastest way to understand your exposure to then new regulation and to avoid being surprised by a future assurance finding. Ask questions like:
- Which deals would pass hourly matching?
- Which would pass deliverability?
- Where do we rely on residual mix or fallbacks?
- Which sites are in weak data infrastructure regions?
- Invest in data precision. Hourly matching is a monumental shift in how we understood our data infrastructure. Feasibility for this work is a major theme in stakeholder responses for a reason. (EY). If you want optionality, start working toward:
- Interval consumption data access (utility + submetering where needed)
- Contractual instrument timestamping capability
- Investing in internal systems that can allocate instruments to loads transparently
- Engage utilities and suppliers early (especially if you use tariffs/standard products).
If you rely on green tariffs or standard supply offerings, the SSS and residual mix clarifications could affect how those claims work. Bring utilities into the conversation now, as this will also affect their side of the relationship.
Takeaway
This is the maturation of the clean electricity market colliding with the maturation of climate disclosure.
For years, Scope 2 market-based accounting helped scale voluntary. Now, as electricity demand grows, grids are decarbonizing unevenly, and GHG reduction claims face higher scrutiny. These changes are being rebuilt to better reflect time, place, and traceability
Graphic from ghgprotocol.org
