What Changes are Proposed? What’s at Stake?
Scope 2 emissions are associated with purchased electricity, which is often treated as essentially synonymous with grid-based electricity use. Under the current market-based accounting method, procured clean energy — through unbundled RECs or bundled PPAs — is assigned against electricity consumption and counted as zero emissions, regardless of when and where the clean energy generation happened. So the net emissions reported only reflect emissions from the remaining balance of grid-based electricity use.
Now the Greenhouse Gas Protocol is revising Scope 2, with new standards expected to come into force in 2028. Though voluntary, the Protocol is the standard used for 97% of corporate disclosures, so the incentives created by the Protocol will shape corporate purchasing activity, which in turn will impact investors and project developers.
Two distinct Scope 2 proposals are on the table:
- Hourly matching (24/7 carbon-free energy [CFE]). Matching consumption with clean generation in the same grid, in each hour of the day. The theory behind this approach is that same-hour, same-location matching will result in more accurate claims about plausibly consumed electricity. In other words: it’s easier to be accountable when the project is on the same grid, and if the energy was generated at the same time as it was consumed. This approach encourages the purchases of clean energy close to load, and – because of the constant balancing required to match consumption and generation – is expected to drive more activity in the spot market rather than long-term purchase agreements (such as PPAs).
- Consequential emissions accounting. Some refer to this as “impact accounting” as well. Rather than attempting to match megawatt-hours of electricity usage or consumption, this approach measures the emissions impact of electricity usage/generation – such as induced emissions from load, or emissions avoided by clean generation – and adds up those impacts. The resulting incentive for a corporate buyer is to focus on clean energy procurement in the dirtiest grids, not necessarily the areas closest to their load. This approach offers lower cost implementation thanks to increased flexibility, more effective decarbonization, and also encourages the long-term purchases of power that drive global impact.
REsurety’s Response to the Greenhouse Gas Protocol (GHGP) Consultation
The GHGP has opened a public comment period through January 31, 2026 to collect stakeholder perspectives on the proposed changes.
REsurety has many resources to help corporates respond, including a blog authored by Adam Reeve on what the proposed changes mean for your business, as well as a calculator tool to understand how each accounting methodology might look for your current or planned procurement strategy.
Below, we’re including the REsurety response to both the Scope 2 and the Consequential Metric GHGP surveys. Responses are due by January 31st, 2026 (as per recent extension) – draft yours today!