The GHG Protocol is considering two market-based methods for Scope 2 emissions reporting, combining stricter hourly electricity matching with the option to continue using existing accounting rules during a transition period. Following industry consultation and the ISB’s October 2026 update, a consolidated public consultation is planned for Q2 2027, with the joint GHG Protocol–ISO Corporate Standard expected in Q4 2028. Companies should continue applying existing requirements while improving electricity data quality and preparing for potentially more granular clean energy reporting.
The GHG Protocol is moving towards a dual-method approach to Scope 2 emissions reporting, potentially allowing companies to choose between stricter hourly electricity matching requirements and the existing market-based accounting rules. The proposed direction follows substantial industry opposition to mandatory hourly matching and forms part of the broader revision of the GHG Protocol’s corporate emissions accounting standards. A consolidated public consultation is planned for Q2 2027, with the joint GHG Protocol–ISO Corporate Standard expected in Q4 2028.
Two Market-Based Methods Under Consideration
Under the proposed approach, companies would report purchased electricity emissions using one of two market-based methods.
Method 1 would introduce more rigorous requirements for clean electricity claims, including hourly matching, deliverability and incrementality. These requirements aim to strengthen the credibility of corporate renewable electricity claims by improving the alignment between electricity consumption and clean energy procurement.
Method 2 would retain the existing 2015 Scope 2 rules, allowing companies to continue using their current electricity procurement strategies during a transition period.
At its September 2026 meeting, the Independent Standards Board (ISB) considered different approaches to implementing the two methods before directing the Scope 2 Technical Working Group to refine the proposal. The emerging direction suggests that companies could use Method 2 until a future implementation date, which has yet to be determined, while being encouraged to adopt Method 1. Companies would also need to disclose which method they apply during the transition. The precise requirements and wording remain subject to further development.
Revision Timeline: From Consultation to Publication
The current proposals form part of a broader revision of the GHG Protocol’s corporate emissions accounting framework. The Scope 2 consultation process gathered feedback on proposed changes, including hourly matching and deliverability requirements. According to the GHG Protocol’s update published on 16 October 2026, the proposed dual-method approach reflects the need to balance more rigorous electricity accounting with practical implementation challenges.
The next major milestone is a consolidated public consultation planned for Q2 2027, covering Scope 1, Scope 2, Scope 3 and Actions and Market Instruments. The joint GHG Protocol–ISO Corporate Standard is expected to be published in Q4 2028. The implementation date and transition arrangements for the revised Scope 2 requirements have not yet been finalised.
Existing standards remain applicable until the revised framework is finalised and becomes applicable.
Industry Concerns and Consultation Results
The proposed flexibility reflects substantial opposition to mandatory hourly matching. Of 909 respondents who commented on the issue, 70% expressed little or no support, while 22% supported the requirement. Among corporate respondents, only 12% supported hourly matching, while 82% expressed little or no support. On deliverability requirements, 59% of 875 respondents opposed the proposed approach.
Concerns included administrative costs, data-management complexity and the risk that stricter requirements could discourage companies from purchasing clean electricity. Some stakeholders argued that hourly matching should remain optional, while others supported more rigorous accounting to improve the credibility of corporate climate claims.
The ISB also voted against including the marginal impact method in Scope 2, directing this work instead to the separate Actions and Market Instruments workstream.
What the Update Means for Companies
No immediate reporting changes are required. Companies should continue applying the existing Scope 2 accounting requirements while the revision progresses.
However, sustainability, finance and energy procurement teams should prepare for potentially more granular electricity reporting. Improving hourly electricity consumption data, documenting the origin of energy attribute certificates and maintaining both location-based and market-based Scope 2 emissions figures can help companies prepare for future requirements.
Companies should avoid changing electricity procurement contracts solely in anticipation of proposals that have not yet been adopted. Instead, they should monitor the consultation process and assess whether their current energy procurement strategies and data systems could support hourly matching in the future.
For ESG reporting software providers, the proposed direction may increase the need to record the market-based method applied and, where relevant, hourly consumption and certificate data. These are practical preparation considerations rather than confirmed new reporting requirements.
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