As of Monday, Oct. 20, stakeholders have 60 calendar days to weigh in on the Greenhouse Gas (GHG) Protocol’s proposed updates to the Scope 2 Guidance and an emerging consequential accounting method.   

There is no time to waste. The comment periods end on Dec. 19, 2025, the consultation materials exceed 60 pages, and the consultations include over 200 questions.  

Requests for consultation submissions to remain confidential require prior approval and must be submitted prior to Dec. 1, 2025. So, now is the time to ensure that your organization’s voice is heard while these critical revisions are still under discussion.   

What’s the Fuss?  

While the proposed Scope 2 Guidance maintains many aspects of the previous version, such as the dual reporting structure (location- and market-based), the draft introduces stricter temporal and spatial granularity reporting requirements. Feedback from the now-open Scope 2 Public Consultation will inform further revisions before the final publication of the new standard in 2027.  

For consequential accounting, the Actions and Market Instruments (AMI) Technical Working Group (TWG) is currently producing a white paper, expected in December 2025, to cover key concepts, principles, and approaches. The Electricity-Sector Consequential Methods Public Consultation will gather input to inform the AMI TWG’s development of requirements for “reporting emissions impacts outside corporate inventories.”  

According to the Protocol, “publication and effective dates for Scope 2 and AMI are intended to be coordinated so that any new LBM/MBM requirements take effect alongside complementary AMI outcomes.”

Digging Into the Scope 2 Details 

The Scope 2 TWG and Independent Standards Board (ISB) have been discussing proposed revisions to Scope 2 Guidance since September 2024. Over that time, the discussions increasingly shifted toward prioritizing temporal specificity and tighter market boundaries in reporting. The GHG Protocol’s latest blogs outline these requirements and frame the proposed revisions to the existing approach of annual matching and broad boundaries as a way to “keep Scope 2 inventories decision-useful, interoperable across frameworks, and provide comparable reporting data.”  

Location-Based Method (LBM) Updates 

The draft guidance proposes the following requirements for the location-based method:  

• New emission factor hierarchy prioritizing emission factors with the highest spatial precision, followed by the highest temporal precision. 
  • The hierarchy requires using the most “local” emission factor available for the grid that supplies the load, and then the most granular temporal emission factor (hourly before monthly).  
  • This hierarchy also favors using consumption-based factors (which reflect imports and exports across grid boundaries) over production-only (averaging grid resources within a region) factors.  
• Addition of the definition for “accessible”: publicly available, free to use, and from a credible source. 
• Requirement to use the most precise location-based emission factor accessible for which activity data is also available.  
• Feasibility measures include load profiles and phased implementation.  

Market-Based Method (MBM) Updates 

The draft guidance proposes the following requirements for the market-based method: 

• Update to the Scope 2 Quality Criteria 4 to require that all contractual instruments used be issued and redeemed for the same hour as the energy consumption to which the instrument is applied, except in certain cases of exemption.  
• Update to the Scope 2 Quality Criteria 5 to require that all contractual instruments used be sourced from the same market boundary in which the reporting entity’s electricity-consuming operations are located and to which the instrument is applied, or otherwise meet criteria to demonstrate deliverability.  
• New guidance for Standard Supply Service (SSS) and a requirement that an organization “shall not claim more than its pro-rate share of SSS” to address what users can claim regarding publicly funded clean energy resources.  
• Updated definition of residual mix emission factors to reflect the GHG intensity of electricity, within the relevant market boundary and time interval, that is not claimed through contractual instruments, including voluntary purchases or SSS allocations.  
• New requirement for the use of fossil-based emission factors where no residual mix emission factor is available.  
• Feasibility measures include load profiles, exemption thresholds, phased implementation, and a legacy clause.  

CEBA’s View 

CEBA supports optional granular time and location matching but has deep concerns with the mandatory matching requirements included in the draft Scope 2 Guidance. A one-size-fits-all procurement mandate does not reflect the diversity of buyer needs, markets, and resource availability and could unintentionally chill voluntary clean energy procurement. This is especially the case amid policy uncertainty and active opposition to clean energy development in parts of the United States.  

CEBA’s May 2025 letter to the ISB highlighted that 75% and 66% of surveyed corporate buyers opposed mandatory hourly matching and location matching, respectively. This opposition is built on the following concerns voiced by CEBA membership:  

• Cost and capacity constraints: Moving to hourly matching could divert staff and funding from advanced procurement to bookkeeping. 
• Slowing market momentum: Mandatory matching could shrink demand for clean energy and deter new buyers from entering the marketplace.  
• Data gaps: Tracking would be nearly impossible for buyers that manage thousands of sites or have distributed operations, especially because hourly data are nonexistent in many regions.  
• Diminishing climate impact: Limiting purchases to a narrow geography can restrict the emissions reduction impacts that some companies have by preventing funding for new clean energy projects in areas where the grid is dirtier.  

CEBA is supportive of the development of a consequential accounting method, preferably included in the Scope 2 Guidance, so that users may report the emissions impacts of their actions.  

This 60-day period provides a critical opportunity, as feedback will shape accounting for voluntary clean electricity procurement; what claims companies can make; how registries and suppliers manage market instruments; and the cost and complexity of corporate reporting for years to come.  

Next Steps 

The public consultation window is the single best opportunity to shape the final Scope 2 Guidance and weigh in on the consequential accounting method. CEBA strongly encourages that all stakeholders submit feedback. Note that if you have already submitted feedback to the Protocol, it is not clear if it will count — “feedback shared with the GHG Protocol via other channels will not be considered as part of the public consultation process.”  

To help with preparing submissions, CEBA recommends the following:  

• Review the GHGP’s consultation materials, Scope 2 TWG meeting minutes and presentations, and other relevant resources to inform your comment.  
• Seek approval for a confidential submission prior to Dec. 1, 2025, if this enables your organization to respond. 
• Develop focused, concrete comments grounded in operational realities, pointing to data gaps and unintended consequences in specific markets.  
• If you have provided feedback to the GHG Protocol prior to Oct. 20, 2025, consider resubmitting.