The First Look: Greenhouse Gas Protocol Scope 2 Proposed Updates
On Monday, October 20, the GHGP released their Scope 2 public consultation alongside a separate consequential metric consultation. Comments are due Friday, December 19. Make your voice heard. EnergyTag will have more content and support available in the coming days and weeks. For now, here is a quick reaction to what is in the Scope 2 public consultation release.
The Scope 2 accounting consultation recommends moving both market- and location-based methodologies towards greater temporal and spatial granularity (i.e. hourly and locational matching).
These proposed changes are evidence-based, designed to drive significant impact in clean energy procurement and decarbonization, and thoughtfully crafted for feasibility and flexibility to support all organizations along their journey.

Source: GHGP
Topline Takeaways:
- These changes bring clean energy accounting to closer alignment with how grids operate by incorporating hourly matching requirements for the world’s largest energy users and more accurate market boundaries (with allowance for cross-boundary matching with appropriate proof).
- Consultation will receive comments on Standard Supply Service — the proposal to more fairly allocate clean electricity from publicly funded, mandated, or shared resources, such as those delivered through default utility service or government clean energy programs. This can help reduce attribute shuffling and drive investment into newer, more impactful projects.
- These changes can strengthen accuracy, scientific integrity, and comparability in Scope 2 inventory reporting and support ambitious climate action.
- Feasibility remains central, and thoughtful flexibilities are proposed to ensure the standard remains useful.
- Hourly matching and market-boundary definitions acknowledge a balance between perfect accuracy and effective implementation — they are not perfect, but represent a significant step forward.
- These rules make it quite simple to do Scope 2 inventory accounting (annual fossil mix available for all unmatched consumption), but make it harder for the world’s largest energy users to claim 100% clean electricity procurement.
- These changes strive for fairness and a better reflection of the reality of decarbonization progress.
Stay tuned for more as the consultation process continues. EnergyTag will be supporting organizations wishing to respond to the consultation and will co-host a webinar explaining the what, why, and how for consultation responses on Thursday, November 6.