Scope 2 Is Evolving: What the GHG Protocol Consultation Could Mean for Corporates

For more than a decade, annual matching has been the prevailing approach to corporate Scope 2 reporting. By matching annual electricity consumption with national or regional Energy Attribute Certificates (EACs), companies have been able to make renewable electricity claims and report progress against climate targets in line with existing guidance. The Greenhouse Gas (GHG) Protocol, which sets the voluntary corporate reporting standards for tens of thousands of companies worldwide, first issued guidance in 2015 and has not made amendments since.

That approach is now under review

In October 2025, the GHG Protocol released a draft update to its Scope 2 guidance, opening a public consultation on potential changes to how renewable electricity claims are assessed and reported. The draft focuses in particular on making claims more granular in terms of timing and location of generation, and has triggered renewed discussion across the market.

Why Scope 2 is under discussion

Scope 2 reporting plays a central role in corporate climate disclosures. It underpins voluntary initiatives, investor reporting and regulatory frameworks such as CSRD (the EU Corporate Sustainability Directive) with its ESRS E1 standard. As expectations around transparency and comparability increase, so does attention on how renewable electricity claims are constructed and interpreted.

Under the current framework, annual matching allows renewable electricity to be accounted for on a yearly basis, even when generation and consumption occur at different times. In addition, renewable electricity can be accounted for within a wide geographic area (e.g. AIB in Europe, US/Canada), even when generation and consumption occur in different geographies.

While fully compliant today, this approach does not distinguish between temporal or geographical differences within electricity systems. For example, a corporate with night-time operations in Germany can procure solar renewable energy in Spain.

As a result, standard setters and stakeholders are examining whether additional approaches could complement existing methods and improve how Scope 2 reporting reflects the timing and location of electricity use with the intention to accelerate greater adoption of renewable energy.

What the GHG Protocol is proposing

The draft Scope 2 guidance proposes introducing greater granularity, often referred to as hourly matching, as one possible evolution of Scope 2 accounting. Importantly, the community will need to align on how greater granularity will develop from current procurement approaches such as annual EAC matching, utility green tariffs and long-term instruments like VPPAs.

The draft includes three main elements:

• Geographical deliverability requirements, requiring matching within restricted market boundaries.
• Temporal matching, with hourly matching proposed within a market above a defined annual consumption threshold, still to be confirmed.
• Use of a defined residual mix when the consumption doesn’t match the generation, and the use of fossil-based rates when no residual mix is available.

Final guidance is expected at the end of 2027, with phased implementation starting toward 2030. The GHG Protocol has indicated that practical implementation will be central to the final design.

Implementation measures under discussion to support a feasible transition include:

• Legacy provisions for existing long-term contracts
• The use of standardized load profiles where hourly consumption data is not available
• The level of consumption threshold over which the matching must be done on an hourly basis
• Intermediate approaches such as monthly matching as a stepping stone toward finer temporal resolution

These elements are intended to allow corporates to build capability over time rather than requiring immediate structural change.

What this could mean for corporates

As the consultation progresses, corporates are beginning to assess how potential changes might affect renewable electricity claims, reported Scope 2 emissions and procurement strategies.

For organizations that rely heavily on currently accepted multi-country market boundaries in Europe and North America and annual EAC matching, outcomes under more granular scenarios may differ depending on load profiles, regions and portfolio structure. For others, the implications may be limited or manageable through existing instruments.

At this stage, the focus for many companies is to understand potential exposure and the range of options available across different markets and time horizons.

Following the consultation and looking ahead

The GHG Protocol Scope 2 update remains a voluntary standard under consultation, and discussion among corporate buyers, market participants, and other stakeholders is ongoing. Final outcomes, thresholds, and implementation details have not yet been determined.

Scope 2 accounting is therefore entering a period of review and discussion rather than a sudden shift. Annual matching, hourly matching, green tariffs, and long-term procurement instruments are expected to continue to coexist, with different roles depending on market conditions and corporate objectives.

For corporates, staying informed on the timeline for potential changes and areas of debate can support better internal alignment across sustainability, procurement, and reporting teams as standards continue to evolve.