GHG Protocol Signals Delay to Hourly Matching Rules for Scope 2

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GHG Protocol plans to delay making its stricter Scope 2 rules mandatory. In a progress update on revising the standard, it said companies claiming environmental benefits from clean energy purchases would not yet have to match them to the time and location of their electricity use.

The delay follows the release of consultation results showing very little support among companies for the new requirements. Respondents also worried the rules could discourage global corporate participation in voluntary clean energy procurement markets.

What was proposed

Scope 2 covers emissions from purchased electricity, steam, heat and cooling. GHG Protocol says nearly 40% of global greenhouse gas emissions can be traced to energy generation, and half of that energy is used by industrial or commercial entities. It launched a Technical Working Group in 2024 to revise the original 2015 guidance, and opened a consultation in October 2025.

Two of the most significant proposed changes were these. Hourly matching would require organizations using contractual instruments to match them to electricity consumption hour by hour. Deliverability would require those instruments to come from renewable electricity that can be delivered to the same market where the power is consumed.

What companies said

Only 12% of companies supported hourly matching, while 82% reported low or no support. For deliverability, 19% were in favor and 71% reported low or no support.

On hourly matching, 87% of respondents feared it could discourage participation in voluntary procurement markets, and 86% cited the burden and cost of reporting. On deliverability, 87% said narrower market boundaries would limit where companies can invest for the greatest decarbonization impact, and 72% said it could push buyers from long-term agreements toward spot purchases.

GHG Protocol sorted the responses into two "theories of change." One holds that the requirements make it likelier corporate demand supports new clean power. The other holds that annual matching and broad geographic boundaries channel capital into the global renewables market by keeping barriers low and supporting a large market for energy attribute certificates.

The proposed path

The Scope 2 Secretariat proposed two market-based methods. Method 1 includes hourly matching and deliverability, while Method 2 keeps the current rules. GHG Protocol's Independent Standard Board then proposed that companies should use Method 1 for market-based Scope 2 reporting but may keep using Method 2 until a date yet to be set. Companies would have to disclose which method they use. After that date, they would have to follow Method 1 if data meeting the quality criteria is available.

GHG Protocol plans to consult on the update in the second quarter of 2027. That consultation will cover proposed requirements for Scope 1, 2 and 3 and for actions and market instruments, as part of a joint GHG Protocol-ISO Corporate Standard expected in the fourth quarter of 2028.

Source: ESG Today