GHG Protocol (Independent Standards Board)Standard setterGlobal

Published 23 Oct 2026

Explains: Scope 2 Market-based Method Update: From 2025-2026 Public Consultation to Current Status, Status update, 16 October 2026, 16 Oct 2026

How will the GHG Protocol change the way companies count green electricity?

A widely used rulebook for counting company emissions is moving towards matching green power certificates hour by hour and grid by grid. Nothing changes in reports yet, and the switch date is still open.

Proposed
16 Oct 2026
Consultation
20 Oct 2025
Adopted
In force

ProposedNext: Standards board meeting to review the working group's proposals · 15 Dec 2026

This is a proposed direction, not a final rule. The 2015 Scope 2 Guidance still applies. A wider public consultation is slated for Q2 2027 and a joint GHG Protocol–ISO standard for Q4 2028.

AI-generated illustration

The short, public version.

What happened

On 16 October 2026 the Greenhouse Gas Protocol, a widely used rulebook for counting company emissions, set out where its review of electricity accounting has reached. Its standards board backs a new, stricter way to count green power bought with certificates, matched hour by hour and from grids that can deliver it. The current method would stay available until a date that has not yet been set.

The idea behind it

Two ways to count the emissions from your electricity

When a company uses electricity, the power stations that made it released greenhouse gases. These count as the company's Scope 2 emissions. Since 2015 the GHG Protocol has asked most companies to report this number in two ways (dual reporting).

The first way is location-based. It uses the average mix of power on the local grid. If your grid is half gas and half wind, your electricity is counted as half gas and half wind, whatever deal you signed.

The second way is market-based. It reflects the power a company has chosen to buy. Each unit of renewable power creates a certificate, called an energy attribute certificate. In Great Britain these are REGOs, one for every megawatt hour of renewable output. A company that buys enough certificates to cover a year's use can today report its market-based Scope 2 as close to zero.

Under today's rules, a firm can use solar certificates from a sunny afternoon to cover factory use at midnight, or certificates from a distant grid that cannot send it any power. The proposed new method adds two tests. Hourly matching means certificates must come from the same hour as the electricity used. Deliverability means they must come from a grid that can physically deliver power to the user.

The board now favours a stricter method (Method 1) built on these tests, plus a preference for new clean power plants (incrementality). The current approach (Method 2) could still be used until a cut-off date. How long that lasts, and whether market-based reporting stays required at all, are still open questions.

nearly 1,100

responses to the 2025–26 public consultation, from 56 countries

Source: GHG Protocol feedback summary, 29 July 2026

10 of 10

standards board members who backed moving to Method 1 in a September 2026 pulse check (not a formal decision)

Source: Scope 2 working group minutes, 6 October 2026

Q4 2028

slated publication of the joint GHG Protocol–ISO corporate standard that will carry the new rules

Source: GHG Protocol update, 16 October 2026

What actually changes

Area	Before	After
Time matching	Certificates can cover any use in the same year (annual matching).	Method 1 would need certificates from the same hour as the electricity used.
Geography	Certificates can come from a broad market area, such as a whole region.	Method 1 would need certificates from grids that can deliver power to the user.
New clean power	No preference for new or old power plants.	Method 1 would include incrementality, favouring newer plants. Details are still being worked out.
Which method to use	One market-based method, from the 2015 Scope 2 Guidance.	Two market-based methods. Method 2 (today's) may be used until a set date, and companies would have to say which one they use.
Other purchases	All qualifying certificates go into the inventory figure.	Purchases that do not meet Method 1 could be reported in a separate GHG impact statement or as indicators.

Timeline

January 2015 · upcoming
Scope 2 Guidance published
Introduces dual reporting, location-based and market-based.
14 July 2025 · upcoming
Board sends revisions to consultation
The vote was 10 to 1.
20 Oct 2025 – 31 Jan 2026 · upcoming
Public consultation
Proposes hourly matching and deliverability.
29 July 2026 · upcoming
Feedback summary published
Low support among companies for hourly matching and deliverability.
16 October 2026 · upcoming
Status update published
Sets out the two-method direction of travel.
20–22 October 2026 · upcoming
Working group workshop, Washington DC
15 December 2026 · upcoming
Standards board reviews working group proposals
Q2 2027 · upcoming
Consolidated public consultation
Today

Who it affects

Large companies that buy renewable power

Certificates or green power deals that do not match by hour and grid might no longer cut their market-based figure under Method 1. They may need hourly meter data and new types of contract.

Threshold: Exemptions for smaller users were proposed in 2025; whether thresholds survive is open.

Smaller companies

The 2025 draft proposed exempting smaller organisations from hourly matching. The board's newer direction leaves this unsettled.

Energy suppliers and certificate registries

Customers may ask for hourly certificates and green tariffs tied to specific hours and grids.

Investors and reporting regimes

Many disclosure rules point to the GHG Protocol. IFRS S2 already asks for location-based Scope 2 plus information on contractual instruments, so market-based changes affect how those notes are read.

A worked example

An office that uses power day and night

Illustrative company. It uses 1,000 megawatt hours (MWh) a year, 500 MWh in daylight and 500 MWh at night. It buys 1,000 MWh of solar certificates, all made in daylight hours on its own grid. Assume an illustrative leftover-grid (residual mix) factor of 0.4 tonnes of CO2e per MWh.

01Today's method (Method 2): 1,000 MWh of certificates cover 1,000 MWh of yearly use. Market-based Scope 2 is reported as zero.
02Method 1, hourly matching: daylight certificates can only cover daylight use, so 500 MWh are matched.
03The other 500 MWh of solar certificates cannot be used for night hours.
04The 500 MWh used at night take the residual mix factor: 500 × 0.4 = 200 tonnes CO2e (illustrative calc).

Result

Under Method 1 the same purchase would give a market-based Scope 2 figure of about 200 tonnes instead of zero.

Illustrative only. Numbers are invented to show the mechanics. Final Method 1 rules, including any thresholds, load-profile shortcuts or legacy protections, are not yet set.

Common misreadings

You might read

The new rules apply to this year's reports.

What's actually the case

Nothing has changed yet. The 2015 Scope 2 Guidance still applies, the direction is proposed, and the joint standard is slated for Q4 2028 with a transition date still to be set.

You might read

Renewable certificates are being banned.

What's actually the case

Certificates stay. Under Method 1 they would need to match by hour and come from a deliverable grid. Today's method could be used until a cut-off date, and other purchases could appear in a separate impact statement.

You might read

Companies will stop reporting the grid-average figure.

What's actually the case

The 2025 draft kept dual reporting, so the location-based number continues alongside the market-based one.

What's still uncertain

When the switch happens: The cut-off date for today's method is undecided. The GHG Protocol secretariat told the working group that whether market-based reporting is required at all is still an open question.
ISO's working group sees it differently: Minutes record that ISO Working Group 4 favours monthly matching as the minimum, with hourly optional, and dropped deliverability as not practical. The two bodies plan one joint standard, so these views need to be reconciled.
Buyers and others disagree: The Corporate Energy Buyers Association supports optional hourly matching but has deep concerns about making it mandatory. Some working group members said the direction departs from the balance of consultation feedback.

For practitionersExtra layer · optional for general readersShow

Scope & thresholds

Applies to the Scope 2 market-based method under the GHG Protocol Corporate Standard; the location-based method is revised separately.
Status: proposed ISB direction of travel (September 2026), to be refined by the Scope 2 TWG. Not an approved standard.
Normative strength (shall/should/may) of the market-based requirement is still to be determined.
Delivery vehicle: joint GHG Protocol–ISO corporate standard (with ISO 14064-1), consultation Q2 2027, publication slated Q4 2028.

Key clauses

MBM update (16 Oct 2026), ISB direction of travel: Method 2 may be used until a TBD date; Method 1 should be used; companies shall disclose which method applies; after the date, Method 1 shall be used where data meeting quality criteria exists.
MBM update, Method 1 definition: Incorporates hourly matching, deliverability and incrementality accounting and reporting requirements.
MBM update, AMI multi-statement framework: Market-based GHG Inventory Statement, GHG Impact Statement and Non-GHG Indicators Statement; procurement outside the inventory may go in the impact statement or as indicators.
TWG Meeting #23 minutes (6 Oct 2026): ISB pulse check 10/10 for transition to Method 1; thresholds sit outside the Method 1 framework; legacy clause need still debated.
2025 consultation draft (overview, 29 Sep 2025): Proposed hourly matching with small-entity exemptions, deliverable market boundaries, load-profile hierarchy, legacy clause, and fossil-only fallback where no residual mix exists.

What to do now

Keep reporting under the 2015 Scope 2 Guidance; no change is in force.
Map current certificate and PPA portfolio by hour, grid region and plant age to estimate a Method 1 figure.
Check whether long-term PPAs being signed now would meet hourly and deliverability tests.
Watch the 15 December 2026 ISB meeting and the Q2 2027 consolidated consultation, and plan to respond.

Data you'll need

Hourly (or best available) electricity consumption by site and grid region
Certificate data with production timestamps, generator location and commissioning date
Residual mix emission factors per market, ideally time-resolved

Primary documents

Key terms

Scope 2: Emissions from making the electricity, heat or steam a company buys and uses.
Practitioner note
Indirect emissions from purchased or acquired energy under the GHG Protocol Corporate Standard.
Location-based method: Counts your electricity using the average mix of power on your local grid.
Market-based method: Counts your electricity using the power deals and certificates you have bought.
Energy attribute certificate: A certificate showing one unit of power came from a particular source, such as wind.
Practitioner note
E.g. REGOs in Great Britain, issued per MWh of eligible renewable output.
Hourly matching: Making sure green power certificates come from the same hour you used the electricity.
Deliverability: Making sure the green power came from a grid that can actually send power to you.

In short

The GHG Protocol is moving towards a stricter way to count green electricity bought with certificates, matched hour by hour and from grids that can deliver it. Today's method stays until a date not yet set, and nothing changes in current reports. The new rules are expected in a joint standard slated for late 2028.

Sources

Scope 2 Market-based Method Update: From 2025–2026 Public Consultation to Current Status — GHG Protocol, 16 Oct 2026
Scope 2 Full TWG Meeting #23 minutes — GHG Protocol, 6 Oct 2026
Scope 2 Public Consultation Feedback Summary: Executive Summary — GHG Protocol, 29 Jul 2026
Upcoming Scope 2 Public Consultation: Overview of Revisions — GHG Protocol, 29 Sep 2025
Scope 2 Standard Advances: ISB Approves Consultation — GHG Protocol, 1 Aug 2025
Scope 2 Guidance: Executive Summary — GHG Protocol, Jan 2015
IFRS S2 Climate-related Disclosures — IFRS Foundation
About the REGO scheme — Ofgem
The Greenhouse Gas Protocol Opens Two Public Consultations: Why It Matters — Corporate Energy Buyers Association, 21 Oct 2025

This explainer was written with AI assistance and checked against the primary documents listed above. How we work