GHG Protocol Scope 2 Revisions: Public Comment Participation Guide (Until January 31st)

Global Sustainability Standards Board (GSSB) Board Member
GHG Protocol Technical Working Group (TWG) Members
Director of Zeroboard Research Institute Tomoo Machiba

The GHG Protocol, an international private rulebook for calculating greenhouse gas (GHG) emission amount that cause climate change, is undergoing its first major revision in approximately 20 years. In October 2025, a revised version of the Protocol was published, detailing the calculation of Scope 2 emissions (indirect emissions from the use of electricity, heat, and steam supplied by October) and the concept of resulting emissions impacts in the power sector.

*The overall picture of the GHG Protocol revision (background, aims of the revision, impact on other areas) is summarized in the article " GHG Protocol Revision Interim Report ."

The proposal will have a major impact on Japan's power industry and companies, as it will mean that non-fossil fuel certificates, which many companies rely on to achieve decarbonization, will no longer be valid in their current form, and that major Contents will be needed to certificate rules and renewable energy procurement methods.

Because the GHG Protocol's calculation methodology is widely applied to sustainability disclosure standards such as IFRS S, SSBJ, GRI, and European CSRD /ESRS, as well as emissions reduction target Settings by SBTi and benchmarks such as CDPs, the revisions could have an impact on companies' future business and investment plans. The Protocol Secretariat has postponed the public consultation and is now accepting comments until January 31, 2026. To help companies and stakeholders participate in the public comment process, this article summarizes the proposed revisions and key points of the resulting emissions impacts, the points on which opinions are sought through the questionnaire, and tips for responding, based on materials from the GHG Protocol Secretariat *1 .

Background to the revision of Scope 2- Refining inventory calculations

According to the GHG Protocol Secretariat, the Protocol's Corporate Standards, Scope 2 Guidance, and Corporate Value Chain (Scope 3) Standards, which are currently being revised, are originally intended to take stock of GHG emission amount attributable to each organization and its value chain (inventory accounting), and are clearly distinguished from consequential accounting, which estimates the impact of specific emission reduction actions on the entire system by comparing them with a baseline in which they do not exist. While both inventory accounting and consequential accounting have value, they have different perspectives and targets for calculation, so they should be clearly distinguished in reporting (Figure 1).

Source: GHG Protocol, Land Sector and Removals Guidance: Part 1 (draft) *2 Figure 13.1, page 243
Zeroboard has translated the text into Japanese and made some corrections to the design and notation.

As the movement toward mandatory disclosure of emission amount based on GHG protocols such as IFRS S and CSRD /ESRS progresses, providing accurate and comparable data that will help investors and other stakeholders make decisions will be key. For this reason, the revision of Scope 2 aims to improve accuracy and comparability by purifying it into an emissions inventory that is physically linked to a company's own activity, and to maintain consistency with Scope 1 and Scope 3.

Furthermore, as the renewable energy market matures, with renewable energy generation expected to surpass coal-fired power for the first time in the first half of 2025 *3 and the cost of generating electricity using existing technologies such as solar and onshore wind power falling dramatically, claims of 100% renewable energy that are out of sync with a company's actual consumption risk being perceived as greenwashing. The plan also aims to align each company's renewable energy procurement with the physical reality of the power system and accelerate substantial decarbonization without the need for fossil fuels, known as "24/7 carbon-free electricity." The plan aims to curb claims of renewable energy replacement through the use of existing power sources and instead encourage investment in new, additional renewable energy sources, particularly stable power sources such as geothermal and offshore wind, which are still expensive but have little time fluctuation, as well as storage facilities, and the spread of demand response (adjustment of demand patterns).

Points to note when answering the questionnaire

The GHG Protocol Secretariat is accepting comments via an online questionnaire *4 until January 31, 2026. Comments submitted by other means, such as email, will not be considered. In the interest of transparency, all responses submitted will be made public, including names, organization names, regions, etc. In principle, responses that are not to be made public due to commercial confidentiality or other reasons, must be applied for and approved in advance.

Revisions to the protocol are reviewed and decisions are made in the order of "scientific consistency," "impact," and "feasibility," and public comments are judged not simply by majority vote, but on whether they meet these priorities. Since each organization is only allowed to submit one comment, and there is no voting, it seems unlikely that it would be effective for many within the industry to submit the same opinion.

When expressing your opinion, it is effective to avoid one-sided complaints such as "it's costly" or "it's more work." Instead, it is effective to consider priorities and adopt a universal logical structure that goes beyond Japan's domestic circumstances. While there is a high possibility that the current "100% renewable energy strategy" of many companies will collapse, the application of the revised standards is still several years away, and each country will likely make progress in developing corresponding systems and regulations in the meantime. It is important to think based on future conditions, not the current situation, and to present constructive alternatives and opinions in light of the above priorities from the perspective of promoting decarbonization. It would also be effective to present specific alternatives, transition periods, and exemptions to ensure feasibility.

The questionnaire contains 183 questions for Scope 2 alone (the questions are listed in the public comment materials), but you do not need to answer all of them; you can answer only the parts that are relevant to your company or that you consider important, using the information below as a reference.

If you want to see more detailsHerePlease register from here.
The full document will be sent to you by email.

Below is a summary of the column, which you can download.

Key points of the revisions and public comments

1. Definition and purpose of Scope 2 and calculation standards (summary)

While the "dual accounting" of Scope 2's location and market standards will be maintained, the proposal is to clarify the definitions and purposes of both and align Scope 2 with the physical reality of the power system (when and where electricity is generated). The attributional nature of the Scope 2 definition will be emphasized, and the effects of avoided emissions will be excluded. The location standard will reflect "time" and "place," and consumption-based calculations will be recommended. The market standard will also specify requirements for the alignment of certificates with physical consumption (temporal correlation and supply availability).

For details, please download:
The key points of the revision (changes in definitions) and points on which opinions are sought (points of discussion in Q18 to Q22) are summarized in the DL materials.

2. Revision of Location Standards (Summary)

Proposals for location criteria include more precise data and stricter selection rules. Priority is given to narrower geographical boundaries (local boundaries), and priority is given to monthly over annual time granularity, and hourly over monthly. Consumption- Emission factor factors are recommended over production-based. Data "accessibility" requires data to be publicly available, free of charge, and from reliable sources. If hourly data is unavailable, allocation and estimation using load profiles is permitted.

For details, please download:
The Emission factor hierarchy (Q23-34), accessibility (Q35-39), "shall" mandate (Q44-47), investor and guarantor perspectives (Q52-56), data retention status (Q57-60), and cost and burden reduction measures (Q62-66).

3. Revision of Market Standards (Summary)

The market standard is a calculation method that takes into account contracts such as renewable energy certificates (EACs) and power purchase agreements (PPAs). To prevent deviation from actual consumption, the following four stricter measures have been proposed.

3-1. Hourly matching

A proposal to move the contract consistency certification from annual to hourly, requiring that the certificate be generated and redeemed during the same time period as the electricity was consumed. If no hourly data is available, an estimate based on the load/generation profile will be allowed.

For details, please download:
The pros and cons of hourly matching (Q71-76) and costs and effort (Q77-82) are summarized in the downloadable materials.

3-2. Supply availability and market boundaries

The trend is to limit certificate procurement to "same markets where electricity can be physically transmitted." The market boundary may be determined by bidding zones, etc. For procurement outside the region, supply feasibility must be demonstrated by securing price differentials (within a certain range) or physical transmission rights.

For details, please download:
The DL materials summarize the verification of supply feasibility (Q83-86) and market boundary definition (Q88-91).

3-3. Standard Supply Service(SSS)

Public power sources (such as renewable energy supported by subsidies and levies, large-scale hydropower, and nuclear power) and default supply sources will be defined as "standard supply Service(SSS)," restricting the ability of specific companies to assert environmental value on a monopoly basis. Low-carbon power sources included in SSS will be limited to claims up to the grid average ratio.

For details, please download:
The DL materials summarize the pros and cons of the SSS concept (Q97-101), definition and scope (Q102-105), and default specifications (Q107-109).

3-4. Residual mix and fossil fuel base factor

This proposal tightens the Emission factor rules that apply to electricity consumption not covered by certificates, etc. The residual mix reflects the composition minus the purchase of certificates by SSS and others, and indicates a direction to use a fossil fuel-based factor (or a grid average of fossil fuels only) as the default if the residual mix is ​​unreliable.

For details, please download:
The DL materials summarize the residual mix definition (Q113-117), data preparation status (Q118-123), and fossil fuel factor enforcement (Q124-129).

In addition, the stricter overall evaluation (Q130-151) with four points is also explained in the DL.

4. Mitigation and transitional measures (summary)

In order to avoid market disruption due to sudden changes caused by the introduction of the above proposed amendments, the following mitigation and transitional measures have been proposed and comments are being sought.

4-1. Exemption provisions

The proposal is to exempt organizations and location with low electricity consumption from the hourly matching requirement and allow monthly or annual matching. The threshold is being considered to be in the range of 5 to 50 GWh, and exemptions based on small and medium-sized enterprise criteria are also being considered.

For details, please download:
The DL materials include the exemption threshold (Q70), the pros and cons of exemption and threshold (Q153-165), and the exemption deadline (Q166-167).

4-2. Legacy clauses

A proposal to allow long-term contracts (such as PPAs) concluded before the revision to be reported under the previous rules for a certain period or for the duration of the contract. Points of contention include the time of the contract and the applicable period.

For details, please download:
The DL materials summarize the pros and cons of implementation (Q171-175), eligibility and duration (Q176-178), and alternatives (Q181-183).

4-3. Phased introduction

After the final standard is published (scheduled for the second half of 2027), a transition period of several years is expected. The question is from which reporting year the standard will be applicable.

For details, please download:
The DL materials provide an overview of when the system can be introduced (Q67-68).

5. Consequential Accounting in the Electricity Sector (Summary)

This public consultation includes proposals and questions regarding the use of consequential accounting methods to estimate avoided emissions from emissions reduction actions in the electricity sector. Below we explain the background, Contents, and points on which we are seeking feedback in the questions.

5-1. Background to the discussion on consequential valuation

Apart from inventory calculations, there is growing interest in the impact of specific interventions on the entire system (avoided emissions). In the electricity sector, the Emission factor of marginal power sources has become important, and in Japan, a way of thinking has been presented to evaluate reduction effects on the assumption that thermal power is the marginal power source.

For details, please download:
The DL materials provide a summary of the background (including charts and figures) and explain the relationship with the AMI Working Group.

5-2. Proposal Contents

The proposal consists of four elements: (1) calculation formula (amount of electricity procured x MER), (2) additionality, (3) MER (OM/BM), and (4) weighting of OM/BM. It also recommends annual reporting and indicates a policy of not including secondary effects.

For details, please download:
The DL materials outline the specifics of the four elements, the methods and databases that can be adopted, and implementation issues.

5-3. Points on which opinions are sought

Specific feedback is required on the advantages and Issue of using consequential accounting in the power sector, calculation formulas, additionality tests, MER methodology and granularity, and OM/BM weighting.

For details, please download:
The intent behind questions Q18 to Q52 and the perspectives for Create comments are summarized in the downloadable materials.

The proposed Scope 2 revisions are expected to have a major impact on Japan's electricity market and renewable energy system. Companies operating overseas will also be concerned about how they will be handled in electricity procurement in each country. The public consultation is an important opportunity to directly participate in the formation of future international decarbonization rules. While there is a hurdle of being in English, many of the questions simply require you to choose from multiple options, so we hope you will respond while referring to the downloadable materials.

"GHG Protocol Scope 2 Revision Proposal: Public Comment Participation Guide"
Download the full PDF for free here

1) GHG Protocol, Public Consultation – Scope 2 and Public Consultation – Consequential Electricity-Sector Emissions Impacts. https://ghgprotocol.org/ghg-protocol-public-consultations 

2) GHG Protocol, Land Sector and Removals Guidance, Part 1: Accounting and Reporting Requirements and Guidance, Draft for pilot testing and review, September 2022. https://ghgprotocol.org/land-sector-and-removals-standard 

3) BBC, “Renewables overtake coal as world's biggest source of electricity”, 7 October 2025. www.bbc.com/news/articles/cx2rz08en2po 

4) GHG Protocol, GHG Protocol Public Consultations. https://ghgprotocol.org/ghg-protocol-public-consultations