Public comments on the revised GHG protocol Scope 2 have been released — Multiple methods to be considered due to disagreements over hourly matching, etc.

Vice Chair of the Global Sustainability Standards Board (GSSB)
Member of the GHG Protocol Expert Working Group (TWG)
Director of Zeroboard Research Institute Tomoo Machiba

On July 29, 2026, the GHG Protocol Secretariat published the results of the public consultation (public comments) on the proposed revisions to the calculation and disclosure methods for Scope 2 (indirect emissions from the use of electricity, heat, and steam supplied by others) *1) . Based on the input received from more than 1,000 countries in 56 countries, the Protocol's Independent Standards Board (ISB) instructed the Technical Working Group (TWG) to consider multiple approaches to calculation and disclosure based on market standards *2) . This article summarizes the main feedback, including that from Japan, the reactions from various parties, the future process, and the responses of Japanese companies.

overview of the proposed revisions

The current Scope 2 Guidance (2015) requires dual reporting of indirect emissions from purchased electricity, etc., based on both location and market criteria. In the revision process, the Scope 2 TWG, consisting of approximately 45 experts, drafted the proposal, and in July 2025, the ISB approved submitting it for public comment. The comment period ran from October 20 of the same year to January 31, 2026 (*3) .

While maintaining dual reporting, the proposal includes stricter quality standards for electricity contract certificates under market criteria, including: ① mandatory hourly matching for high-consumption organizations; ② procurement from within the physically possible range to consumption points (supply feasibility); ③ allocation of public and mandatory supplies such as FIT (feed-in tariff) as "standard supply Service" (SSS) to limit monopolistic claims by specific companies; and ④ updating the definition of residual mix and defaulting to the application of fossil fuel-based coefficients when there is no residual mix (Figure). Under location criteria, the proposal calls for an Emission factor hierarchy that prioritizes geographical granularity, temporal granularity, and import reflection, and the obligation to use the most precise coefficients that are "accessible" (free, public, and reliable sources). Measures to enhance feasibility were also presented, such as the use of load profiles, exemption from hourly matching for low-consumption organizations, legacy clauses in existing contracts, and phased application (for details, please refer to our insight " GHG Protocol Scope 2 Revision Proposal, Public Comment Participation Guide " *3) ).

Figure: overview of the proposed Scope 2 revisions


Zeroboard Create based on GHG Protocol documentation *4)

Key points of the feedback

1,072 responses were received from 56 countries. By organizational type, companies accounted for 43.5%, industry associations 9.6%, and consultants 9.0%, together making up nearly two-thirds, or approximately 62%. NGOs/civil society accounted for 8.6%, academia/research 4.1%, power companies 8.5%, and Financial Institution 2.2%, representing smaller groups. By region, Europe accounted for 35.7%, North America 34.1%, and East Asia 17.4% (186 responses). In general, support for hourly rates and supply potential was low in market criteria, while residual mix, SSS, and default coefficient application received relatively moderate support. Support for and opposition to the proposed hierarchical location criteria were evenly divided *5) . The main points are summarized below (Table).

1) Hourly Matching

The time-of-day matching initiative received strong opposition overall, with 22% in favor, 7% neutral, and 70% low or against out of 909 responses. Among companies and industry groups, support was 12% each, while low or against reached 82% each. East Asia, including Japan, also showed strong opposition, with 15% in favor and 81% low or against. Conversely, data analytics and software providers showed a contrasting result, with 81% in support. According to EnergyTag, a UK non-profit organization that develops high-granularity Energy certification standards, Google's support among these was identifiable *6) .

Supporters emphasized that the measure would prevent time discrepancies, such as claiming solar consumption at night, and would lead to greater scientific integrity of inventories and a reduction in greenwashing risks. Many also pointed out that improved accuracy in supply and demand timing would encourage investment in technologies necessary for further decarbonization, such as energy storage, demand flexibility, and clean baseload. Concerns among those concerned included the possibility of discouraging participation in the voluntary renewable energy procurement market (87%), increased reporting and auditing burdens and costs (86%), and the need for it to be optional rather than mandatory (84%). There was broad support for the hourly exemption measure for low-consumption organizations, with 76% of the 748 responses voting in favor of the exemption.

2) Availability of supply (deliveryability)

Regarding supply feasibility, out of 875 responses, 30% supported, 11% were neutral, and 59% were unsupportive or opposed. While 19% of businesses supported the measure and 71% were unsupportive or opposed, other stakeholders showed relatively higher support. Supporters argued that the accuracy of inventory would be compromised by certificates from remote locations unrelated to the consumption grid. The most common reason for opposition was concern that narrowing market boundaries could hinder investment in regions with high decarbonization potential (87%), and there was also concern about the possibility of avoiding long-term power purchase agreements (PPAs) and relying on short-term procurement by purchasing renewable energy certificates on a case-by-case basis (72%). The aggregated document also recorded opinions that, given Japan's nationwide mechanism to prevent double counting of non-fossil fuel certificates, the addition of supply feasibility requirements is unnecessary.

3) Standard Supply Service(SSS)

The introduction of SSS received higher support than the two requirements mentioned above, with 49% in favor, 21% neutral, and 30% against among 522 responses. While there are expectations for fair allocation of renewable energy consumption and prevention of double counting, East Asia showed a harsh result with 19% in favor and 66% against. In Japan, Taiwan, Malaysia, and other countries, where certificates derived from FIT account for the majority of voluntary procurement, there are strong concerns that considering SSS will drastically reduce the number of eligible certificates, leading to price increases and a decline in procurement willingness. Many also called for clarification of the definition, such as partial subsidies and the treatment of FIT.

4) Legacy clause

Regarding the legacy clause that would allow existing long-term contracts, which might not be included under market standards, to remain valid for a certain period after the new standards come into effect, 90% of the 801 responses supported it. This is close to a consensus from the perspective of maintaining market confidence and ensuring fairness for early adopters. In terms of design, the specifics of the application start date (contract signing or power generation start date) and the validity period remain points of contention.

5) other Key Issues

Location Criteria: Regarding the Emission factor hierarchy, support was evenly divided, with 40% in favor, 44% weakly supporting or against, and 17% neutral. In East Asia, support was 23%, while weakly supporting or against was 60%. While there are expectations that refining geographical and temporal granularity will improve accuracy, concerns were raised about the narrowness of regional boundaries, consistency with mandatory disclosure, and increased costs. There was broad support for the definition of "accessible" (free, public, and reliable sources), but support for mandating the use of the most refined factors was divided.

Revision of Residual Mix Definition: 59% of 537 responses supported the update, while 23% were unsupportive or opposed. While there was strong expectation for preventing double counting and clarifying the definition, support remained low in East Asia, with only 29% supporting the update and 53% being unsupportive or opposed. The feasibility of implementing a revised residual mix at the market boundary level was a key point of contention.

Defaulting to fossil fuel-based coefficients: The proposal to use fossil fuel-based coefficients instead of grid averages when there is no residual mix received mixed support from 46% of 522 respondents, with 39% showing little or no support. The conflict stems from both appreciation of data conservatism and the promotion of renewable energy procurement, and concerns about increased emissions reporting in data-deficient regions.

Feasibility Measures: While there is broad support for various exemptions, the use of load profiles, and phased implementation, there is disagreement on whether they are sufficient from a feasibility standpoint. The ISB concludes that the current proposal, which combines stricter calculation and disclosure methods with exemptions, is not sufficiently effective in lowering barriers to corporate participation or in increasing the effectiveness of actually supplying renewable energy to the grid.

Table: Feedback on the proposed revisions to Scope 2

Reactions from various parties

The Industry, which calculates and discloses data based on the GHG protocol, is most clearly opposed to the application of hourly matching and supply feasibility, citing concerns about increased cost burdens, a shrinking of the self-sufficiency market, and increased difficulty in PPAs. On the other hand, EnergyTag claims that more than 100 organizations, including Google, Engie, and the Sierra Club, support the revised Scope 2 plan, and that more than 1,500 companies worldwide are already implementing time-of-use accounting, with corresponding pricing structures available in countries that account for 73% of global electricity demand, thus asserting that it is "reality, not theory." Developers of technologies that are difficult to evaluate using annual matching, such as geothermal energy and energy storage, are also among the supporters. *6)

From the perspectives of scientific integrity and preventing greenwashing, NGOs and academia have relatively high support for the revised proposal, but support for hourly matching is divided, with only 48% of NGOs and 47% of academia supporting it. Although the number of responses from investors and Financial Institution was limited, only 26% supported hourly matching, while 86% supported SSS, indicating interest in market transparency and the prevention of double counting. The Japanese Bankers Association, on the other hand, has expressed concern about the side effects on sustainable finance due to stricter regulations. *7)

Other opinions and related points from Japan included in the summary document that, while the environment for acquiring time-of-day consumption data is relatively improving due to the spread of smart meters, the use of load profiles may deviate from the annual indicators of domestic regulations; the argument that the supply feasibility requirement is unnecessary based on nationwide tracking of non-fossil fuel certificates; and the difficulty of SSS classification due to the dual nature of FIT and attribute-based trading. The opinion distribution across East Asia (15% in favor of hourly rates, 19% in favor of SSS rates, 29% in favor of residual mix rates, etc.) is consistent with the cautious stance of Japanese companies and Industry associations.

Handling of hourly matchmaking in SBTi 2nd Edition

The Scientific Targets Initiative (SBTi) published the second version of its enterprise net-zero standard in June 2026. While the initial draft considered a phased hourly matching obligation for large consumers, the final version retained annual matching for determining progress toward the target. Instead, companies in Category A (large enterprises + medium-sized enterprises in high-income countries) with an annual electricity consumption of 10 GWh or more within their supply area are required to calculate and disclose their hourly matching ratio, and a voluntary leadership evaluation program has been established (matching more than 50% of consumption with low-carbon electricity by time of day by 2030, more than 75% by 2035, and more than 90% thereafter). The SBTi has made it clear that it will not preempt the results of deliberations while maintaining consistency with the direction of the Scope 2 revision, and will solicit evidence to explore the additional impact of hourly matching .*8)

Future revision process

In April 2026, the ISB decided to first review the public comments itself to determine the direction, and then entrust the detailed design to the TWG. In July of the same year, the ISB instructed the TWG to consider multiple reporting approaches regarding market standards as its direction. *2) The public comments highlighted a design question: "To what extent should contractual attributes be linked to physical time and place?" and the two theories of change behind it. One is a path to maximize renewable energy trading through participation in voluntary procurement, and the other is a path to increase grid effectiveness by tightening matching conditions. It is thought that the ISB introduced the consideration of multiple methods because it could not converge this conflict into a single proposal.

The Scope 2 TWG is expected to hold an in-person meeting in September 2026 to discuss multiple approaches based on the public comments received *9) . In parallel, in light of the integration with ISO 14064-1, the draft consultations on Corporate Standards, Scope 2, Scope 3, and Behavior and Market Instruments (AMI) will be unified and published in the second quarter of 2027 for public comment. During this time, it will be up to the ISB to decide whether Scope 2-specific consultations will be needed again. The final standards are expected to be completed by the end of 2028 as a single document, "Corporate Standards, Third Edition" *10) .

Even if opposition prevails in public comments, the final decision on the Contents will be based on evidence and three criteria: "scientific integrity," "impact," and "feasibility." In the future, interim solutions such as multiple reporting methods and phased implementation will likely be the focus of discussion. In the meantime, Japanese companies should prepare for the revisions by: ① understanding the current state of their renewable energy procurement in terms of time, location, and reliance on FIT; ② responding promptly to the requirements of SBTi version 2; ③ providing continuous input on market boundaries, SSS, and legacy design through the government and industry associations; and ④ considering investments in time-value power sources such as battery storage, geothermal energy, and demand response (DR).

*1) Greenhouse Gas Protocol, Scope 2 Public Consultation Summary, 29 July 2026. https://ghgprotocol.org/sites/default/files/2026-07/S2-PublicConsultationSummaryofFeedback-2026.07.29.pdf

*2) Greenhouse Gas Protocol, Scope 2 Public Consultation Summary of Feedback: Executive Summary, 29 July 2026. https://ghgprotocol.org/sites/default/files/2026-07/S2-ExecutiveSummary-PublicConsultation%20ummaryofFeedback-2026.07.29.pdf

*3) Tomoo Machiba, "Guide to Participating in Public Comments on the Revised GHG Protocol Scope 2,"Zeroboard Insight, January 9, 2026. zeroboard 

*4) Greenhouse Gas Protocol, “Upcoming Scope 2 Public Consultation: Overview of Revisions”, blog post, 29 September 2025. https://ghgprotocol.org/blog/upcoming-scope-2-public-consultation-overview-revisions 

*5) Argus Media, “GHG Protocol faces pushback on scope 2 reforms,” 29 July 2026. https://www.argusmedia.com/en/news-and-insights/latest-market-news/2858486-ghg-protocol-faces-pushback-on-scope-2-reforms

*6) EnergyTag, “Leading corporates, investors and researchers back higher-integrity clean energy accounting — While many anonymous companies endorse a flavored status quo,” press release, 31 July 2026. https://energytag.org/wp-content/uploads/2026/07/GHGP-Consultation-Press-Release-1.pdf

*7) Japanese Bankers Association, JBA Comments on Greenhouse Gas Protocol Scope 2 Public Consultation, 26 December 2025. https://www.zenginkyo.or.jp/fileadmin/res/en/news/news251226.pdf

*8) Science Based Targets Initiative (SBTi), Corporate Net-Zero Standard Version 2.0, June 2026. https://sciencebasedtargets.org/corporate-net-zero-standard-v2

*9) Heather Clancy, “GHG Protocol adjusts standards update timelines”, Trellis, 29 July 2026. https://trellis.net/article/ghg-protocol-adjusts-standards-update-timelines 

*10) Greenhouse Gas Protocol, Corporate Accounting and Reporting Standard (Corporate Standard), Version 3.0 Standard Development Plan, 29 July 2026. https://ghgprotocol.org/sites/default/files/2026-07/Consolidated-StandardDevelopmentPlan%28SDP%29-2026.07.29.pdf