The future of the GHG Protocol: How the standards are evolving

The Greenhouse Gas (GHG) Protocol standards are the most widely adopted standards for GHG emissions accounting globally. However, despite their widespread use, the standards have remained largely unchanged since 2015. With an increasing focus on decarbonization, the need for updates to ensure consistent and comparable GHG emissions calculations has become crucial.

To address this need, the GHG Protocol conducted a five-month public comment period starting in November 2022 to gather stakeholder feedback on the current standards documents, including the Corporate Standard, Scope 2 Guidance, Scope 3 Standard, and Scope 3 Calculation Guidance. During this period, they collected over 1,400 responses focused on understanding user needs and identifying gaps which may warrant clarifications, additional guidance, or updates. In addition, they also gathered over 230 proposals for potential updates to the standards and guidance. This feedback is currently being analyzed, with a final report expected in 2025.

Here, we present some key findings from the surveys, offering insights into the future evolution of these standards.

Although each guidance document covered in the surveys highlighted unique areas of improvement for specific topics, there were many common themes across all topics. Responses suggested that the GHG protocol should:

• Provide further guidance on the role of market-based mechanisms in GHG accounting: The role of market-based mechanisms, such as energy attribute certificates (EACs), green tariffs, and other contractual options, has come under increased scrutiny. Companies often use these mechanisms to reduce their emissions, making it a critical consideration for the GHG Protocol and its impact on corporate accounting and reporting in the future. Further, as corporate value chain emissions have become increasingly important with companies disclosing emissions and setting targets, there has also been confusion around the role of market-based mechanisms in scope 3 accounting. Survey respondents called for clearer quality criteria for market-based approaches and guidance on their role in scope 3 accounting. The GHG Protocol is addressing this critical issue through a seperate review process.
• Align with other reporting standards: As requirements for GHG emissions and sustainability continue to gain traction, the emergence of new reporting standards has added even more complexity and confusion around reporting. Respondents emphasized the need for increased harmonization and alignment with other reporting programs, including CDP, ISO, Science Based Targets Initiative (SBTi), Global Reporting Initiative (GRI), International Sustainability Standards Board (ISSB), Task-Force on Climate-Related Financial Disclosures (TCFD), EU Corporate Sustainability Directive (CSDR), and the new SEC Climate Disclosure Rule.
• Require third-party verification: Currently, the GHG Protocol does not mandate verification or assurance of GHG inventories in its standards. Feedback on this topic varied widely. Some respondents feared it would burden companies and add confusion, especially with existing global verification requirements. Others believed verification could enhance transparency, comparability, and confidence in the data. Future revisions might include requirements for limited assurance or verification, or at least increased guidance on the topic.
• Encourage the use of high-quality data and calculation methods: Accurate emissions accounting is challenging when it relies heavily on assumptions and estimates. Respondents stressed the need for guidance on acceptable estimation methods and tools for collecting data on operations and supply chain activities. They also highlighted the limited availability and accessibility of high-quality emission factors, particularly for Scope 3 emissions. Suggestions included creating an open-source emission factor database to enhance consistency and transparency across inventories. In terms of calculation methods, many requests focused on practical guidance, examples, and case studies. Respondents sought increased details for specific emissions sources like fugitive emissions, self-generated energy, new technologies, and avoided emissions. Suggestions also included recommendations to phase out unreliable methods such as spend-based approaches.
• Disclose the source of input data: Improved data quality and transparency are essential for accurate emissions tracking. Currently, the GHG Protocol lacks requirements for companies to disclose the exclusion of sources, facilities, and operations or discuss the use of estimated versus actual data. This lack of transparency could lead to confusion (or worse, manipulation) in reporting. Accurate and consistent tracking is critical for establishing targets and recognizing emissions reductions for decarbonization. Respondents also underscored the necessity for reliable regional-, category-, and industry-specific benchmarks to ensure transparency and accountability across emissions reporting. To further support accurate tracking, respondents suggested the GHG Protocol provides guidance on setting internal key performance indicators (KPIs) based on intensity metrics, increased guidance on target-setting based on the inclusion or exclusion of data, and tools to properly track company, product, and value chain performance.

Stakeholders provided additional feedback not covered in this article, including requirements to disclose triggers for base year recalculations and removing requirements to report emissions for all seven GHGs unless these are found to be material. While most feedback was applicable to all standards developed by the GHG Protocol, several standard-specific suggestions were notable:

• For the Corporate Standard, responses proposed moving away from three consolidation approaches (operational, financial, and equity share) into a single approach aligned with financial accounting. This would improve comparability, consistency, regulatory alignment, and aggregation possibilities.
• In the Scope 2 guidance, there were significant comments around maintaining dual reporting of market-based and location-based emissions. This approach links consumer choice to impact. Respondents also highlighted the need for increased guidance in emerging energy technologies, such as energy storage, granular grid emissions data, and hydrogen as an energy carrier.
• Lastly, for Scope 3, there were requests for additional accounting support by means of guidance clarification (the distinction between upstream and downstream T&D, shared activities), access to quantification tools, calculation examples, and generally more resources.

Based on these responses, there are several key opportunities to enhance the alignment, reliability, and relevance of the GHG Protocol standards. Revisions are expected to continue until 2025, with final statements anticipated by late 2025 to 2026. Ramboll’s technical experts are closely tracking these developments and supporting our clients with potential changes. Since this timeline may vary, it is crucial to stay updated with the GHG Protocol's website and announcements for the most current information (which you can also find via Ramboll insights) – please reach out to us with any questions or to understand potential impacts on your GHG inventory.

The revisions to the GHG Protocol standards are not a one-time event, and the public comment period demonstrates the commitment to user-driven improvement. As stakeholder needs evolve and new climate challenges emerge, the GHG Protocol will likely continue to refine and update its standards through ongoing public engagement processes. Companies and other stakeholders should stay informed and prepare to adapt their reporting practices as the standards evolve.