What to Know About the Upcoming GHG Protocol Scope 2 Revisions: The Rise of Hourly Accounting
The GHG Protocol announced proposed updates to its Scope 2 Guidance (2015), entering a 60-day public consultation starting October 20, 2025. These changes will fundamentally shape how companies measure and report emissions from purchased electricity, the foundation of corporate decarbonization targets and energy procurement claims. This guidance underpins corporate reporting frameworks, like CDP, as well as mandatory compliance reporting, like CSRD and SB253 in CA, among others.
The update keeps the familiar dual-reporting structure of location-based and market-based emissions reporting, but fundamentally raises the bar for accuracy, transparency, and comparability across global frameworks like IFRS S2, ESRS/CSRD, and SBTi.
Why an Update Now
When the Scope 2 Guidance was released in 2015, renewable tracking systems were often annual, grids were static and had large boundaries, and disclosure rules were voluntary. Today, electricity markets are dynamic, data granularity has exploded, and many jurisdictions require formal climate disclosures.
These proposed updates aim to fix key issues like double counting risk and mismatched claims by:
- Aligning Scope 2 rules with modern, data-driven energy markets and grid realities.
- Reducing inconsistencies across reporting regimes.
- Strengthening the credibility of renewable energy and net-zero claims (such as the claim that an entity is powered by 100% renewable energy).
What’s Staying the Same
The core two-method structure remains, as both methods offer decision-useful insights:
- Location-based method: Reflects the average emissions intensity of the grid where electricity is consumed.
- Market-based method: Reflects emissions from purchased energy backed by contractual instruments like RECs or GOs, reflecting purchasing decisions.
What’s Changing
| Area | Current (2015) | Proposed (2025) |
| Location-Based Precision | Regional or national grid averages | Must use the most precise accessible emission factors (geographic + temporal alignment). |
| Grid Boundary | Often ignores energy trade | Must prefer consumption-based factors reflecting imported/exported electricity flows. |
| Market-Based Matching | Annual or monthly certificate matching | Move to hourly matching as the new gold standard for claims. |
| Market Deliverability | Broad market boundaries (e.g., entire US or EU) | Certificates must be deliverable within the reporting entity’s local grid connection (e.g., within ERCOT or PJM). |
| Residual Mix Defaults | Grid average | Use a specific residual mix factor (RMF) or a fossil-only factor when RMF is unavailable (critical for avoiding double counting). |
| Implementation Flexibility | Few defined provisions | Introduces load profiles (for estimating hourly consumption), legacy clauses (for existing long-term contracts), and a multiyear phase-in. |
What This Means for Energy Suppliers
Energy suppliers and utilities will face new expectations for granularity and transparency:
- Hourly matching will require suppliers to track when their generation aligns with customer load, moving beyond simple annual totals.
- Deliverability rules mean green-power claims must be confined to physically connected grid regions, discouraging the sale of certificates far from the point of consumption.
- Standard Supply Service allocation (SSS) – Suppliers “should” allocate SSS electricity supply and related EACs for energy on a prorata basis – helping to avoid companies needing to calculate their own share of the supply.
In short: suppliers will need to tighten up how they account for their energy, so that there is a more uniform and consistent method of reporting to customers.
What This Means for Corporate Buyers
For corporations, the revisions tighten how Scope 2 claims are made:
- Hourly is the Benchmark: Annual REC matching will no longer suffice for robust claims; hourly or near-hourly alignment becomes the new benchmark for credible decarbonization.
- Hierarchy of Data Quality: Given that hourly data is not widely accessible, the go forward guidance proposes that companies use the most “appropriate and accurate” data available for different calculations and inputs (such as emission factors and load data). It offers hierarchies to inform decision making in situations where the ideal data is not available.
- Tightening of Market Boundaries: Introducing a methodology for demonstrating deliverability
In short: the accounting process for Scope 2 emissions becomes significantly more data-driven but in a thoughtful and scalable way.
The Cleartrace Take and Call To Action
At Cleartrace, we view these updates as a needed upgrade to the accounting framework—a necessary step toward achieving physical grid reality.
However, there’s a long way to go in this process, and the revision team is at a critical juncture needing important feedback from all parties and stakeholders. The call to action is clear, it’s time to read, assess, and weigh in with input that will help ensure the GHG gets this right.
To review the Consultation Materials, click here.
To complete the Consultation Survey, click here.
The public consultation runs from October 20, 2025 to December 19, 2025, with final guidance anticipated by the end of 2027—though stay tuned for many more updates in the months ahead. Cleartrace will continue to participate in the consultation and help both suppliers and buyers navigate this new era of granular energy accountability.
