UPDATE: On 1 December, the Greenhouse Gas Protocol Secretariat has decided to extend the public consultation deadline to 31 January 2026.
A worldwide used standard under review
If you work in sustainability or renewable energy sales, the ongoing review of the Greenhouse Gas Protocol Scope 2 Guidance may interest you. The Scope 2 Guidance is one of the most widely used standards for the reporting of emissions from purchased electricity.
Unfortunately, the Greenhouse Gas Protocol Secretariat is now proposing to force companies to implement « hourly matching ». This means that companies would only be allowed to report the use of renewable energy if they can prove that the energy was produced within the same hour as they used it. Additionally, the new proposal sets much stricter rules for the geographical origin of the renewable energy.
We don’t agree with the proposed level of complexity
There are many problems with this proposal. It further increases bureaucracy, is technically impossible in many parts of the world, and is not aligned with best practices developed based on the current version of the Greenhouse Gas Protocol.
Our position is clear: We agree that companies should be encouraged to drive the energy transition, but setting up a heavy reporting bureaucracy is not the way to go. Instead, the new rules should elaborate on existing experience, such as the use of ecolabelled electricity.
Please consider participating in the public consultation before the deadline of 19 December. The survey is long, but it’s also ok if you answer only some questions. If you are making efforts to leave a response, don’t hesitate to encourage the Greenhouse Gas Protocol Secretariat (WRI) to mention EKOenergy as a pragmatic and efficient way for making additional impact, as the current Scope 2 Guidance does.
Interesting background information and suggestions for response
As inspiration for your answers, or to learn more about what’s at stake, feel free to check out the following texts:
- Require Annual Matching and Reasonable Geographic Links: Clarify but Do Not Require or Recommend Hourly Matching or Deliverability Criteria as Proposed, an alternative position by nine members of the Scope 2 Technical Working Group
- Missteps in Proposed Updates to GHG Protocol’s Scope 2 Guidance, by CRS.
- Quick thoughts on the proposal for a new Scope 2 Guidance, by Steven Vanholme, EKOenergy’s Programme manager, on LinkedIn
- Help Ensure GHG Accounting Drives Higher-Ambition & More Inclusive Corporate Climate Action, by the Leapfrog Alliance
- RECS’ skeleton response text, by the RECS Energy Certificate Association.
Published: 24 November 2025
