The GHG Protocol's July 2026 update did not change the rules for reporting purchased electricity. Companies should continue to apply the 2015 Scope 2 Guidance while the revision proceeds. The useful response is preparation, not premature compliance: retain better load and certificate data, test hourly and geographic matching, separate inventory results from claims about wider grid impact, and avoid assuming that a future legacy clause will protect contracts signed today.
For energy attribute certificate (EAC) buyers, the question is no longer whether Scope 2 accounting may become more granular. It is which procurement decisions are sensible before the final design is known.
What changed on 29 July 2026
The Greenhouse Gas Protocol published three connected developments:
- Results from its consultation on proposed revisions to Scope 2 accounting.
- Preliminary feedback on a proposed multi-statement approach for actions and market instruments.
- A new plan to consolidate the Corporate Standard, Scope 2 Guidance, Scope 3 Standard and Actions and Market Instruments work with ISO 14064-1.
The consultation received nearly 1,100 responses from 56 countries. Companies, industry groups and consultants made up 62% of respondents, which matters when interpreting the results: this was a large international consultation, but it was not a balanced survey of all electricity-market participants. GHG Protocol's executive summary reports lower representation from NGOs and academia, energy suppliers, retailers and utilities.
The timetable is now longer than earlier plans suggested. A consolidated draft is estimated for public consultation in Q2 2027, and the revised joint standard is estimated for publication in Q4 2028. GHG Protocol says the schedule may change, including if pilot testing is added. The consolidated Standard Development Plan also says the Scope 2 technical group will work through consultation and ISO feedback in Q3 and Q4 2026.
That creates a long transition window. It does not create permission to describe a proposal as an adopted requirement.
Five Scope 2 issues to put on the procurement register
| Issue | Status on 11 August 2026 | Possible effect on EAC procurement | Proportionate action now |
|---|---|---|---|
| Hourly matching | Proposed, with low support for the design as consulted | Annual certificates may not cover every consumption hour under a more granular method | Retain interval load data where available and ask suppliers whether generation timestamps can be delivered |
| Deliverability | Proposed, with divided views on suitable geographic boundaries | Certificates sourced from a broad national or multi-country market may face narrower tests | Record generation location, grid area, interconnection evidence and the load location behind each claim |
| Residual mix and default factors | Proposed updates received more support, with implementation concerns | Unmatched consumption could carry a different or higher factor where a compliant residual mix is unavailable | Inventory the factor source, boundary, publication date and fallback used for every operating market |
| Legacy treatment | Proposed, not guaranteed | Existing PPAs and EAC contracts may or may not retain eligibility under future rules | Do not price or approve a contract on an assumed grandfathering outcome; preserve data and amendment rights |
| Multi-statement reporting | Under development, not yet a final standard | Inventory emissions, contractual results and wider emissions impact may be reported separately | Build separate records now; do not net avoided-emissions estimates against the Scope 2 inventory |
This table is a readiness map, not a prediction of the final standard. The consultation feedback showed low support for hourly matching and deliverability as proposed, while respondents were more supportive of changes concerning residual mix, standard supply service and fossil-based fallback factors. GHG Protocol's consultation findings say feasibility concerns included cost, audit burden, registry and utility data, and the pace of transition.
Do not rewrite the 2026 inventory around a consultation draft
The current GHG Protocol Scope 2 Guidance remains the operative reference. It covers purchased or acquired electricity, steam, heat and cooling, and sets eight quality criteria for contractual instruments used in the market-based method. Sentinel Earth's existing guide explains how Scope 1, 2 and 3 inventories work.
The 2015 framework requires dual reporting with location-based and, where applicable, market-based results. The location-based method reflects average emissions for the grid where consumption occurs. The market-based method uses qualifying contractual information associated with procurement choices.
The consultation proposal retained that dual structure but considered stricter temporal and geographic requirements. It would have required hourly matching for large organisations and plausible deliverability between generation and consumption, subject to exemptions and transition provisions. Respondents did not endorse that package uniformly. GHG Protocol is now considering whether multiple reporting approaches could better represent different theories of change, according to its 29 July FAQ.
Three conclusions follow:
- Current inventories should not be restated merely because a proposal was published.
- New procurement should not ignore the issues the proposal exposed.
- Public claims should state which method, boundary, period and instrument they describe.
Build an evidence schedule before adding contract clauses
The most useful preparation is an evidence schedule that follows each megawatt-hour from load to cancellation. It should be capable of supporting current annual accounting and a more granular future test without promising that either outcome is guaranteed.
For each operating site or reporting unit, retain:
- metered consumption, including hourly or sub-hourly data where reasonably available;
- the reporting period and organisational boundary;
- certificate type, registry, serial numbers, technology, facility and commissioning information;
- generation period, ideally with timestamps that can be reconciled to load;
- generator location and the market or grid boundary used;
- supplier and utility product terms, including standard supply allocations;
- certificate ownership, transfer and cancellation evidence;
- the emission factor and residual-mix source used for unmatched consumption;
- calculation versions, approvals and assurance evidence.
Data rights belong in procurement discussions. A low-cost certificate that arrives without the fields needed for reconciliation can become expensive when teams have to rebuild an audit trail. Buyers should ask whether suppliers can export records in a stable, machine-readable form and whether those records remain accessible after the contract ends.
Match contract design to the procurement horizon
Not every purchase needs the same level of protection.
| Procurement horizon | Main exposure | Buyer control to consider |
|---|---|---|
| Annual or spot EAC purchase | Limited ability to correct missing fields after delivery | Specify the required registry, generation period, facility location, cancellation deadline and evidence pack before execution |
| Multi-year EAC supply | Eligibility criteria or market boundaries may change during the term | Add data-delivery obligations, substitution rules, change-control steps and a defined process for replacing non-conforming instruments |
| PPA or virtual PPA | Long tenor, accounting treatment and physical deliverability may diverge | Preserve meter and generation data, define environmental-attribute ownership, plan separate inventory and impact reporting, and obtain legal and accounting review of change provisions |
These are issues for contract review, not model clauses. Their operation depends on jurisdiction, market design, accounting policy and the specific product. A buyer should not accept a supplier's general assurance that an instrument is "Scope 2 compliant" without identifying the edition, quality criteria, reporting programme and period to which that statement refers.
Treat hourly matching as a data test before treating it as a sourcing mandate
The consultation results show why a staged approach is sensible. Among respondents who opposed the proposed hourly requirement and gave reasons, 87% selected concern about discouraging participation in voluntary clean-energy procurement, while 86% selected administrative, data-management and audit burden. These percentages describe a subset of respondents to those questions, not the full sample. The full consultation summary, pages 51-52 provides the denominator context.
A buyer can learn a great deal without committing to 100% hourly procurement:
- Select the sites with the largest electricity load or best interval data.
- Map one year's consumption against the timestamps available for existing certificates or contracted generation.
- Identify uncovered hours, boundary mismatches and missing residual-mix data.
- Price the data, certificate and operational changes needed to close those gaps.
- Keep the test result separate from the reported inventory unless it meets the current reporting policy and assurance controls.
This pilot answers a practical question: where is the organisation exposed if the final standard becomes more granular? It does not imply that hourly matching will be mandatory in the form consulted.
Keep inventory accounting and impact claims separate
GHG Protocol's emerging Actions and Market Instruments work points towards separate statements for physical inventory emissions, market-based or contractual emissions, and the emissions impact of corporate actions. Its latest FAQ says organisations experimenting with that approach should keep the categories separate and avoid netting between them while detailed requirements are developed.
That distinction is especially relevant to virtual PPAs and procurement located outside the grid serving the buyer's load. A transaction may help finance renewable generation yet fail a future deliverability test for the Scope 2 inventory. The two propositions should be assessed independently:
- What emissions are allocated to the reporting organisation's electricity consumption?
- What wider change, if any, did the procurement action cause compared with a credible counterfactual?
The second question needs its own method and evidence. It should not be used to reduce the first result unless the applicable inventory rules allow it. The same separation supports clearer corporate carbon-claim controls.
A decision rule for purchases made before Q2 2027
Procurement teams do not need to pause credible renewable-electricity buying until the next consultation. They do need a decision record.
Proceed when the purchase meets current rules, has a clear use case, preserves the data needed for assurance and can be adapted at reasonable cost. Escalate when a long-term contract depends on assumed grandfathering, uses a broad geographic boundary that cannot be explained, provides no timestamp or facility-level data, or combines an inventory claim with an avoided-emissions claim.
The next formal checkpoint is the estimated Q2 2027 consultation on the consolidated corporate standard. Before then, buyers can make their systems more informative without pretending to know the final answer.
Organisations reviewing EAC or Guarantee of Origin procurement can discuss consumption geography, reporting period, instrument, registry, technology, vintage and cancellation evidence through Sentinel Earth's environmental asset sourcing team. Any contract, disclosure or claims conclusion should also receive appropriate legal and technical review.
Sources
- GHG Protocol, Scope 2 Guidance, accessed 11 August 2026.
- GHG Protocol, Scope 2 Public Consultation Feedback Summary: Executive Summary, 29 July 2026.
- GHG Protocol, Scope 2 Public Consultation Summary of Feedback, 29 July 2026.
- GHG Protocol, Key Standard Development Updates: FAQ, 29 July 2026.
- GHG Protocol, Consolidated Corporate Standard Development Plan, version 2.0, 29 July 2026.
