GHG Protocol Scope 2 revision in consultation: hourly matching proposed

What happened

On 20 October 2025 GHG Protocol launched a public consultation on revising its 2015 Scope 2 Guidance. The consultation was originally due to close on 19 December 2025; at stakeholders' request it was extended to 31 January 2026. On the same day a separate consultation opened on consequential accounting methods for the electricity sector.

Main elements of the proposal:

• Dual reporting continues: Reporting under both the location-based and market-based methods is kept.
• Hourly matching: In the market-based method, instead of matching contractual instruments (renewable energy certificates, PPAs) with consumption "as closely as possible", an hourly matching requirement is proposed for large organisations. Organisations below the threshold can continue with annual matching.
• Deliverability: The clean energy source must be reasonably deliverable to where the organisation consumes electricity.
• Residual mix: The definition of the residual mix factor for unclaimed electricity is updated; where no residual mix exists, a fossil-based factor is proposed.
• Location-based method: A hierarchy that prioritises more precise emission factors by location, time interval and data type, with a requirement to use the most precise factor available.
• Feasibility: Standard load profiles where hourly data is unavailable, a legacy (grandfathering) clause for existing contracts and a multi-year phased transition.

Under GHG Protocol's initial timeline, a second consultation was expected in 2026 and the final standard in 2027. The consultation results were published in July 2026 and the timeline was updated (our news on the feedback).

Who is affected

Turkish companies that reduce market-based Scope 2 emissions with YEK-G certificates (Türkiye's renewable energy guarantees of origin), international renewable energy certificates or green tariffs. If the proposal is adopted as it stands, certificate purchases based on annual volume matching may not be enough for large organisations. Companies with SBTi targets, companies reporting Scope 2 under CDP or TSRS (the Turkish Sustainability Reporting Standards), and exporters making low-carbon electricity claims to EU customers are particularly affected.

What companies should do

• Check your access to hourly data on your electricity consumption (meter and distribution company data).
• Document the dates and scope of your existing PPA and certificate contracts; the legacy clause will rely on these documents.
• Clarify the source and year of the grid factor you use in your location-based calculation.

Alalëa supports Scope 2 calculations and reviews of renewable energy claims: carbon footprint.