GHG Protocol outlines possible Scope 2 transition; requirements and dates remain open
GHG Protocol has outlined two proposed Scope 2 market-based methods and a possible transition, but requirements, implementation timing and technical details remain unresolved.
Source published: 2026-10-16
Audience / jurisdiction: International; relevant to organizations and practitioners following GHG Protocol electricity accounting, with no country-specific legal obligation established by this update.
A proposed direction, not a finalized accounting change
GHG Protocol has outlined a possible transition in market-based Scope 2 accounting, while leaving central decisions about requirements and timing unresolved. Its October 16, 2026 update describes two proposed methods for electricity accounting and a potential route from the existing approach towards a method incorporating hourly matching, deliverability and incrementality.
For sustainability managers and greenhouse gas reporting teams, the immediate significance is the direction of standards development—not a new compliance deadline. The update follows September Independent Standards Board discussions and identifies matters needing further refinement. It does not establish that hourly matching is now mandatory or that existing electricity certificates have become invalid.
Sources: [1]
What the two proposed methods would mean
Under the proposal, Method 1 would incorporate hourly matching, deliverability and incrementality. Method 2 would retain the existing 2015 Scope 2 approach. These are proposed approaches within an unfinished development process, rather than two newly finalized reporting options.
The possible transition would allow Method 2 to remain available until a date that has not yet been decided, followed by Method 1 where qualifying data is available. That qualification matters: the proposal links the future approach to data availability, while feasibility and technical details remain under discussion.
Reporting teams should therefore avoid treating the update as a settled specification for electricity procurement or accounting systems. The source does not resolve every condition that would determine how the proposed methods operate in practice.
Sources: [1]
Requirements, timing and legal applicability remain distinct
Several decisions remain open, including whether particular provisions would be mandatory or optional, when implementation would occur and how technical and feasibility questions would be addressed. No transition deadline is established by this update.
The distinction is important when briefing management. A proposal can justify monitoring and exploratory work without supporting a claim that an organization must immediately replace its accounting approach. Any internal summary should separate the proposed direction from unresolved decisions, rather than presenting a single future compliance date.
This is international accounting-framework development by GHG Protocol, not a country-specific legal measure. The supplied evidence does not establish a legal obligation for all businesses, or identify a jurisdiction in which the proposed changes have taken effect.
Sources: [1]
A proportionate preparation step: map evidence gaps
As a preparatory exercise—not a new reporting requirement—teams could inventory the electricity information they already hold. A useful starting point would be to record the time granularity of consumption data, the evidence available for electricity purchases and certificates, and the gaps that would need clarification before assessing a different accounting approach.
For example, a team could distinguish information held centrally from information that would require a supplier request. It could also record which questions relate to its own data systems and which depend on future technical decisions. This would make later assessments more focused without assuming that the proposal is final.
Keep that exploratory work separate from decisions to change accounting policies or make procurement commitments. The purpose at this stage is to understand exposure to possible changes and prepare informed questions, not to claim conformity with an unfinished method.
Sources: [1]
Watch the next milestones without treating them as deadlines
The development timetable anticipates a consolidated consultation in the second quarter of 2027 and publication of the joint GHG Protocol–ISO Corporate Standard in the fourth quarter of 2028. Both are planned milestones, not effective dates for the proposed Scope 2 changes.
For management-system practitioners, the next useful checkpoint is further clarification of the methods, their applicability and any eventual transition arrangements. An internal monitoring record could track those questions alongside the planned consultation. Until decisions are finalized, management briefings should preserve the central distinction: a possible future accounting direction has been outlined, but its requirements and implementation dates remain undecided.
Sources: [1]
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Your experience
Which gaps in your electricity-consumption and procurement evidence would you need to understand before assessing the proposed methods?
Originally published by AdviseISO, a knowledge-sharing initiative of W3 Solutionz.
