GHG Protocol AMI feedback supports separate reporting statements, not immediate rule changes
GHG Protocol’s AMI feedback summary shows strong respondent support for separate reporting statements, alongside concerns about inventory integrity, double counting and evidence quality.
Source published: 2026-09-23
Audience / jurisdiction: International; sustainability reporting teams and advisers monitoring GHG Protocol developments. No jurisdiction-specific legal obligation established.
A development update, not a new reporting obligation
GHG Protocol has published a summary of feedback on its proposed Actions and Market Instruments (AMI) reporting approach. Its standards-development repository lists the summary under September 23, 2026. The release provides a useful signal for sustainability teams following corporate greenhouse-gas accounting developments, but it is consultation evidence rather than a final reporting standard.
The summary records 437 valid responses, with 84% supporting or strongly supporting the proposed multi-statement structure. That level of support indicates interest among respondents in separating different kinds of reporting information. It does not establish that the proposal’s technical details have been settled or that organisations must begin using additional statements.
Why separate statements matter
The central issue is how to present information about actions and market instruments without obscuring the physical greenhouse-gas inventory. The feedback summary considers a multi-statement approach that separates accounting concepts rather than treating every reported measure as interchangeable.
For practitioners, the important distinction is between inventory information and other evidence about instruments, interventions or indicators. These can answer different questions. A reporting package may seek to explain both an organisation’s emissions and the effects of its actions, but combining those explanations without clear boundaries can make the resulting claims difficult to interpret.
The proposal should therefore be understood as a developing reporting architecture, not permission to subtract any claimed benefit from an inventory total. The feedback places particular emphasis on preserving inventory integrity and avoiding inappropriate netting.
Sources: [2]
Support comes with safeguards and caveats
Respondents highlighted safeguards including prevention of double counting, clear reporting boundaries and quality criteria. These concerns matter because a structure can attract broad support while still leaving important questions about acceptable evidence and presentation unresolved.
Many respondents also recommended that additional statements initially remain optional. That is a stakeholder recommendation recorded in the summary, not an adopted rule. Teams should avoid turning it into either a promised exemption or an expectation that optional reporting will necessarily be the final approach.
The consultation’s composition also limits how broadly its results should be interpreted: 91% of respondents were from the Global North. The reported support is a result from this respondent group, not proof of universal agreement across regions or reporting contexts.
Sources: [2]
A practical response: organise evidence without changing requirements
A proportionate preparation step is to map existing evidence into distinct categories: physical inventory data, contractual or market instruments, evidence of intervention impacts, and other indicators. This is an editorial suggestion informed by the summary’s emphasis on separate accounting logic; it is not a requirement to implement proposed statements.
For example, a sustainability team could keep the evidence for an emissions figure separate from the evidence supporting a claimed intervention benefit. An internal review could then ask what each figure represents, which boundary it uses and whether the same benefit appears elsewhere in the reporting package.
This exercise can help identify ambiguous claims before a reporting redesign is considered. It need not involve adopting new calculations or changing an existing disclosure solely because consultation respondents favoured the proposal. The immediate objective is clearer evidence organisation, not early implementation of an unfinished framework.
Sources: [2]
What this means for reporting teams now
This update is relevant to organisations and advisers following GHG Protocol developments internationally. The reviewed sources do not establish a jurisdiction-specific legal obligation, an effective date for the proposed structure or a certification transition deadline. The feedback summary is not a published ISO standard.
For now, management-system practitioners can monitor the development repository and use the summary to frame internal questions about boundaries, evidence quality and double counting. Publication of consultation findings is a reason to pay attention, not a reason to announce that current reporting requirements have changed.
Sources
- Standards Development and Governance Repository — AMI summary entry
- Actions and Market Instruments—Phase 1 Progress Update White Paper: Request for Information, Summary of Responses
Your experience
Can your reporting team clearly distinguish inventory figures from market-instrument claims and intervention-impact evidence?
Originally published by AdviseISO, a knowledge-sharing initiative of W3 Solutionz.