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Corporations, trade groups and other stakeholders have until Jan. 31 to comment on the Greenhouse Gas Protocol’s controversial proposed changes to the methodology for calculating emissions related to electricity.

The deadline was originally Dec. 19, but the organization extended the public consultation period to accommodate more feedback.

The revisions, which would take effect in 2027, suggest major changes to how companies will be able to claim emissions reductions related to virtual power purchase agreements and other contracts they use to match their electricity consumption with renewable electricity sources.

This is the first major refresh since the methodology was adopted in 2014.

New math

Under the proposed update, corporations will be required to match those loads on an hourly basis using renewable resources on the same grid as their original power consumption. These calculations fall under the Scope 2 category for greenhouse gas emissions. 

“This is intended to reduce double counting and ensure reported clean energy purchases more accurately reflect the physical realities of the power grid,” Greenhouse Gas (GHG) Protocol said in October, when it opened the public consultation. 

The organization may include exemptions for smaller organizations. It is also considering a clause that would exempt legacy contracts signed before the new rules take effect. It’s particularly interested in comments related to those items.

GHG Protocol is also soliciting comments about a methodology that covers “consequential” accounting methods that guide how companies can report on projects that add renewable power to electric grids that are fossil fuel-heavy but aren’t in the same location as their operations.

Some companies with active renewable energy goals invest in projects of this nature, such as Salesforce and Microsoft, mainly for their social benefits and community goodwill.

More complexity

Corporate energy buyers expect the proposed modifications to complicate the process of making Scope 2 reduction claims.

“From my perspective, everything needs to be evaluated through one specific lens, and that is, Are the rules successfully encouraging more clean energy on the grid to most effectively tackle climate change?” said Bob Redlinger, director of energy and global sustainability at Apple, during a recent webinar discussing the changes. “And from that lens, the current rules have been very successful. I think that’s the lens from which any new rules or proposed changes also need to be examined.”   

Contracts by companies with emissions reduction commitments have added (or will add when complete) close to 128 gigawatts of renewable or clean energy to the U.S. electric grid from 2014 through November 2025, according to data collected by the Clean Energy Buyers Association, which takes issue with the hourly matching proposal.

While some regions of the U.S. grid have abundant clean energy resources, many other places do not.

The new rules could have the unintended impact of making it not economical and overly complex for some companies to continue making voluntary renewable energy purchases, Redlinger said: “I worry that with the GHG Protocol’s proposal to seek hourly matching for individual organizations and with very narrow geographic boundaries, it could actually slow the progress of decarbonization.”

What’s next

After the public consultation closes, GHG Protocol will analyze the comments and produce a summary. The organization’s governance rules suggest that this analysis may be published on its website, along with specific feedback — although some companies requested a chance to comment anonymously.

After the review period, the technical working group and independent standards board responsible for the methodology will consider modifications. 

Another draft of the updated rules will be published in 2026, followed by another 60-day public consultation period. A final version of the revised methodology is due in 2027.