GHG Protocol Updates 2026: What Changes in Scope 2 & Scope 3 Accounting (and Why It Matters)

Direction of travel: boundary clarity + systematic measurement discipline

The GHG Protocol Scope 3 Calculation Guidance frames the 15 categories as a systematic measurement framework for companies. Source In a compliance program, “systematic” typically means documented boundaries, consistent categorization decisions, controlled data sources, and repeatable calculation logic suitable for audit evidence. Source

What you can say with confidence vs what must stay labeled as “direction of travel”

You can state with confidence that Scope 3 is organized into 15 categories under the GHGP Scope 3 Standard (2011), because that structure is explicitly referenced as the canonical backbone in the IFRS S2 applying note. Source You can state with confidence that the categories are intended as a systematic framework, because the GHGP Scope 3 Calculation Guidance states that intent. Source You should label as “direction of travel” any expectations about tighter boundaries, higher supplier primary data usage, or standardized disclosure templates unless those expectations are explicitly stated in the provided sources. Source

How to Interpret "Systematic Framework" into Controls

If your Scope 3 approach is intended to be systematic, a practical implication is that you need a documented mapping of business processes to categories (e.g., procurement spend → Category 1) and the ability to reproduce that mapping consistently over time. Source If your Scope 3 approach is intended to be systematic, a practical implication is that you need traceability from reported totals back to the underlying activity datasets and factor assumptions used for each category. Source

Why Organizations Should Avoid Claiming Automatic Alignment with IFRS/ESRS

KPMG’s interpretive note cautions that any changes to the GHG Protocol will not be automatically incorporated into IFRS Sustainability Disclosure Standards or ESRS and that references would need to be revised. Source This means companies should treat “alignment” as a managed mapping exercise across frameworks rather than assuming automatic regulatory flow-through. Source

6) Compliance impact: what breaks in existing corporate workflows

Data architecture: what becomes harder if hourly matching/deliverability is adopted (proposed)

The GHG Protocol proposal described in the consultation announcement includes hourly matching and deliverability requirements for market-based reporting. Source If adopted, this would increase expectations for time-resolved electricity consumption and certificate attribute management (for example, aligning certificate attributes and consumption periods). Source The same announcement references practicality measures such as load profiles and exemption thresholds, which implies that implementation may differ by organizational size, data availability, or materiality thresholds as proposed. Source

What changes operationally for energy procurement teams (proposed)

If hourly matching is introduced for market-based reporting as described, energy procurement workflows may need tighter linkage between contract attributes and the time profile of consumption that the instruments are intended to cover. Source If deliverability is introduced for market-based reporting as described, procurement may need additional checks about whether instruments are considered deliverable to the consumption location under the proposal framing. Source The proposal’s inclusion of legacy clause and phased implementation suggests there may be a transition pathway for existing contracts if finalized. Source

What changes operationally for procurement and supply chain (Scope 3) owners (baseline)

The Scope 3 framework is explicitly structured into 15 categories, which implies procurement and supply chain teams often sit on key datasets for multiple categories such as purchased goods and services and upstream transportation. Source Because the Scope 3 Calculation Guidance frames the 15 categories as systematic, procurement workflows that rely on supplier data are more likely to be scrutinized for data completeness and reproducibility in assurance contexts. Source

Governance: who owns Scope 2 vs Scope 3 vs procurement vs finance vs assurance

Scope 2 dual reporting requirements depend on whether contractual instruments and supplier-specific data exist in the relevant markets. Source Scope 3 is structured into 15 categories intended as a systematic framework, which implies distributed ownership across procurement, finance, operations, HR, and product teams depending on category. Source

7) Implementation Playbook

Readiness checklist (systems, contracts, supplier engagement, assurance)

• Map where dual reporting is required today: identify markets where contractual instruments or supplier-specific product data exist and confirm dual reporting is applied. Source
• Inventory contractual instruments and attributes: document how market-based attributes are sourced, stored, and linked to consumption. Source
• Scope 3 category ownership map: assign the 15 categories to data owners and ensure category decisions are consistently applied. Source
• Consultation tracking: monitor the second consultation in 2026 and expected publication in 2027 as stated. Source

Controls-and-evidence checklist (what auditors will ask for)

• Evidence of dual reporting logic: documented location-based and market-based calculation approaches as defined in Scope 2 Guidance. Source
• Instrument traceability: linking contractual instruments to reporting boundaries (organizational boundary and consumption location) for market-based claims. Source
• Category boundary traceability: evidence that each Scope 3 emission source is assigned to a category in the 15-category framework. Source
• Cross-framework mapping controls: explicit evidence that GHGP changes are not treated as automatically incorporated into IFRS/ESRS references. Source

Minimum Viable Compliance vs Gold Standard

Minimum viable compliance focuses on meeting current dual reporting requirements and maintaining category completeness in the 15-category Scope 3 structure. Source A “gold standard” typically means improving internal evidence, traceability, and automation so proposed integrity requirements can be adopted with fewer manual workarounds if finalized. Source

12-week plan (readiness sprint) — what you can do without assuming final rules

• Week 1–2: Confirm where dual reporting is required by identifying markets with contractual instruments as described by the Scope 2 Guidance and verifying both location-based and market-based outputs exist. Source
• Week 2–4: Create an evidence inventory for market-based claims showing contractual instruments and how they were applied, consistent with “market-based reflects contractual instrument-based attributes.” Source
• Week 3–6: Create a Scope 3 category ownership and data map across the 15 categories, consistent with the systematic framework intent. Source
• Week 6–12: Perform a gap assessment against proposed hourly matching/deliverability concepts by checking whether electricity and instrument data can be joined at finer time granularity, while labeling results as readiness only (not a claim of compliance with finalized rules). Source

12-month plan (controls build) — how to reduce assurance friction

The proposal describes a phased implementation timeline, which makes a 12-month controls build a reasonable governance concept for many organizations even before final publication, as long as it is described as preparation for a proposed direction. Source The Scope 3 guidance describes a systematic framework, which supports investing in repeatable data pipelines and documented category logic to reduce year-over-year rework. Source

8) Devil’s Advocate

9) Outlook 2026–2030

The GHG Protocol announcement states that a second public consultation will follow in 2026 and final publication is expected in 2027. Source For organizations reporting under multiple regimes, any “alignment” claims should be controlled because changes will not be automatically incorporated into IFRS Sustainability Disclosure Standards or ESRS without revised references. Source Scope 3’s 15-category structure is expected to remain the stable backbone for categorization and disclosure mapping because it is referenced as the canonical structure derived from the GHGP Scope 3 Standard. Source

Data Visualizations

Frequently Asked Questions