SLR Contributes to GHG Scope 2 Consultation

In November 2025, GHG Protocol launched a public consultation on a revision to the Scope 2 Guidance (2015) as a key component of its standards development. This consultation matters because it will define how reporting companies account for their electricity use and impact a key emissions reduction level that companies are using to meet targets.

The consultation seeks stakeholder input on proposed updates to both the location-based and market-based methods for Scope 2 emissions reporting, which will influence how companies account for and disclose Scope 2 emissions. Key proposals emphasise enhanced accuracy, transparency and alignment with evolving energy markets, including measures such as updated emission factor hierarchies and refined reporting criteria to reflect when and where electricity is consumed.

Highlights of our response include:

1. Location‑based methodology: We support clearer hierarchies, transparent and credible emission factors, practical spatial and temporal boundaries, and improvements to data quality that remain feasible across regions with varying data availability and renewable access.
2. Market‑based methodology: We advocate for stronger deliverability rules, clearer residual mix definitions, safeguards against misallocation and greenwashing, alignment with realistic grid boundaries, and an equitable, phased approach that avoids disproportionate burdens on smaller consumers or constrained regions.
3. Fostering data reliability and traceability: Our response acknowledges the intention of this revision to enhance quality of data during Scope 2 carbon accounting and provides suggestions for GHG Protocol to allow reporters to refer to data sources with high scientific reliability and avoid greenwashing.
4. Referring to actual common corporate practices: We provide suggestions based on ‘on-the-ground' experiences from climate and carbon related projects, such as companies’ common data-gathering practices when compiling market-based emission figures.

Location-based methodology:

• Support for a clear hierarchy in selecting location-based emission factors to enhance accuracy, comparability and transparency.
• Preference for consumption-based emission factors as the primary approach.
• Call for clearer rules on defining spatial and temporal boundaries.
• Expectation that all emission factors should be publicly available, credible and transparent.
• Caution against excessive granularity, as overly local boundaries may disadvantage regions with structural energy constraints or limited renewable capacity.
• Concern over data availability, noting that hourly data and load profiles are not accessible in many regions where annual reporting is standard.
• Emphasis on practicality, balancing improved data precision with feasibility, cost considerations and energy security realities.
• Support an approach that improves data quality without placing disproportionate reporting burdens on organisations.

Market-based methodology:

• Call for clearer deliverability rules to strengthen the robustness of the market-based emissions methodology.
• Support for improved residual mix definitions to enhance accuracy and transparency.
• Advocacy for safeguards that reduce misallocation and help prevent greenwashing.
• Alignment of contractual instruments with actual grid boundaries to improve scientific integrity.
• Emphasis on practicality, recognising that many organisations depend on monthly billing data and lack the infrastructure for hourly or highly granular tracking.
• Support for exemptions and phased implementation, particularly for smaller consumers.
• Importance of publicly accessible data to promote global equity and comparability.
• Concern over socioeconomic impacts, noting that overly narrow boundaries may disadvantage regions with limited renewable resources or slower investment.