The GHG Protocol Independent Standards Board opened a public consultation on proposed updates to Scope 2 accounting in October 2025. These revisions represent some of the most consequential changes to electricity emissions reporting since the original Scope 2 Guidance was released, and they will directly impact how organizations calculate, document, and assure purchased electricity emissions moving forward.
GHG reporters, sustainability teams, and compliance managers, please note the extensive changes under consideration. They will require greater precision, structure, and scrutiny for voluntary disclosures.
This article is a practical overview of the key proposed changes and how our team at SCS Engineers supports clients in navigating both the technical details and real-world implementation
Why These Updates Matter
Scope 2 has relied on two methods of indirect emissions disclosure:
Over time, inconsistencies in data quality, geographic boundaries, and interpretation have created challenges for comparability and assurance. The proposed revisions aim to:
Scope 2 is being repositioned from a reporting formality to a more rigorous, data-driven metric under the key changes outlined below.
Key Proposed Changes
Organizations would be required to use the most precise emission factors accessible, following a defined hierarchy:
This means many reporters may move away from national annual averages toward more localized or even hourly grid factors, where available.
A new definition of “accessible” is also introduced: emission factors must be publicly available, free to use, and from a credible source.
What this means in practice:
Reporters would be expected to match the precision of their electricity consumption data with the precision of emission factors.
If hourly grid factors are accessible, but your utility bills are annual totals, you may need to use load profiles to estimate hourly consumption — or remain at annual resolution if that’s all your activity data supports.
This introduces new methodological decisions and QA/QC considerations that sustainability teams will be paying close attention to.
The proposed revisions tighten requirements around market-based claims by emphasizing:
These changes are intended to ensure that market-based Scope 2 results better reflect physical grid realities, not just contractual ownership.
For companies relying heavily on RECs or supplier programs, this may materially change reported emissions.
While final publication isn’t expected until late 2027, the general principles should be implemented where practical. Organizations that wait until requirements become mandatory may face:
Early planning is critical.
Final Thoughts
These proposed Scope 2 updates reflect a broader shift in climate disclosure: greater rigor, tighter boundaries, and higher expectations for data quality. Organizations that proactively translate evolving standards into practical, defensible reporting programs — or verify conformance with leading GHG frameworks — will reduce compliance risk and strengthen stakeholder trust. Third‑party GHG consultants and engineers can support companies by identifying applicable standards, designing robust data‑collection systems, performing emissions calculations and quality checks, preparing transparent disclosures, and conducting independent verifications to demonstrate credibility and continuous improvement.
SCS Engineers has provided environmental consulting and GHG services for over 30 years, supporting clients from global multinational corporations to local organizations.
Contact us to learn how we can assist with measuring, managing, and disclosing GHG emissions in accordance with the latest and evolving standards.
Additional Resources:
Meet Author Stephen Holle. Mr. Holle is an environmental professional with expertise in environmental compliance auditing, landfill cell construction and closure, gas extraction system construction, due diligence, and light industrial EHS auditing. He has managed projects involving permitting, reporting, compliance tracking, regulatory agency liaison, and environmental sampling across various solid waste and industrial facilities, including landfills, landfill gas control facilities, transfer stations, and power plants. Reach him at SCS Engineers or via LinkedIn.
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