GHG Protocol consultation period now open: Help ensure GHG accounting drives higher-ambition & more inclusive corporate climate action
The 60-day public consultation period began last week for proposed revisions to the Greenhouse Gas Protocol (GHGP), which serves as the principal framework for corporate greenhouse gas emission accounting.
A similar additional consultation period is expected to begin in a few weeks for the Science Based Targets Initiative (SBTi) to inform its respective revision. SBTi serves as the principal framework for voluntary corporate emission reduction target-setting. Because SBTi and GHGP serve as the principal frameworks, respectively, for voluntary corporate emission reduction target-setting and accounting, they effectively determine the market rules and incentives that shape the strategies companies adopt and decisions that companies make to reduce their reported emissions. These overlapping consultation periods represent an important, time-sensitive opportunity for diverse stakeholders to engage in reshaping the future of voluntary clean energy markets.
Any stakeholder can engage in the GHGP consultation process. Learn more here about how to submit feedback to the GHGP proposed revisions by the 19 December 2025 deadline
The Leapfrog Alliance—a coalition that brings together nearly 20 diverse nonprofits globally around the idea of creating stronger incentives for corporate investment in clean energy access in unelectrified and underserved communities—has been preparing for this key moment to reform the legacy imbalances in existing greenhouse gas accounting and disclosure frameworks for “Scope 2” accounting.
The Leapfrog Alliance encourages as many stakeholders as possible—including (and especially) those who haven’t yet engaged—to submit comments during the GHGP and SBTi consultation periods. This call to action builds on the prior public appeal that the Leapfrog Alliance published earlier this year and recent engagements, such as a webinar and New York Climate Week event, that emphasized the importance of broadening the number and types of stakeholders engaged during both consultation periods.
The Leapfrog Alliance invites stakeholders to submit feedback to GHGP that emphasizes the principles, objectives, and practical solutions our diverse nonprofit community developed that highlight the following five key recommendations:
Urge GHGP to remove the proposed new “hourly deliverability” requirements for Scope 2 market-based accounting: The proposed new hourly deliverability requirements under GHGP’s Scope 2 Quality Criteria 4 introduce new challenges and costs to voluntary clean energy markets without proven real-world benefits for global power sector decarbonization. Some companies may want to pursue hourly strategies. However, hourly consumption data isn’t available for most buyers and hourly procurement solutions aren’t available in most markets globally. While a volumetric and/or business category-based exemption under the Exemption to Quality Criteria 4 may reduce some risks and would be essential for its feasibility if the new hourly deliverability requirements remain, this proposed new requirement generally risks reducing voluntary market demand by increasing costs (and costs not spent on clean energy), introducing added complexity, and creating new supply and market access constraints. This new requirement may undermine incentives for clean energy investments and in turn unintentionally increase emissions from the power sector—increasing climate risks for already underserved, at-risk communities in under-electrified regions. GHGP should offer clear guidance on how to account for hourly procurement but shouldn’t require it.
Encourage GHGP to add guidance on out-of-market procurement for high impact clean energy within Scope 2: GHGP should add guidance that clarifies how companies can procure clean energy outside their traditional market boundary if—and only if—the other market has a higher relative carbon-intensity or low electrification rates. GHGP should allow (and arguably encourage) companies to procure and “count” clean energy they procure from more carbon-intensive or under-electrified regions so that companies can deliver the biggest global emissions benefit per dollar spent on clean energy. Enabling this type of higher-ambition corporate strategy would also help ensure GHGP alignment with expected new SBTi’s guidance on Indirect Mitigation for Scope 2.
Urge GHGP to deliver usable guidance on the Marginal Impact accounting method within Scope 2 alongside other incentives for promoting energy access: The carbon intensity of a given market’s power sector offers a more direct proxy for optimizing procurement for decarbonization across a market’s power sector compared to an individual company’s hourly use. However, if a company procures clean energy from a project generating electricity in a more carbon-intensive market or time, this action is currently invisible in Scope 2 accounting. Given limited corporate budgets and how emissions know no borders, companies should have the option to optimize their procurement for marginal emissions impact so they can help make the most of each dollar they spend to help decarbonize the global power sector. Grid carbon intensity and marginal emissions data are already (publicly) accessible, so companies today can easily verify the carbon-intensity associated with the location and time of the clean energy sources to produce a carbon-intensity score for each energy attribute certificate (EAC) they procured. If companies drive greater decarbonization globally through procurement, this helps reduce power sector emissions and as a result reduces climate risks for everyone, including under-electrified communities that have the greatest climate risk exposure. GHGP should accelerate and (re)integrate their guidance on the Marginal Impact method so that companies know how to report clean energy that is optimized for decarbonization impact and should ensure the final version better reflects expert feedback on how to make this method usable for application in clean energy markets. The addition of the Marginal Impact method to Scope 2 accounting should also build on other existing models that can generate funds for new renewable capacity in under-electrified regions. This will help ensure it aligns with the existing recommendations found in GHGP’s Chapter 11, which offers guidance about ways for companies to go beyond the basics of renewable energy procurement and support positive impact.
Show support for GHGP’s introduction of African power pools as single markets and encourage SBTi to follow suit: The first-time guidance on market boundaries for African continent and acknowledgement of each of the five African power pools as single markets for voluntary clean energy procurement will help address legacy confusion about market boundaries on the continent. This guidance will introduce new and important flexibility across a given power pool region for corporate procurement. Currently, if a company lacks sufficient clean energy options in an African country where their Scope 2 emissions originate, they typically leave this budget unspent since buying from a neighboring African country wouldn’t count in their Scope 2 market-based emissions reporting. The proposed revision would introduce regional flexibility and enable companies to buy clean energy from any country within the same power pool region. Stakeholders should consider encouraging SBTi to adopt similar recognition of African power pools as single markets for voluntary procurement once SBTi’s consultation period begins.
Show support for definition of “accessible” data: The GHGP has introduced a new definition around “accessible” data and defines it as publicly available, free to use, and from a credible source. This definition supports inclusivity and should apply for any requirements.
The Leapfrog Alliance will share SBTi-specific recommendations once the SBTi consultation period begins so that stakeholders can similarly help ensure that SBTi offers guidance and incentives for corporate procurement supporting investments in energy access in under-electrified communities.
Please visit www.leapfrogalliance.org to learn more. If you represent a nonprofit, please consider becoming a supporter of the Leapfrog Alliance and submit an application using this short form.
For any questions about the GHGP consultation process and how to engage, then please contact the Leapfrog Alliance convener, Energy Peace Partners (EPP), via email at leapfrogalliance@energypeacepartners.com.