What the proposed Scope 2 changes could mean for your organisation 

What the proposed Scope 2 changes could mean for your organisation 

In our previous article, we explored the broader revisions underway to the Greenhouse Gas (GHG) Protocol and why businesses should begin paying attention now. In this second piece, we take a closer look at one of the most significant areas of proposed change: Scope 2 emissions. 

Scope 2 emissions — those associated with purchased electricity — are a major component of many organisations’ carbon footprints. For many businesses, particularly in energy-intensive sectors, they also represent one of the most tangible opportunities for emissions reduction. The proposed updates signal a clear shift in how these emissions will be measured and reported, with greater emphasis on accuracy, transparency and real-world impact. 

From annual averages to hourly accuracy

One of the most notable proposed changes is the move towards hourly matching of electricity consumption and renewable energy generation under the market-based method. 

Currently, companies can match their electricity use with renewable energy on an annual basis. Under the proposed revisions, this would no longer be sufficient. Instead, organisations would need to demonstrate that their electricity consumption is matched with renewable energy on an hour-by-hour basis. 

This represents a fundamental shift. It places greater value on when electricity is generated and used — not just how much is procured over the course of a year. For example, solar generation during daylight hours may no longer fully offset electricity used in the evening unless complemented by storage or other renewable sources. 

Stronger link between procurement and physical reality

Another key theme is the requirement for renewable electricity to be physically deliverable to the grid where it is consumed. 

This means organisations may need to reassess certain contractual arrangements, particularly virtual power purchase agreements (VPPAs) or energy attribute certificates (EACs) sourced from other regions. Under the new rules, some of these instruments may no longer qualify if they are not sufficiently connected to the local grid. 

In parallel, the proposed introduction of a residual mix or fossil-only emissions factor for unmatched electricity marks a tightening of accounting rules. Companies would no longer be able to rely on grid-average emission factors, increasing the visibility of any gaps in renewable coverage. 

Together, these changes reflect a broader effort to ensure that renewable electricity claims more accurately represent real emissions reductions, rather than purely accounting-based improvements. 

More granular data, higher expectations

The proposed changes also introduce a more detailed approach to data. Companies using the location-based method may be required to use smaller geographic boundaries and shorter time intervals, while all organisations will need to rely more heavily on actual consumption data rather than estimates. 

This will increase data requirements and complexity, particularly for organisations operating across multiple sites or jurisdictions. It is likely to be especially relevant for sectors such as data centres, manufacturing and pharmaceuticals, where electricity demand is both significant and continuous. However, it also represents a step towards more robust and comparable emissions reporting. 

Introducing consequential reporting

Alongside these technical updates, the GHG Protocol is also exploring a new concept: consequential reporting. 

While existing approaches focus on “what are my emissions?”, consequential reporting asks a different question: “what difference did my actions make?” While methodologies are still evolving, this approach seeks to assess whether renewable energy procurement is contributing to emissions reductions at a system level, rather than simply improving a company’s reported footprint. 

What should organisations be thinking about now?

Although the final standards are not expected until 2027, there are practical steps organisations can begin to consider: 

  • Engage with energy suppliers to understand the availability of more granular (e.g. hourly) consumption and emissions data 
  • Review existing market-based instruments, such as PPAs and certificates, to assess potential future eligibility 
  • Explore strategies for 24/7 renewable coverage, particularly for energy-intensive operations 
  • Monitor developments closely, especially if you have SBTi targets or report under GHG Protocol-aligned frameworks 

While the proposed changes will introduce additional complexity, the direction of travel is clear: increasing scrutiny on the integrity of Scope 2 claims and a stronger focus on real-world emissions impact. Organisations that begin preparing now will be better positioned to respond as expectations continue to evolve. 

Accelerate Pact signatories  

For signatories of Accelerate: The Business Pact for Climate and Nature, the Climate Transition Plan Scorecard will incorporate changes to the GHG Protocol once they have been finalised and agreed.  

For more info, please contact environment@bitc.ie