Electricity Maps' Response to the GHG Protocol Scope 2 Public Consultation
A brief summary of Electricity Maps' response to the GHG Protocol's Scope 2 public consultation
Jan 27, 2026
The Greenhouse Gas (GHG) Protocol public consultation on proposed updates to Scope 2 guidance closes on January 31, 2026. Electricity Maps has closely followed this phase of the revision process through the Scope 2 Technical Working Group and Independent Standards Board, and we’re happy to share the highlights of our response here.
Our purpose in participating in the public consultation is to advocate for more granular measurement of the carbon emissions of electricity to drive real-world decarbonization.
By prioritizing physical grid reality, both in time (hourly) and space (local market boundaries), the GHG Protocol can transform Scope 2 reporting into a powerful tool for active climate action.
Electricity Maps provides the hourly (and sub-hourly), granular data from around the world necessary to make this high-integrity future feasible today.
We encourage interested organizations to submit their own responses by the January 31 deadline.
Three Core Principles
Attributional Integrity: We fully support refining the Scope 2 definition to include only emissions from generation processes physically connected to the reporter’s value chain.
Physical Reality: We advocate for location-based methods that reflect electricity physically delivered at the specific times and locations of consumption, and market-based methods with strong deliverability requirements.
Grid Decarbonization Goal: Accuracy alone is not the goal of carbon accounting; the standard must incentivize procurement that aligns with system needs and drives real-world grid decarbonization.
An Improved Location-Based Method (LBM) Hierarchy
Granularity as Standard: We fully support the update to the LBM emission factor hierarchy prioritizing hourly, consumption-based data at a local boundary.
Data Accessibility: Our global operations demonstrate that high-granularity, consumption-based data already exists and is accessible for the majority of the global grid.
Independent Methodologies: We argue that independent providers must be recognized as credible sources, as they are often the only source of the most precise, decision-useful data in many regions.
Aligning the Market-Based Method (MBM) with Reality
Hourly Matching: We strongly support Quality Criteria 4, requiring all contractual instruments to be issued and redeemed for the same hour as consumption.
Deliverability: We support Quality Criteria 5, requiring instruments to be sourced from the same deliverable market boundary as the demand. We advocate for deliverable market boundaries that align with the physical reality of the grid to ensure contractual claims are physically plausible and reflect actual transmission constraints. We support using broader regional power pools where physical interconnection and operational governance demonstrate a unified market, such as 45V in the United States.
Additionality: We recommend including additionality criteria in the Market-Based Method requirements to incentivize the addition of new clean power to the grid.
Avoiding Double-Counting with Standard Supply Service (SSS) & Residual Mix
Pro-Rata Allocation: We support the requirement that reporting entities shall not claim more than their pro-rata share of SSS to maintain the integrity of the Residual Mix.
Vintage Requirement: In the absence of centralized registries, we support designating certain resources as SSS based on asset age to ensure higher integrity than allowing open claims on all clean generation.
Fossil Fallback: We support the requirement to use a fossil-based emission factor as a conservative default when no residual mix or contractual instrument is available.
Feasibility & Transition Measures
Load Profiles: We support the use of load profiles as a vital feasibility measure for reporters without hourly meters, prioritizing the most granular profile accessible.
Time-Limited Exemptions: We support exemptions for small and medium enterprises (SMEs) to manage the transition burden, provided they are time-limited and require Mandatory Dual Disclosure of hourly LBM results.
Legacy Clause: We support a legacy clause for long-term contracts (5+ years) signed prior to the standard's publication to protect early adopters and market stability.
Ready to access granular data to power your Scope 2 carbon accounting today? Get started now.
The Greenhouse Gas (GHG) Protocol public consultation on proposed updates to Scope 2 guidance closes on January 31, 2026. Electricity Maps has closely followed this phase of the revision process through the Scope 2 Technical Working Group and Independent Standards Board, and we’re happy to share the highlights of our response here.
Our purpose in participating in the public consultation is to advocate for more granular measurement of the carbon emissions of electricity to drive real-world decarbonization.
By prioritizing physical grid reality, both in time (hourly) and space (local market boundaries), the GHG Protocol can transform Scope 2 reporting into a powerful tool for active climate action.
Electricity Maps provides the hourly (and sub-hourly), granular data from around the world necessary to make this high-integrity future feasible today.
We encourage interested organizations to submit their own responses by the January 31 deadline.
Three Core Principles
Attributional Integrity: We fully support refining the Scope 2 definition to include only emissions from generation processes physically connected to the reporter’s value chain.
Physical Reality: We advocate for location-based methods that reflect electricity physically delivered at the specific times and locations of consumption, and market-based methods with strong deliverability requirements.
Grid Decarbonization Goal: Accuracy alone is not the goal of carbon accounting; the standard must incentivize procurement that aligns with system needs and drives real-world grid decarbonization.
An Improved Location-Based Method (LBM) Hierarchy
Granularity as Standard: We fully support the update to the LBM emission factor hierarchy prioritizing hourly, consumption-based data at a local boundary.
Data Accessibility: Our global operations demonstrate that high-granularity, consumption-based data already exists and is accessible for the majority of the global grid.
Independent Methodologies: We argue that independent providers must be recognized as credible sources, as they are often the only source of the most precise, decision-useful data in many regions.
Aligning the Market-Based Method (MBM) with Reality
Hourly Matching: We strongly support Quality Criteria 4, requiring all contractual instruments to be issued and redeemed for the same hour as consumption.
Deliverability: We support Quality Criteria 5, requiring instruments to be sourced from the same deliverable market boundary as the demand. We advocate for deliverable market boundaries that align with the physical reality of the grid to ensure contractual claims are physically plausible and reflect actual transmission constraints. We support using broader regional power pools where physical interconnection and operational governance demonstrate a unified market, such as 45V in the United States.
Additionality: We recommend including additionality criteria in the Market-Based Method requirements to incentivize the addition of new clean power to the grid.
Avoiding Double-Counting with Standard Supply Service (SSS) & Residual Mix
Pro-Rata Allocation: We support the requirement that reporting entities shall not claim more than their pro-rata share of SSS to maintain the integrity of the Residual Mix.
Vintage Requirement: In the absence of centralized registries, we support designating certain resources as SSS based on asset age to ensure higher integrity than allowing open claims on all clean generation.
Fossil Fallback: We support the requirement to use a fossil-based emission factor as a conservative default when no residual mix or contractual instrument is available.
Feasibility & Transition Measures
Load Profiles: We support the use of load profiles as a vital feasibility measure for reporters without hourly meters, prioritizing the most granular profile accessible.
Time-Limited Exemptions: We support exemptions for small and medium enterprises (SMEs) to manage the transition burden, provided they are time-limited and require Mandatory Dual Disclosure of hourly LBM results.
Legacy Clause: We support a legacy clause for long-term contracts (5+ years) signed prior to the standard's publication to protect early adopters and market stability.
Ready to access granular data to power your Scope 2 carbon accounting today? Get started now.
The Greenhouse Gas (GHG) Protocol public consultation on proposed updates to Scope 2 guidance closes on January 31, 2026. Electricity Maps has closely followed this phase of the revision process through the Scope 2 Technical Working Group and Independent Standards Board, and we’re happy to share the highlights of our response here.
Our purpose in participating in the public consultation is to advocate for more granular measurement of the carbon emissions of electricity to drive real-world decarbonization.
By prioritizing physical grid reality, both in time (hourly) and space (local market boundaries), the GHG Protocol can transform Scope 2 reporting into a powerful tool for active climate action.
Electricity Maps provides the hourly (and sub-hourly), granular data from around the world necessary to make this high-integrity future feasible today.
We encourage interested organizations to submit their own responses by the January 31 deadline.
Three Core Principles
Attributional Integrity: We fully support refining the Scope 2 definition to include only emissions from generation processes physically connected to the reporter’s value chain.
Physical Reality: We advocate for location-based methods that reflect electricity physically delivered at the specific times and locations of consumption, and market-based methods with strong deliverability requirements.
Grid Decarbonization Goal: Accuracy alone is not the goal of carbon accounting; the standard must incentivize procurement that aligns with system needs and drives real-world grid decarbonization.
An Improved Location-Based Method (LBM) Hierarchy
Granularity as Standard: We fully support the update to the LBM emission factor hierarchy prioritizing hourly, consumption-based data at a local boundary.
Data Accessibility: Our global operations demonstrate that high-granularity, consumption-based data already exists and is accessible for the majority of the global grid.
Independent Methodologies: We argue that independent providers must be recognized as credible sources, as they are often the only source of the most precise, decision-useful data in many regions.
Aligning the Market-Based Method (MBM) with Reality
Hourly Matching: We strongly support Quality Criteria 4, requiring all contractual instruments to be issued and redeemed for the same hour as consumption.
Deliverability: We support Quality Criteria 5, requiring instruments to be sourced from the same deliverable market boundary as the demand. We advocate for deliverable market boundaries that align with the physical reality of the grid to ensure contractual claims are physically plausible and reflect actual transmission constraints. We support using broader regional power pools where physical interconnection and operational governance demonstrate a unified market, such as 45V in the United States.
Additionality: We recommend including additionality criteria in the Market-Based Method requirements to incentivize the addition of new clean power to the grid.
Avoiding Double-Counting with Standard Supply Service (SSS) & Residual Mix
Pro-Rata Allocation: We support the requirement that reporting entities shall not claim more than their pro-rata share of SSS to maintain the integrity of the Residual Mix.
Vintage Requirement: In the absence of centralized registries, we support designating certain resources as SSS based on asset age to ensure higher integrity than allowing open claims on all clean generation.
Fossil Fallback: We support the requirement to use a fossil-based emission factor as a conservative default when no residual mix or contractual instrument is available.
Feasibility & Transition Measures
Load Profiles: We support the use of load profiles as a vital feasibility measure for reporters without hourly meters, prioritizing the most granular profile accessible.
Time-Limited Exemptions: We support exemptions for small and medium enterprises (SMEs) to manage the transition burden, provided they are time-limited and require Mandatory Dual Disclosure of hourly LBM results.
Legacy Clause: We support a legacy clause for long-term contracts (5+ years) signed prior to the standard's publication to protect early adopters and market stability.
Ready to access granular data to power your Scope 2 carbon accounting today? Get started now.
The Greenhouse Gas (GHG) Protocol public consultation on proposed updates to Scope 2 guidance closes on January 31, 2026. Electricity Maps has closely followed this phase of the revision process through the Scope 2 Technical Working Group and Independent Standards Board, and we’re happy to share the highlights of our response here.
Our purpose in participating in the public consultation is to advocate for more granular measurement of the carbon emissions of electricity to drive real-world decarbonization.
By prioritizing physical grid reality, both in time (hourly) and space (local market boundaries), the GHG Protocol can transform Scope 2 reporting into a powerful tool for active climate action.
Electricity Maps provides the hourly (and sub-hourly), granular data from around the world necessary to make this high-integrity future feasible today.
We encourage interested organizations to submit their own responses by the January 31 deadline.
Three Core Principles
Attributional Integrity: We fully support refining the Scope 2 definition to include only emissions from generation processes physically connected to the reporter’s value chain.
Physical Reality: We advocate for location-based methods that reflect electricity physically delivered at the specific times and locations of consumption, and market-based methods with strong deliverability requirements.
Grid Decarbonization Goal: Accuracy alone is not the goal of carbon accounting; the standard must incentivize procurement that aligns with system needs and drives real-world grid decarbonization.
An Improved Location-Based Method (LBM) Hierarchy
Granularity as Standard: We fully support the update to the LBM emission factor hierarchy prioritizing hourly, consumption-based data at a local boundary.
Data Accessibility: Our global operations demonstrate that high-granularity, consumption-based data already exists and is accessible for the majority of the global grid.
Independent Methodologies: We argue that independent providers must be recognized as credible sources, as they are often the only source of the most precise, decision-useful data in many regions.
Aligning the Market-Based Method (MBM) with Reality
Hourly Matching: We strongly support Quality Criteria 4, requiring all contractual instruments to be issued and redeemed for the same hour as consumption.
Deliverability: We support Quality Criteria 5, requiring instruments to be sourced from the same deliverable market boundary as the demand. We advocate for deliverable market boundaries that align with the physical reality of the grid to ensure contractual claims are physically plausible and reflect actual transmission constraints. We support using broader regional power pools where physical interconnection and operational governance demonstrate a unified market, such as 45V in the United States.
Additionality: We recommend including additionality criteria in the Market-Based Method requirements to incentivize the addition of new clean power to the grid.
Avoiding Double-Counting with Standard Supply Service (SSS) & Residual Mix
Pro-Rata Allocation: We support the requirement that reporting entities shall not claim more than their pro-rata share of SSS to maintain the integrity of the Residual Mix.
Vintage Requirement: In the absence of centralized registries, we support designating certain resources as SSS based on asset age to ensure higher integrity than allowing open claims on all clean generation.
Fossil Fallback: We support the requirement to use a fossil-based emission factor as a conservative default when no residual mix or contractual instrument is available.
Feasibility & Transition Measures
Load Profiles: We support the use of load profiles as a vital feasibility measure for reporters without hourly meters, prioritizing the most granular profile accessible.
Time-Limited Exemptions: We support exemptions for small and medium enterprises (SMEs) to manage the transition burden, provided they are time-limited and require Mandatory Dual Disclosure of hourly LBM results.
Legacy Clause: We support a legacy clause for long-term contracts (5+ years) signed prior to the standard's publication to protect early adopters and market stability.
Ready to access granular data to power your Scope 2 carbon accounting today? Get started now.
