By Jon Powers, President at CleanCapital, and Roger Ballentine, President at Green Strategies, Inc.
Originally published by CleanCapital.
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The Greenhouse Gas (GHG) Protocol, developed over 25 years ago, has become the standard for corporate emissions tracking. It began as a voluntary framework and is now used by over 90% of companies that track emissions. In the recent Experts Only podcast episode, we discuss the future of Scope 2 emission tracking for corporations. Today, as we are navigating the changing landscape in clean energy, corporates shouldn’t lose sight of tracking Scope 2 emissions. Scope 2 emissions often make up a significant share of a company’s carbon footprint and can either help or hinder achieving climate goals.
With proposed changes to the Greenhouse Gas Protocol threatening to restrict how companies can account for renewable energy purchases, the flexibility and affordability of clean energy procurement are at risk for many. These changes could undermine the future of corporate sustainability targets, increase operational costs, and stall progress in the voluntary renewable energy market. The companies that act now to understand and influence these changes will, ultimately, be in a better position to manage risk, maintain their credibility, and be a leader in energy dominance.
In procuring clean electricity to meet their climate and business goals, companies follow the GHG Protocol’s Scope 2 Guidance. Under the guidance, Scope 2 standardizes how corporations measure emissions from purchased or acquired from sources such as electricity, steam, heat and cooling. The Scope 2 Guidance has been instrumental in building the voluntary market for clean energy and supporting the development of 100 gigawatts of clean energy purchased by corporates. The Scope 2 Guidance is currently undergoing its first revision in over a decade to reflect the advancements in measurements and technologies. These updates to the Guidance will significantly impact corporate clean electricity procurement strategies around the world.
Green Strategies has been working alongside companies, NGOs, and other grid experts to identify a range of potential Scope 2 reforms. While we know the status quo needs modernization, we recognize the potential for some companies to back away from their Scope 2 goals if viable ways to procure clean electricity and mechanisms to demonstrate reductions in emissions are not available to them. Currently, the Protocol’s Technical Working Group is proposing a requirement for reporting Scope 2 inventories on a time and location-granular basis, also known “24/7” accounting.
This proposal would require companies to match clean electricity purchases with their electricity consumption on an hourly basis and within the same limited geographic regions in which they operate. Such a change could help drive companies to focus more closely on the time and location aspects of their use and consumption, creating demand for crucial clean resources capable of meeting demand at all times. This is why Green Strategies has supported adding time and location matching as an option for buyers to pursue, along with other options that allow and incentivize companies to procure renewable energy on the dirtiest grids in order to maximize the real-world emissions impact of their actions. Unfortunately, by exclusively mandating narrow time and location accounting for nearly all companies, the current proposal runs the clear risk of reducing overall renewable corporate procurement and missing critical opportunities to reduce more emissions sooner.
Green Strategies recently confirmed these risks through a survey asking companies how these proposed Scope 2 changes might impact their clean electricity procurement practices. We found that nearly 80% of respondents lack confidence that they would be able to procure time-matched clean electricity within smaller market boundaries. 70% of respondents said they have current procurement contracts that would no longer be eligible under smaller market boundaries. Companies cited higher costs, technical capacity, as well as the availability of clean generation as key concerns with this proposal. You can read a summary of this report here or the full report here.
At the 2025 Clean Energy Buyers Alliance (CEBA) Spring Summit, no session gathered more attention than one on 24/7 and Scope 2 updates. Other than the few companies who have been closely involved in the Protocol’s process, many CEBA members were surprised and concerned about the prospect of mandatory 24/7 accounting.
