As part of the Greenhouse Gas Protocol’s (GHG Protocol) revision of its emissions accounting standards, it held a public consultation from October 2025 to January 2026 on its draft Scope 2 Guidance, which covers emissions from purchased electricity.
The proposed updates shift the current Scope 2 Guidance from annual matching towards greater granularity in electricity procurement, requiring companies to match their electricity demand with carbon-free energy produced in the same hour and sourced from the same region where consumption occurs. According to the GHG Protocol’s Scope 2 Technical Working Group (TWG), which prioritized scientific integrity above all other considerations in its assessment, this shift toward more granular accounting would increase the accuracy of corporate emissions claims. Many academics and the International Energy Agency (IEA) advise that the changes would likely drive greater decarbonization than the current standard.
The GHG Protocol published the Scope 2 consultation responses in July 2026. Of the 1,072 responses received, over half were submitted anonymously. InfluenceMap’s prior research on corporate engagement on Scope 2 emissions accounting found that Technology companies demonstrated substantial indirect engagement through industry associations. In a clear continuation of this trend, the July 2026 publication reveals that very few Technology companies were willing to publicly disclose their positions on the draft Scope 2 Guidance: Google responded in support of the updates, but Apple, Amazon, Meta, and Microsoft were notably absent from the pool of public responses. While the Emissions First Partnership, a coalition formed to advocate on Scope 2 emissions accounting whose members include Amazon, Intel, Meta, and Salesforce, declined to publicly respond to the consultation, InfluenceMap located evidence of the group’s participation.
Building on our previous research, the entities selected for this analysis include perspectives from the utilities, technology, and energy sectors. In addition to these entities, this analysis also covers organizations not fully assessed in InfluenceMap’s database, but with a history of engagement on Scope 2 emissions accounting, primarily through sponsored research published on behalf of technology companies. These include the Emissions First Partnership, REsurety, WattTime, the Technical University of Berlin (TU Berlin), and Princeton ZERO Lab.
Disclaimer: This graphic is based on quantitative responses to the Scope 2 consultation indicating entities’ support for, or opposition to, the proposed updates. This evidence currently does not contribute to entities’ scores on their LobbyMap profiles. The full data informing this analysis is accessible through the Greenhouse Gas Protocol’s website. Select quotes from entities’ written responses can be found in the tables at the bottom of this page.
InfluenceMap’s analysis of the entities’ consultation responses finds several recurring narratives underpinning respondents’ arguments on the proposed Scope 2 updates. The GHG Protocol’s summary of the consultation responses found that while companies and trade groups broadly opposed the proposed updates, respondents from academia and civil society (NGOs) supported the updates at significantly higher rates. Proponents more frequently cited studies from authoritative sources, such as peer-reviewed studies and government reports (Constellation, Google), to support their claims. Conversely, opponents’ responses often cited self-administered studies and findings (i.e. CEBA citing a private survey of its members, and WattTime citing its own study, co-sponsored by Apple and Meta). The table below provides an abbreviated list of pervasive narratives and examples of some, but not all, of the entities that used them in their responses.
| Proponent Narratives | Opponent Narratives |
|---|---|
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| Supporting hourly matching and more stringent deliverability criteria | |
|---|---|
| Constellation | “A market-based method that relies on hourly accounting, physical deliverability boundaries, and the fair allocation of clean energy will drive climate impact by addressing oversupply and creating incentives for the technologies and power system investments that will be required to achieve a net-zero grid. Because hourly matching is optional today, commenters advocating for voluntary approaches to hourly accounting are essentially endorsing a status quo that is no longer working. The research [...] and market conditions [...] are unambiguous – the current standards for voluntary clean energy procurement are neither credible nor impactful.” |
| “We support the proposed changes to retain contractual instruments for market-based claims, as well as to specify that the market instrument be temporally and spatially correlated to the reporter’s underlying electricity consumption.[...] At the top of GHGP’s decision-making hierarchy is “scientific integrity.” The proposed updates improve accuracy and scientific integrity of location-based Scope 2 emissions, while providing options to support feasible implementation.” | |
| Iron Mountain | “We support the proposed updates which increase the level of granularity of data tracking spatially and temporally, thereby improving accuracy. [...] Hourly matching drives decarbonization by sending signals and investment direction to deploy technologies necessary to decarbonize all hours of the day. Today’s methodology allows organizations to claim 100% clean electricity procurement based entirely on solar and completely uncorrelated to actual electricity consumption. The current proposal fixes that issue.” |
| Princeton ZERO Lab * **
* Princeton ZERO Lab has published several studies on emissions accounting funded by Google. Further details on sponsored research on emissions accounting can be found in InfluenceMap’s October 2025 report. ** This response was submitted on behalf of an individual, rather than an organization. This is common for respondents from academia/research. | “Today’s methodology allows organizations to claim 100% clean electricity procurement based entirely on solar or on power in regions that are not physically connected/deliverable. This hurts credibility and undermines consequential impact. Reforms align with recent government programs, including: EU Hydrogen Standard [...] US 45V Clean Hydrogen Standard [...] Hourly matching drives decarbonization by sending signals and investment direction to deploy technologies necessary to decarbonize all hours of the day, including batteries, demand flexibility, longer-duration storage technologies, and 'clean firm' generation technologies.” |
| Technische Universität Berlin * **
* Technische Universität Berlin has published several studies on emissions accounting funded by Google. Further details on sponsored research on emissions accounting can be found in InfluenceMap’s October 2025 report. ** This response was submitted on behalf of an individual, rather than an organization. This is common for respondents from academia/research. | “Procuring clean electricity from incremental/new resources (incrementality concept) that is deliverable to the consumer of electricity (deliverability concept), with production matched to consumption in time (temporal granularity, or hourly matching concept), eliminates Scope 2 emissions associated with the participating consumer's electricity consumption and reduces system-level emissions. [...] This hourly matching approach consistently delivers lower consequential emission outcomes compared to annual matching. The disparity in decarbonization outcomes between the hourly hourly and annual renewable matching policies becomes increasingly pronounced as local grids transition to cleaner states over time. [...] Hourly matching with an "imperfect score" of 90%–95% has only a small cost premium over annual renewable matching, but can already result in significant reduction of attributional (inventory) and consequential system-level emissions compared to annual matching.” |
| Mixed support for hourly matching and/or more stringent deliverability criteria | |
|---|---|
| Engie | “ENGIE [...] supports the proposed change (hourly matching should follow a required “shall” approach) – providing that mandatory implementation is done under the following conditions: No earlier than Reporting year 2030; Is phased and includes a legacy clause for existing contracts. [...] Includes exemptions for companies with annual consumption up to 50 GWh/year within a country. These conditions underpin ENGIE’s position on hourly matching – if they are not included in the GHG Protocol’s post-public consultation proposal, ENGIE would need to review its position. ... ENGIE does not support the proposed zonal market boundaries. ENGIE does support clearly defined market boundaries, but where the minimum boundary is set at the country level.” |
| Ørsted | “Ørsted is generally well disposed towards the long-term movement of GHG scope 2 accounting methodologies (market-based) towards more locational and temporal granularity as to better reflect physical flows of electricity. We also look favorably upon 24/7 matching as a long-term goal [...] As an immediate and interim step following the publication of the scope 2 guidance, strict yearly matching could be used as an immediate step (in 2026) prior to eventual monthly, weekly and hourly matching” |
| Unilever *
* Unilever declined to submit their response to the Scope 2 Public Consultation with attribution. If electing to submit anonymously, respondents are responsible for ensuring any identifying information is removed. Unilever did not remove all of its identifying information, naming itself in its response to question 58 of the consultation (published under ID 781). | “We support using national boundaries as the deliverability boundary in both MBM and LBM. Exceptions should be made for small countries importing a significant share of their total electricity consumption volume from a neighbouring country. Additionally, large nations such as USA and India may benefit [from] more granular sub-boundaries however regional experts should be consulted with directly in this regard. [...] [W]e also believe that requiring granular accounting and procurement brings significant and unnecessary complexity to a market where there are already existing barriers to corporate renewable electricity procurement. We urge the GHGP to consider such cases fully where imposing 'a one size fits all' temporal granularity requirement could hinder renewable energy development.” |
| WindEurope | “WindEurope sees long-term value in more granular matching as it can support better accounting and investment in flexibility. However, making it mandatory now would add complexity and undermine the clear distinction between accounting and system operation. For large industrial consumers, mandatory hourly matching before the market for hourly-certified products is sufficiently mature could complicate energy procurement, potentially slowing the growth of corporate PPAs and electrification. At the same time, WindEurope recognises that some large and advanced electricity consumers can pursue more granular matching on a voluntary basis.” |
| Opposing hourly matching and more stringent deliverability criteria | |
|---|---|
| American Petroleum Institute | ”Mandatory hourly matching and deliverability would likely create significant uncertainty in energy markets, increase the cost of contractual instruments, and disrupt existing contracts. Such changes risk reducing voluntary participation in electricity markets and increasing overall energy costs, thereby reducing energy accessibility and affordability.” |
| Clean Energy Buyers Association (CEBA) *
* In March 2026, during the course of InfluenceMap’s tracking of corporate engagement on the Scope 2 Guidance, CEBA underwent an organizational change, ceasing engagement as the Clean Energy Buyers Association and instead adopting the name Corporate Energy Buyers Association. | “CEBA opposes the GHG Protocol’s proposal to mandate hourly matching and physical deliverability in the market-based method. [...] Proposing to hardcode mandatory requirements of hourly matching and deliverability is a policy-directed action beyond the Protocol’s own identified remit. The Scope 2 Guidance should be maintained and enhanced to ‘advance systemic electric grid decarbonization globally.’” |
| Emissions First Partnership *
* Emissions First Partnership declined to submit their response to the Scope 2 Public Consultation with attribution. If electing to submit anonymously, respondents are responsible for ensuring any identifying information is removed. Emissions First Partnership did not remove all of its identifying information, stating that their response (published under ID 1109) was on “behalf of the Emissions First Partnership.” | “The purpose of scope 2, therefore, needs to reflect these dual priorities: an attributional approach for the inventory and a consequential approach alongside it [...] balancing scientific integrity, climate impact, and feasibility requires a Scope 2 framework that preserves the rigor of attributional accounting without imposing requirements, such as mandatory hourly or deliverable matching, that ultimately reduce climate impact and undermine feasibility.” |
| Hewlett Packard | “We disagree with the proposal for hourly and location-matching requirements for market-based instruments. We are of the view that hourly matching should follow an optional “may” rather than a required “shall” approach and sourcing contractual instruments within deliverable market boundaries should also follow an optional “may” rather than a required “shall” approach. While the proposed changes may improve methodological precision, we are concerned that the benefits would outweigh the higher costs, reporting burden, and reduced ability to support large-scale clean energy development.” |
| REsurety *
* REsurety has published several studies on emissions accounting funded by Meta and Microsoft. Further details on sponsored research on emissions accounting can be found in InfluenceMap’s October 2025 report. | "While we support modernizing the Market Based Method (as described in other answers), we do not support changing its fundamental definition from a procurement metric to usage metric. The definition should not mandate hourly matching or physical deliverability. These should be optional reporting pathways alongside an equal Impact Accounting pathway that measures emissions across a reporter's contractual information and claims flow." |
| Rivian | “We strongly disagree with the proposal to mandate “temporal correlation and deliverability requirements” within the market-based method (MBM). [...] Instead of driving more clean energy, these rigid rules create perverse incentives: pushing buyers toward spot REC purchases from existing assets, raising costs but reducing bankable, long-term contracts that finance new capacity. [...] Mandating hourly matching, rather than optional, would undermine the market mechanisms that drive clean energy deployment, distort the operation of grid assets like energy storage, and impose prohibitive costs without guaranteeing emissions reductions.” |
| U.S. Chamber of Commerce | “The proposed combined changes to the Market-Based Method, hourly matching, and deliverability raise serious concerns regarding feasibility, cost, and unintended consequences. The Market-Based Method has long provided a stable and credible way for companies to reflect contractual attributes associated with electricity procurement while maintaining comparability across reporters. To date, there has been very little adoption of hourly or geographical matching in the business sector, a reality that reflects inherent technical and logistical challenges associated.” |
| WattTime *
* WattTime has published several studies on emissions accounting funded by Meta, Apple, and other Technology sector companies. Further details on sponsored research on emissions accounting can be found in InfluenceMap’s October 2025 report. | “The deliverability and hourly-matching requirements also risk further exacerbating inequities in clean energy investment. [...] hourly matching, regardless of the size of deliverability regions, remains an existential threat to global, equitable, and impactful decarbonization and should not be adopted. Instead, the GHGP should adopt a consequential metric with avoided emissions, induced emissions, and additionality requirements” |
| Workday | “The intent of higher granularity is to send stronger signals and increase impact. In practice, mandatory hourly and deliverability rules may push buyers away from long-term, bankable contracts and toward spot REC purchases from existing assets. [...] A better path in our view is to keep MBM centered on certificate-based attribution with annual matching as the baseline. Hourly and deliverability matching should be optional (“may”, not “shall”) as a leadership tier, rather than a universal requirement.” |
