Lesley Hunter is senior vice president of policy and engagement at the American Council on Renewable Energy, and Jeffrey Gorham is ACORE's director of policy and engagement.
The Greenhouse Gas Protocol has opened a new public comment period on proposed updates to its Scope 2 Guidance, the rules that determine how companies and organizations measure and report the emissions from their purchased electricity. This might sound like a technical accounting exercise, but its implications are anything but.
The decisions made in this process could reshape the multibillion dollar market for voluntary clean energy procurement — and not necessarily for the better.
The GHG Protocol’s consultation, open through January 31, 2026, proposes significant changes to how companies can report renewable electricity use. Under the draft revisions, all renewable energy procurement would have to be matched hour by hour to a company’s electricity consumption and come from much tighter geographic boundaries to qualify under the accounting method.
The intent is understandable. The GHG Protocol wants to make corporate emissions reporting more precise. But the proposed requirements could have serious unintended consequences — chief among them, undermining corporate demand for clean energy and slowing the pace of renewable deployment in the United States.
For the past decade, companies participating in this voluntary market have driven the demand for clean energy. Companies that buy renewable energy have played a direct role in creating demand for over 40% of all U.S. solar and wind projects added over the past decade. These deals have supported local jobs, driven innovation, and sent powerful market signals that have accelerated the buildout of clean energy at a time when demand is spiking.
The GHG Protocol is the backbone of this voluntary system. It’s the accounting framework that allows companies to claim credit for the development of this clean energy. The GHG Protocol’s market-based approach allows companies to support clean energy even when the electrons powering their operations come from a shared grid. It’s a simple, transparent mechanism that has unlocked billions in private investment and allowed businesses of all sizes to source clean energy for their operations.
Imposing mandatory hourly matching and narrow geographic rules would effectively dismantle that market before trusted tools and data systems exist to make such precision feasible. While more granular reporting can be valuable for companies pursuing 24/7 clean power goals. It should remain optional, not a requirement for all. If adopted as written, the proposal could make it much more difficult for companies to credibly report renewable electricity use, discourage participation in the voluntary market, and ultimately affect funding for new wind, solar, and other clean energy projects.
The GHG Protocol deserves credit for running an open, transparent consultation process and for inviting diverse perspectives. But as it weighs revisions, the organization should carefully consider how these changes could ripple through clean energy markets. Driving more clean energy projects onto the grid directly lowers emissions in the power sector and enables electrification that can lead to emissions reductions in other sectors of the economy. Precision in accounting is important but progress in deployment is essential.
As the comment period continues, ACORE and our members will submit detailed feedback to ensure the final Scope 2 standard reflects both environmental integrity and market reality. We urge all stakeholders to do the same.
The GHG Protocol has a proud history of setting the bar for credible, science-based climate accounting. With thoughtful engagement, it can do so again by crafting a standard that strengthens transparency while preserving the momentum of the clean energy transition.
