(August 11, 2026)

By Margret Nellissery, Senior Analyst and Jean Todea, Senior Communications Lead

The summer is moving along, and while some of us may be thinking about vacation, the GHG Protocol has released a summary of feedback from its public consultation on proposed updates to Scope 2 accounting guidance for the market-based method. There’s a lot in it that matters to how you procure renewable energy in Canada. We'll cover the highlights in this blog, then follow up over the next few weeks with two deeper dives, one on hourly matching and one on deliverability/geographic matching.

The consultation ran from October 2025 to January 2026 and drew 1,100 responses from stakeholders in 56 countries, a clear sign of how much is riding on these changes for renewable energy buyers everywhere. Worth noting: this summary doesn’t introduce any new requirements or final decisions. It only captures the range of perspectives that will shape the next stage of framework development. 

Responses came from more than 15 stakeholder groups. Companies made up the largest share of submissions at 43 per cent, followed by industry groups and consultants at 18.6 per cent. Academia and NGOs contributed around 13 per cent, with smaller shares from government institutions, energy suppliers, grid operators and other stakeholders. Geographically, North America and Europe accounted for about 70 per cent of submissions. East Asia contributed 17.4 per cent, and Oceania, Latin America, Sub-Saharan Africa and other parts of Asia made up the remainder.

We submitted our own feedback during the consultation, focused primarily on two proposed changes: hourly matching and deliverability. Our report, Momentum at Risk, analyzes how these changes could affect corporate renewable energy procurement in Canada, and our recommendations closely align with the themes that emerged in the consultation summary.

One area saw near-universal agreement, and it's good news for anyone with an existing PPA: the need for a practical transition. Every region strongly supported the introduction of a legacy clause to protect pre-existing contracts under the market-based method. Respondents argued that companies have made long-term renewable energy investments under current Scope 2 rules and shouldn't see those investments undermined by new requirements. Many supported grandfathering existing contracts or providing a 10- to 15-year lead time before new rules take effect, warning that sudden changes without a legacy clause could undermine investor confidence, strand long-term power purchase agreements and discourage future procurement. Some proposed a percentage-based phase-in, similar to what we recommended and to proposed SBTi transition models, in which companies gradually apply new requirements across their portfolios.

So what happens next? In July, the GHG Protocol's Independent Standards Board reviewed the consultation findings and set the direction for the revision process. The board has asked its Technical Working Group, an independent body of 45 subject-matter experts, to refine the market-based method, resolve open questions and explore whether multiple reporting approaches could better reflect the range of views expressed. The next public consultation is planned for Q2 2027, giving members with legacy PPAs and procurement plans in motion more time to prepare for what comes next.

The world of corporate procurement is continuing to advance, and Scope 2 accounting is moving toward greater accuracy and accountability; that’s a great thing! The consultation also shows broad recognition that any new requirements must balance environmental integrity with the practical realities of global energy markets and long-term investments.

Over the next few weeks, we'll dive into the next two issues: hourly matching and deliverability/geographic matching.