
Businesses would need to change the way they calculate and report electricity (Scope 2) emissions under new proposals from the Greenhouse Gas Protocol (GHGP).
Why does this matter?
The GHGP Standards are the most widely used global framework for corporate reporting of emissions. This proposal marks the beginning of a multi-year programme of consultations (running to around 2030) aimed at modernising and strengthening the standards.
Changes to Scope 2 are particularly significant because electricity emissions are material for most organisations. If adopted, they could reshape how electricity-related emissions must be measured, reported, and substantiated.
What is proposed?
The GHG Protocol is proposing tighter, more consistent rules for Scope 2 reporting. Changes include stricter criteria for renewable electricity instruments, clearer guidance on dual reporting, stronger disclosure requirements, and new expectations for high-integrity procurement. These updates may affect how organisations source renewable electricity and the credibility of market-based claims.

Summary of changes proposed, sourced from the GHGP website.
What actions is Toitū taking?
Toitū is reviewing the two consultation documents and planning to submit a response, with a focus on ensuring the proposed changes:
- Are practical to implement both by our clients and within Toitū
- Will drive greater positive impact compared to the current guidance
- Have appropriate country-specific considerations or limitations
Actions for clients
Most organisations do not need to take any action at this stage. Final updates to the Scope 2 guidance are not expected until 2027, and the GHG Protocol has indicated there will be phased implementation. Toitū will keep clients informed as the process develops.
Electricity generators, retailers and regular users of Energy Attribute Certificates may like to participate in the consultation. Submissions are open until 31 January 2026.
Keeping you informed
Toitū will keep you up to date as the process progresses and will ensure our systems and guidance are ready ahead of any future changes. If you have questions or would like to discuss what this could mean for your organisation, please contact your Programme Lead.