Month: January 2026

GHG Protocol released a Consultation on their Scope 2 Guidance in October 2025. Douglas Hileman Consulting submitted comments on the good and the bad. However, there are still some things missing. Including some major things that place a disproportionate burden on preparers, and likely contribute to backlash against carbon accounting altogether.

1. “Feasibility” is mentioned, but not enough. It should be considered more
broadly, notably for first-timers and for small and medium-sized enterprises (SMEs).

2. The burden for providing emissions factors should be shifted from preparers to electricity providers. This includes residual emissions factors and temporal alignment.

3. In addition to a hierarchy of preference for types of emissions factors, there should be a hierarchy of preference for the types of operational inputs (aka “activities”) are selected for calculating GHG emissions.

4. The Consultation would require adoption of a hierarchy of preferences for emissions factors for calculating GHG emissions. However, there is no requirement or suggestion that preparers disclose what types of emissions factors they used.

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GHG Protocol released a Consultation on their Scope 2 Guidance in October 2025. The objective is to help preparers improve the accuracy of GHG emissions inventories, and enable users to have more confidence in the disclosures. Douglas Hileman Consulting1 thinks GHG Protocol could do
better.

Here’s what could be better.

1. Provide hierarchy of quality information for operational inputs (aka “activities”) that must be paired with emissions factors to enable calculation of GHG emissions.
2. Create a tiered approach to provide relief to small and medium-sized enterprises (SMEs), and organizations with very small GHG emissions footprint [at least for Scopes 1 and 2].
3. Include a “conform or explain” provisions for using residual emissions factors. This would relieve considerable burden from SMEs and for preparers unable to obtain information from providers of “electricity” as defined in the GHG Protocol.
4. Broaden applicability of “feasibility.” Consider organizations’ limitations in systems, controls, data and resources – especially SMEs.
Watch for companion pieces on Context and Perspectives, The Good. and Still Missing.

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GHG Protocol released a Consultation on their Scope 2 Guidance in October 2025. The objective is to help preparers improve the accuracy of GHG emissions inventories, and enable users to have more confidence in the disclosures. Douglas Hileman Consulting1 has some good things to say. Watch for companion pieces on Needs Improvement and Still Missing.

1. Monitoring and updates are always a good move.
2. The Consultation restates emphasizes key concepts that many overlook.
3. It’s a reminder to avoid double-counting of Scope 2 emissions, although this is more common than you think.
4. Temporal alignment and using residual emissions factors should yield more accurate GHG emissions inventories.
5. “Feasibility”: it’s said out loud! (But not enough).

This is one in a series, including: Context and Perspectives; Needs Improvement; and Still Missing.

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GHG Protocol published a Consultation of Scope 2 Guidance in October 2025.  The intent is to enable more accurate calculations, estimates and disclosures.  Douglas Hileman Consulting[1] offers some context and perspectives on why this is important – and why anyone involved in carbon accounting – or operations, compliance, sustainability or audit – should take notice. 

1. It’s (essentially) the law.
2. It’s another example of how “voluntary” Guidance become mandatory.
3. Consensus provides relief from regulations and B2B chaos.
4. The GHG Protocol creates expectations globally.

This is one in a series, including: The Good; Needs Improvement; and Still Missing. 

[1] The perspectives are mine alone, and do not reflect any client, former employer, or professional organization I have been involved with.

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