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.

Read More