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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