The GHGP’s Technical Working Group is proposing significant shifts that redefine how organisations align electricity use with clean energy supply.

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At the heart of the GHGP Scope 2 debate is a tension between improving the integrity of emissions reporting and the practical impact on business feasibility. Supporters argue that the proposed revisions close loopholes, align claims with real grid behaviour, and strengthen incentives for technologies that are essential for decarbonising energy systems. Critics, however, warn that the new requirements introduce operational burdens, distort the physics of electricity flows, and risk unintended consequences for renewable procurement and market participation.

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Implementing the proposed revisions are particularly challenging in markets with regional complexities, like APAC, where grid structures, data availability and certificate systems vary significantly across markets. Within major markets in APAC, Australia stands out as the clear outlier - offering both state-level spatial granularity and publicly accessible half-hourly dispatch data. Singapore achieves high spatial precision by virtue of its geography despite a single national factor. Malaysia, China, and Indonesia provide meaningful regional disaggregation, while India's official data remains a single national figure. Critically, every market except Australia is constrained to annual temporal resolution, limiting the practical utility of emissions factors for time-sensitive accounting.

The uneven maturity of renewable energy frameworks means that applying the proposed requirements uniformly is not always practical, making the operational and compliance burden disproportionately higher for organisations based in such regions.

In essence, the proposed revisions offer a trade-off: they may strengthen the credibility of emissions reporting but impose significant operational demands that companies must prepare for proactively.  

Carbon Accounting Implications: Elevated operational demands
The shift toward granular, grid‑reflective reporting will significantly elevate the operational demands of carbon accounting:

• Continuous data management through real‑time access to metered data across all facilities will be mandatory, which may require upgraded hardware, new data pipelines, or integration with utility APIs
• Increased collaboration across sustainability, IT, procurement, operations, and finance teams will be required to maintain accurate real‑time disclosures
• Advanced load profiling to align load to grid conditions. As emissions factors will increasingly reflect real grid behaviour, high‑emission hours (e.g., evenings) will carry greater weight. Businesses may need demand‑shifting strategies or onsite storage to mitigate exposure
• Certificate and attribute tracking will require overhauled systems to match consumption with certificates at the same hour and grid node, adding complexity to procurement and reporting, and increasing the need for stronger governance and audits
• Complexity in comparability across regions: Entities with identical usage patterns may display materially different emissions solely due to difference in data availability. Companies with global operations thus face the added challenge of harmonising data across markets with different grid structures, certificate systems, and utilities.

Renewable Energy Procurement Implications: Economic Impact  

• More complex clean energy procurement: In markets without mature systems, companies may need to combine traditional Energy Attribute Certificates (EACs) with granular certificates, raising the overall cost of achieving hourly matching
• Limited supply of hourly‑deliverable renewable energy: Tight availability, combined with rising demand for hourly‑aligned products, may lead to higher prices for renewable energy and certificates
• Upgrades to metering, data, and verification systems: Companies will need new infrastructure capable of capturing, managing, and validating hourly data
• More complex contractual structures: Power Purchase Agreements (PPAs) and EACs will require additional negotiation, monitoring, and internal resources, increasing the cost and effort required for clean energy procurement

The GHGP Scope 2 revisions represent one of the most consequential shifts in corporate carbon accounting in the last decade. They strengthen the credibility of reported emissions and align corporate claims more closely with the physical realities of the power grid. But they also raise the bar for feasibility, requiring new approaches to data, procurement, and planning.

GHGP recently completed its first public consultation on the Scope 2 revisions, with updated text expected by mid‑to‑late 2026. A second consultation will follow on remaining topics, and the final standard is anticipated by end‑2027, with implementation and compliance unlikely till 2028 or later. This gives organisations valuable lead time to prepare for the eventual requirements and also provides an opportunity to engage in the second consultation cycle - enabling them to shape the emerging standards and offer on the ground feedback about the practical implications of the proposed changes.

The shift to granular, hourly accounting will transform how organisations plan energy procurement, going from being an annual reporting task into a real time operational and financial challenge. Companies that prepare early will not only ensure compliance but also reduce transition risk, safeguard their carbon claims, and gain an edge in an increasingly scrutinized energy market. Early action enables organizations to redesign procurement before market constraints tighten, avoid costly retroactive disclosure adjustments, and secure high quality renewable supply ahead of rising demand.

To prepare for this transition, organisations should:

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The Scope 2 revisions are not merely a reporting update; they represent a structural shift in how corporate energy strategy must be designed. Organisations that begin planning now will convert regulatory change into strategic advantage. Those that wait may find themselves navigating higher costs, compressed timelines, and diminished flexibility in a more constrained and transparent energy market.