EFRAG Calls for Balanced and Cost-Effective Approach to Proposed GHG Protocol Scope 2 Changes
In response to the public consultation of the Greenhouse Gas Protocol on the proposed changes to Scope 2 Guidance, EFRAG submits its position, supporting improved comparability while asking for proportionality, clarity and careful cost-benefit consideration.
What is EFRAG calling for?
EFRAG recognises the substantial effort invested in the Scope 2 Guidance and supports the objective of comparability and accuracy of Scope 2 measurement.
However, given the wide application of GHG Protocol and its referencing in regulatory context, EFRAG is very concerned and opposes some of the proposed changes:
The consultation materials and survey are lengthy and, at points, overly complex. EFRAG recommends that future consultations maintain clarity, simplicity, and overall ease of application at the heart of the standard;
EFRAG also emphasises the importance of carefully balancing complexity and cost-effectiveness, particularly in relation to the more detailed and ambitious proposed changes.
Key messages of EFRAG’s position:
Balanced and proportionate approach: ensure careful cost-benefit analysis, weighing complex proposals (e.g. most precise emission factors or hourly matching against their effectiveness) and pilot the revised Scope 2 Guidance before full rollout;
Adequate consultation timeline: allow sufficiently long consultation periods (e.g. minimum 120 days), reflecting growing regulatory relevance of the GHG Protocol;
Concrete drafting: base consultations on specific draft amendments rather than high-level directional proposals;
Consistency across standards: strengthen alignment across different GHG Protocol standards to avoid conceptual inconsistencies;
Principles-based focus: maintain the GHG Protocol on high-level principles, leaving detailed technical specifications to jurisdictions to reflect local data, markets and regulation;
Emphasis on subsidiarity: take into consideration the increasing integration of the GHG Protocol into mandatory reporting frameworks.
What’s next?
All feedback will be analysed by Greenhouse Gas Protocol and work will be undertaken to review and revise the Scope 2 Guidance (2015).
“We welcome the ambition to improve Scope 2 reporting” said Pedro Faria, Environmental Director at EFRAG. “At the same time, changes should be proportionate, clearly justified by user benefit, and capable of being implemented in diverse regulatory and electricity market contexts without creating unintended distortions.”
For more insights, read now:
Results of EFRAG's Greenhouse Gas Protocol Scope 2 Public Consultation Survey