EFRAG publishes its comment letter on the GHG Protocol’s Actions and Market Instruments Phase 1 White Paper

EFRAG emphasises the importance of further clarity on the AMI objectives and recommends a phased approach focused on critical GHG accounting matters.

In its comment letter to the GHG Protocol (GHGP) Request for Information (RFI) on the Actions and Market Instruments (AMI) Phase 1 White Paper, EFRAG welcomes the substantial work undertaken by the GHGP to develop the AMI Phase 1 White Paper, which provides structured approach aiming to address limitations in current emissions accounting and reporting.

At the same time, EFRAG notes that some aspects of the AMI need further clarification and may introduce complexity in a time when stakeholders are seeking simplification.

EFRAG’s key messages focus on the need for clarity, prioritisation of critical GHG accounting challenges, and alignment with existing standards, policies and initiatives that could be impacted by changes to the GHG accounting landscape.

EFRAG’s key messages

  • The importance of clarifying whether the AMI is intended to develop new accounting rules, a broader reporting framework, or a combination of both. We highlight the potential tension of introducing reporting requirements in parallel to existing, jurisdictional reporting requirements, and the uncertainty this may create.

  • The need to focus efforts on improving GHG accounting and addressing critical GHG emissions technical issues that stakeholders have identified as a more urgent priority. Expanding the AMI scope too broadly risks diverting attention away from more pressing matters.

  • Benefits of a phased approach, prioritising methodological gaps in the physical and market-based inventories before progressing to detailed developments in the reporting of GHG impacts of actions.

  • The need for alignment with the ongoing direction of the GHGP revision, notably the Corporate Standard and its proposed objective statement and primary goal, which to our understanding focuses on emissions accounting.

  • Careful consideration is needed regarding how the definition and role of the ‘physical inventory’ interacts with market instruments and traceability, including the interaction with EU policies (e.g. European Union Emissions Trading System, Carbon Border Adjustment Mechanism).

  • The importance of mitigating concerns of greenwashing related to the proposed multi-statement reporting structure by ensuring clear guidance, criteria and safeguards are developed.

  • The need to define foundational principles underpinned by robust measurement methodologies and safeguards for any consequential accounting developments, and that they remain clearly separated from the physical and market-based GHG inventories.

Read more in EFRAG Comment Letter

Stakeholder feedback that informed the comment letter

Following the launch of the GHGP’s RFI period, EFRAG prepared a Draft Comment Letter on the AMI White Paper and conducted a 30-day public consultation seeking feedback and views from EU stakeholders. Through a series of engagement opportunities, including an online survey, workshop, and targeted outreach interviews, EFRAG received and analysed views of 22 stakeholders which helped inform its final response to the GHGP. Find the anonymised summary of stakeholder feedback in EFRAG’s Feedback Statement.

What’s next?

Stakeholder feedback provided to the GHGP will help shape the next stage of AMI development. According to GHGP websites, the full draft AMI standard for public consultation is expected in 2027. 

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