by David Prieto | April 1, 2026
The Greenhouse Gas Protocol just released a white paper proposing a sweeping restructuring of corporate climate accounting and reporting. The 60-day comment period runs through May 31, 2026.
Why It Matters
The guidance expects to “help unlock investments in decarbonization while strengthening the integrity of greenhouse gas (GHG) accounting and reporting.” How? The major change proposed therein is a multi-statement GHG accounting and reporting structure. The paper introduces one statement (Statement 2) that would constitute a market-based inventory for scopes 1, 2 & 3, building on the well-known market-based scope 2 approach and extending it to the other scopes. Through this market-based inventory, companies can demonstrate emission reductions through contractual instruments such as biomethane, green steel, and sustainable aviation fuel certificates.
Why do we need this? The best opportunities for credible, scalable, cost-effective decarbonization are often, at least for now, disconnected from the companies whose climate targets and strategies are driving them to seek the very same emission reductions. The disconnection can be geographic or a long chain of suppliers between the emission source and the consumer-facing brand with a science-based target. Market-based mechanisms allow these limited points of supply and demand for decarbonization to connect efficiently and create near-term impact. Additionally, Statements 3 and 4 in the proposal provide space for companies to demonstrate other critical impacts they can achieve, through carbon offsets, creating products that help others reduce emissions, and more.
That makes these proposed updates great news for decarbonization. “The uncertainty of ‘what will count’ has been holding up investment in the climate projects we so urgently need,” said Emily Damon, ClimeCo’s Chief Growth Officer. “This much-anticipated view into GHG Protocol’s position — especially when paired with the expected final release of SBTi’s Corporate Net-Zero Standard Version 2.0 later this year — should give companies the clarity they need to act.”
What Is Being Proposed
The core proposal is a four-statement reporting architecture that separates today’s single corporate GHG report into distinct, methodologically separate components:
- Statement 1 (Physical GHG Inventory): The existing Scope 1, 2, and 3 inventory, based on physical flows of goods and services, remains unchanged and foundational — no modifications proposed
- Statement 2 (Market-Based GHG Inventory): Extends the current Scope 2 market-based method into Scope 1 and Scope 3, standardizing how companies account for contractual instruments such as biomethane certificates, green steel, and sustainable aviation fuel book-and-claim arrangements
- Statement 3 (GHG Impact Statement): A consequential accounting statement capturing what a company’s actions change in the atmosphere relative to a credible counterfactual baseline — which can include value chain interventions, sector-level investments, avoided emissions from sold products, and retired carbon credits
- Statement 4 (Non-GHG Indicators): A standardized shelf for financial contributions, procurement percentages, intensity metrics, and other KPIs that do not translate into tonnes of CO₂e
We’re encouraged by how much progress the AMI working group has made in aligning with and building on existing standards. The GHG Protocol now incorporates contributions from SBTi, ISO, AIM Platform, TCAT, and ICVCM — reducing the risk of conflicting requirements and strengthening the likelihood that compliant reporting will be recognized across multiple programs and jurisdictions.
What Decisions Are Pending
The white paper is candid about significant open questions remaining:
- Target Claims: Does this mean market-based mechanisms will count toward my SBT? Not yet, but it just got a lot easier for SBTi to say something like SBTs can be met through either physical or contractual inventory. As of now, the white paper states, “These new statements present options for target-setting programs to consider as they create new rules.”
- Instrument Characteristics: Quality criteria and additionality requirements for instruments entering Statement 2 are not yet defined
- Residual Emissions: Residual emission factor treatment for Scope 1 and Scope 3 market instruments — analogous to the residual mix challenge in Scope 2 — remains an open challenge
- Project Accounting: Consequential accounting methods for Statement 3, including credible baseline construction, leakage accounting, and avoided emissions standardization, require further development
- Recommendations: Whether any new statements will be required or optional has not been decided
Timeline & Strategic Implications
The RFI comment period closes May 31, 2026. A draft standard is expected for formal public consultation in Q3 2027, with the final AMI Standard anticipated by the end of 2028.
“For companies with strong avoidance emission stories, who have until now felt that GHG Protocol’s boundaries failed to acknowledge and incentivize their potential to accelerate the net zero transition, this answers a question the industry has long needed resolved,” said David Prieto, ClimeCo’s Vice President for Sustainability Advisory. “We see significant pent-up demand for exactly the kinds of emission reduction projects this framework is designed to recognize — from ultra-efficient HVACs and enhanced geothermal systems to sustainable aviation fuels and carbon capture and storage. This should help unlock that pipeline.”
ClimeCo intends to provide formal feedback during the comment period and continues helping companies and standard-setters alike create clear strategies to maximize climate impact. We’re making a difference today, for a better world tomorrow.
ClimeCo can help. Whether you want to understand what this framework means for your climate strategy, need support preparing a response to the public consultation, or are looking to connect your decarbonization goals with the projects that this standard is designed to recognize, contact us today or reach out to your ClimeCo advisor.
About ClimeCo
ClimeCo is an award-winning leader in decarbonization, empowering global organizations with customized sustainability pathways. Our team of respected scientists and industry experts collaborates with companies, governments, and capital markets to develop tailored ESG and decarbonization solutions. Recognized for creating high-quality, impactful projects, ClimeCo is committed to helping clients achieve their goals, maximize environmental assets, and enhance their brand. Partner with ClimeCo to drive meaningful environmental change and take your climate initiatives to new heights.
Contact us at +1 484.415.0501, info@climeco.com, or through our website climeco.com.
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