The European Financial Reporting Advisory Group has published a comment letter on the GHG Protocol request for information on the Actions and Market Instruments Phase 1 White Paper, backing the effort to address weaknesses in current emissions accounting and reporting while urging greater clarity on the initiative’s purpose and scope. EFRAG said the AMI framework needs to be clearer on whether it is intended to create new accounting rules, a broader reporting framework, or both, and warned that parallel reporting requirements alongside existing jurisdictional regimes could create uncertainty and added complexity. Its response argues that work should prioritise the most urgent greenhouse gas accounting issues identified by stakeholders, rather than expanding AMI too broadly at an early stage. EFRAG recommended a phased approach that first addresses methodological gaps in physical and market-based inventories before moving to more detailed reporting on the greenhouse gas impacts of actions. It also called for alignment with the wider GHG Protocol revision, especially the Corporate Standard and its proposed objective statement, careful treatment of how the physical inventory interacts with market instruments and traceability, including links to European Union policies such as the European Union Emissions Trading System and Carbon Border Adjustment Mechanism, and safeguards to limit greenwashing risks in any multi-statement reporting structure. The final letter was informed by a 30-day public consultation and other outreach activities that gathered and analysed views from 22 stakeholders. According to GHG Protocol websites, feedback on the request for information will inform the next stage of AMI development, with a full draft AMI standard for public consultation expected in 2027.
European Financial Reporting Advisory Group2026-06-12
European Financial Reporting Advisory Group calls for clearer objectives and a phased approach in GHG Protocol AMI development
The European Financial Reporting Advisory Group has told the GHG Protocol that its Actions and Market Instruments work needs clearer objectives and a narrower initial focus on critical greenhouse gas accounting issues. It recommended a phased approach, stronger alignment with existing standards and European Union policies, and safeguards against added complexity and greenwashing. A full draft AMI standard for public consultation is expected in 2027.