The European Financial Reporting Advisory Group (EFRAG) has submitted a position paper responding to the Greenhouse Gas Protocol’s consultation on proposed changes to its Scope 2 Guidance, backing the aim of improving comparability and accuracy while opposing elements it views as overly complex or insufficiently justified by user benefits. EFRAG argues the consultation materials and survey are lengthy and at points overly complex, and calls for clearer, simpler proposals that remain easy to apply. It asks for a careful cost-benefit assessment of more detailed approaches, including proposals such as using the most precise emission factors or hourly matching, and recommends piloting a revised Scope 2 Guidance before full rollout. EFRAG also calls for longer consultation periods, suggesting a minimum of 120 days, consultations based on concrete draft amendments rather than directional proposals, stronger alignment across GHG Protocol standards to avoid conceptual inconsistencies, and a principles-based focus that leaves detailed technical specifications to jurisdictions to reflect local data, markets and regulation. The Greenhouse Gas Protocol will analyse consultation feedback and undertake work to review and revise the 2015 Scope 2 Guidance.
European Financial Reporting Advisory Group 2026-02-20
European Financial Reporting Advisory Group urges proportional and cost-effective changes to Greenhouse Gas Protocol Scope 2 Guidance
EFRAG submitted a position paper on the Greenhouse Gas Protocol's Scope 2 Guidance consultation, supporting improved comparability and accuracy but criticizing complexity and insufficient user benefits. EFRAG calls for simpler proposals, a thorough cost-benefit analysis, and piloting revised guidance before full implementation. It also recommends longer consultation periods, concrete draft amendments, and alignment across standards to avoid inconsistencies.