Policy Paper: Seven keypoints for the Scope 2 Standard

The German CEO Alliance on Climate and Economy is participating in the Greenhouse Gas Protocol’s consultation process on the Scope 2 Standard, using this platform to jointly articulate positions with its member companies and to actively contribute to the further development of the standard.

Berlin, 31.01.2026. This review is highly relevant to the work of the German CEO Alliance on Climate and Economy, as Scope 2 accounting directly influences how companies design renewable electricity procurement strategies, report progress toward climate targets, and make investment decisions in the context of the energy transition.

The alliance supports the overarching objective of enhancing the credibility and transparency of Scope 2 reporting, particularly in relation to green electricity procurement. At the same time, revisions to the standard should reflect practical implementation realities, long investment cycles, and the diversity of corporate starting points.

Seven Key points for an updated Scope-2-Standard:

1. The German CEO Alliance on Climate and Economy supports the general goal of the GHG Protocol review in enhancing credibility and transparency of the reporting system for Scope 2 emissions, especially in conjunction with green electricity procurement.
2. The alliance supports a progressive but pragmatic revision of the Scope 2 Standard, combining higher accounting integrity with feasibility, proportionality, and market compatibility.
3. Hourly matching can serve as a long-term best-practice standard. In the near term, however, it should be introduced gradually, promote voluntary early adoption, and focus on companies with material electricity demand and system relevance.
4. Feasible implementation requires transition and legacy protection, including a transition period of around five years and grandfathering of existing renewable electricity contracts until their expiry.
5. Materiality-based thresholds and de-minimis rules should be applied, with clear differentiation between site-level and company-level consumption and opt-out options for organizations with limited administrative capacity.
6. Geographical matching rules should be compatible with European electricity market integration, existing Guarantees of Origin systems, and cross-border renewable procurement models.
7. Scope 2 reforms should be aligned with broader system transformation objectives, including renewable capacity expansion, grid modernization, flexibility deployment, digitalization, and the long-term affordability of energy for industry and consumers.