GHG Protocol Advances Impact Accounting
Coverage from REsurety, CRS, and others
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The Topic

The GHG Protocol’s Actions and Market Instruments workstream is developing a consequential, or impact, accounting approach that would sit alongside conventional emissions inventories and show how corporate electricity decisions affect system-wide emissions. The proposed framework uses marginal emissions, including build and dispatch effects, to estimate induced emissions from demand and avoided emissions from clean power procurement, storage, or other interventions. It could steer investment toward actions with greater incremental impact, but important questions around baselines, additionality, data quality, assurance, and how the approach fits with annual and hourly matching remain unresolved.
First Article: 03/26/26
Latest Article: 06/08/26
Summary
- The proposed framework would add an optional impact statement alongside physical and market-based emissions inventories.
- Marginal emissions factors are intended to estimate induced emissions from electricity demand and avoided emissions from procurement or storage.
- Location, timing, grid congestion, curtailment, and the mix of marginal generators can materially change a project’s measured impact.
- Consequential accounting is being positioned as complementary to annual, hourly, and locational matching rather than as an immediate replacement.
- Annual matching remains important for broad participation and market liquidity, while more granular approaches can sharpen signals in constrained regions and hours.
- Baselines, additionality, emissions-rate weighting, load emissions, data availability, and third-party assurance still require development.
- Renewable energy certificates and related tracking systems remain necessary to support exclusive claims and prevent double counting.
History
The story has shifted from a general debate over accounting methods to a more specific proposed GHG Protocol framework that would add impact accounting as an optional companion to conventional inventories. The new version also adds unresolved design details—especially baselines, additionality, data quality, and assurance—that suggest the framework is moving toward implementation but is still unsettled.
