EFRAG raises concerns over GHG Protocol's Scope 2 proposals

EFRAG has responded to the public consultation on the proposed revisions to the Greenhouse Gas Protocol’s Scope 2 guidance.

While it supports the objective of improving the comparability and accuracy of Scope 2 emissions measurements, EFRAG said it is “very concerned” over some of the draft changes.

Pedro Faria, EFRAG Environmental Director at EFRAG, stated: “Changes should be proportionate, clearly justified by user benefit, and capable of being implemented in diverse regulatory and electricity market contexts without creating unintended distortions.”

EFRAG calls for:

• A cost-benefit analysis on the more complex proposals and a pilot testing programme before rolling out the revised guidance
• The public consultation to last for a minimum of 120 days, due to the growing regulatory importance of the GHG protocol materials
• Strengthened alignment across the different GHG Protocol standards and guidance
• A principles-based focus, with detailed technical specifications left to jurisdictional requirements

Full position paper

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