Scope 2 rules are changing: What facility leaders need to know now

The Greenhouse Gas Protocol (GHGP) is updating its Scope 2 accounting rules, and these changes will have major implications for facility leaders. Scope 2 emissions come from purchased electricity consumption — the indirect emissions tied to what’s on the grid when and where a facility draws power. And the way in which they’re defined and reported can have major implications for your organization’s facility and energy strategy.

The GHGP provides widely used standards, guidance, and tools for business and government to measure and manage emissions across business and government. In fact, 97% of S&P 500 companies reporting to CDP¹ use GHGP frameworks².  Because most organizational decarbonization commitments depend heavily on electricity-related reductions, facility operations sit at the center of how companies meet their goals.

Despite political headwinds, leading companies across sectors continue to prioritize decarbonization. Nearly two-thirds (63%) of the Forbes Global 2000 have net zero targets, and in the U.S. the number of commitments rose 9% in the past year — part of a broader tripling in net zero targets since 2020³.  

Many organizations voluntarily report emissions reductions due to investor expectations and growing demand for transparency, while others now face regulatory requirements — including California’s climate disclosure laws. Under SB261, companies doing business in California with revenues over $500 million must report climate-related financial risks, and those over $1 billion must disclose greenhouse gas emissions under SB253.⁴  Although SB261’s January 2026 deadline is currently paused pending appeal, CARB has opened a voluntary reporting docket through July 1, 2026 and proposed an initial emissions reporting deadline of August 10, 2026 for Scope 1 and 2 under SB253.⁵

With so much strategy tied to electricity use and emissions reporting, facility leaders need a clear understanding of what the GHGP’s Scope 2 revisions may mean.

How Scope 2 accounting is changing

Since 2015, GHGP Scope 2 Guidance has relied on a market-based methodology that allows companies to claim renewable energy purchases — such as RECs or PPAs — toward their Scope 2 reduction goals, even if the clean energy was generated at a different time or location. Now, new proposals from the GHGP, like hourly matching and impact accounting, aim to strengthen this link by requiring procurement to better reflect actual grid emissions at the time of use. If these methods are adopted, traditional RECs or PPAs may no longer fully count toward Scope 2 reductions unless they meet the new alignment criteria.

Two new accounting approaches are under consideration, with final standards expected in 2027 and implementation likely in 2028.

• Hourly accounting: Matches electricity consumption with clean generation on the same local grid in real time. This method shifts the focus to identifying responsibility for specific, hour-by-hour emissions within a defined geographical boundary. For facility leaders, it fundamentally changes procurement strategies, requiring them to align energy purchases with the exact hours electricity is consumed. Consequently, the timing and location of clean energy sources become critical factors in achieving emissions goals.
• Impact (consequential) accounting: Measures the system-wide change in emissions that results from specific electricity procurement decisions. This includes the avoided emissions achieved when clean energy displaces dirtier generation sources. This method prioritizes emissions reductions where they have the greatest leverage, offering organizations flexibility to direct clean energy investments toward projects that yield the highest impact per dollar spent.⁶

If hourly accounting becomes the standard, organizations could face higher costs because they may need to secure low-carbon electricity even when it’s scarce, manage more complex procurement oversight, and handle expanded data and auditing requirements. Hourly accounting may also increase demand for firm or dispatchable clean energy resources.

If impact accounting prevails, organizations would have more flexibility to pursue emissions-reduction opportunities across a broader landscape rather than conforming to hourly matching constraints.⁷  For facility leaders, this could translate into procurement pathways that are more cost-effective and directly tied to emissions impact.

Regardless of the final methodology, Scope 2 changes create an opportunity for facility leaders to explore more sophisticated energy monitoring and reporting systems, technologies that support stronger demand-side management, and improved approaches to integrating renewables across their portfolios.

What facility leaders can do now

With the GHGP accepting public comments through December 19, 2025,⁸  and final standards expected in 2027, now is the time to assess how current energy procurement strategies — RECs, PPAs, contracts, and data systems — would perform under both proposed methodologies.⁹  

Mantis can help evaluate existing approaches, identify gaps, and prepare facilities for whichever direction the new Scope 2 standard ultimately takes. Proactive facility leaders who act now can turn these accounting changes into smarter, cost-effective pathways to advance organizational goals now — and into the future.