The Greenhouse Gas Protocol’s Scope 2 Accounting Revisions: A Complex Battle Among Tech Giants

I. Initial Appearances vs. Strategic Significance

At first glance, last week’s call for public comment from the Greenhouse Gas Protocol (GHGP) might not seem like a major victory for tech behemoths. In fact, it could be mistaken for a routine administrative task. However, for Google and Microsoft, this announcement represents a significant milestone in their multi – year struggle against competitors regarding the accounting of carbon emissions from data centers and, by extension, in the context of AI.

The GHGP’s move indicates that it is one step closer to implementing a mandatory hourly accounting method for electricity emissions. Google has been advocating for this carbon – accounting system since 2020, while Microsoft has been doing so since 2021. Google spokesperson Mara Harris states, “We support the proposed Scope 2 updates, which would enhance the accuracy and decarbonization impact of carbon inventories.” Microsoft, on the other hand, declined to comment.

II. The Scope 2 Emissions Landscape

A. Definition and Significance

Scope 2 is a sub – category employed by the GHGP to account for a company’s indirect emissions from purchased electricity, steam, heat, or cooling. For tech giants, Scope 2 emissions have skyrocketed as AI has spurred exponential growth in data center energy consumption. As these energy demands have increased, so too has the impetus to develop a new approach to account for them.

B. The Battle Unfolds

In late 2022, the GHGP announced its plan to revise its Scope 2 accounting standards and subsequently received a $9.25 million grant from the Bezos Earth Fund. Suddenly, the battle among tech giants, which had hitherto been confined to white papers, spilled into the real world. A GHGP – sponsored “working group” was established to determine the details of the new standards.

However, some contend that the playing field was never level. A working group member, who supports an alternative “emissions first” form of Scope 2 accounting and requested anonymity to speak freely, remarks, “Our expectation was to have a platform for the exchange of ideas. But it seemed that, from the start, the direction was already pre – determined.”

C. Competing Approaches

1. The Emissions – First Camp
   – The emissions – first camp is a broad coalition. It includes the Emissions First Partnership, founded by Amazon, Meta, and Salesforce. This group posits that companies can maximize annual emission cuts by trading renewable energy certificates (RECs), even if the clean power is purchased far from the point of use.
   – It also encompasses a related approach known as “emissionality” or the “marginal emissions” method. This method aims to introduce stricter rules, ranking RECs based on their marginal emissions benefit to ensure they support new and impactful clean energy initiatives. (Emissions First declined to comment; Salesforce did not respond to a request for comment.)
2. The Hourly Accounting Method
   In contrast, Google and, to a lesser degree, Microsoft advocate for the hourly accounting method. Google’s 24/7 Carbon Free Energy by 2030 goal and Microsoft’s similar 100/100/0 by 2030 vision utilize this standard. It aims to match every hour of electricity consumption from a company’s facility (primarily data centers) with new, locally – produced carbon – free power, ultimately striving for around – the – clock clean energy.

III. The War of White Papers

Tech giants such as Amazon, Google, Meta, and Microsoft have dedicated substantial resources to promoting their respective accounting methods. According to a report by the climate nonprofit InfluenceMap, since October 2017, over 25 major studies on emissions accounting have been published. Since the GHGP Scope 2 revision process commenced in November 2022, at least 13 pieces of corporate – sponsored research have been released. Google has sponsored seven, Meta has sponsored three, Amazon has sponsored two, and Meta and Microsoft have co – sponsored one.

Despite the seemingly balanced representation in academic publishing, critics argue that there was a lack of ideological balance within the working group established by the GHGP to revise the Scope 2 accounting standards. Out of the 45 members, there is no representation from Meta, Amazon, and Salesforce. In an attempt to balance the working group’s composition, the Emissions First Partnership had to lobby the GHGP for the late inclusion of a representative from Heineken (who joined in March 2025), a member of the Emissions First Partnership.

GHGP’s director of governance, David Burns, states, “Following the close of our rolling application window in early 2025, we conducted a gap assessment to address any perceived gaps raised by the Independent Standards Board and stakeholders. Based on this review, the Independent Standards Board appointed additional members across all five Technical Working Groups in February and March 2025. While we will always consider stakeholder views sent via our formal communications channels, no company or coalition has any role in our decision – making, including appointments to technical working groups.”

Meanwhile, Google and Microsoft have direct representatives in the group, as does Energy Tag, a nonprofit that has received grant funding from Google. (Energy Tag did not respond to requests for comment.) Google, through spokesperson Mara Harris, has stated its support for “the continued development of credible metrics to estimate and credit the avoided emissions from carbon – free electricity procurement outside of a company’s carbon inventory,” which could theoretically include the marginal impact method.

IV. The “Goldilocks” Strategy and Its Aftermath

A. The “Goldilocks” Compromise

Despite concerns about the working group’s bias, it managed to progress with a “Goldilocks” strategy that incorporated both mandatory hourly matching and an emissionality method. In June, the group voted on this approach, ultimately deciding to advance both methods to the public comment stage.

B. Rejection and Reversal

Controversially, the latter part of the proposal – the emissions – first element, known as the “marginal impact method” (MIM) – was essentially rejected by the GHGP’s International Standards Board. The board stated that, despite majority support from the working group, the marginal impact method required “further foundational development” before it could proceed to public comment. This decision was made at the end of July.

However, by October, when public consultation was launched, the board seemed to reverse its decision. The hourly accounting proposal was sent to formal public comment, while the marginal emissions proposal was sent to an intermediate public comment step to inform further refinement.

The reasons for this reversal remain unclear. There was internal pressure from the Scope 2 working group. In August, nearly a dozen members of diverse ideological backgrounds signed a private letter to the International Standards Board, asking it to reconsider putting the emissions – first approach on hold and to include it for comment alongside the hourly matching provision. The letter read, “We recommend meeting in early September to ensure we have the appropriate time to respond to feedback.”

One signatory revealed that no such meeting occurred, although the GHGP did receive significant pushback through formal complaint channels regarding the suspension of the emissions – first approach. When WIRED asked the GHGP if the letter or external pressure influenced its decision to reverse the International Standards Board’s decision, the GHGP did not respond. Instead, a spokesperson for the GHGP, Alison Cinnamond, stated, “We did not move the full MIM proposal to public consultation. We did advance questions on consequential accounting that are relevant to MIM. The ISB also did not override any previous decision.”

V. An Unstable Truce?

A. Divergent Perspectives

While it might seem that both the hourly accounting advocates and the emissions – first camp have achieved some measure of success as both methodologies advanced to public comment, emissions – first advocates argue that the marginal emissions proposal sent to public comment is a “watered – down” version of what was initially proposed for the Scope 2 working group.

B. Organizational Shifts

Furthermore, the marginal emissions approach has been transferred from the Scope 2 working group to the Actions and Market Instruments working group. This group experienced a four – month hiatus in meetings between May and September this year due to the loss of two key employees and funding issues. Sources indicate that marginal impact method advocates from the Scope 2 working group were not included in either the September or October meetings, where the marginal impact method was discussed.

GHGP spokesperson Alison Cinnamond states, “The process followed was exactly as outlined in GHG Protocol’s published workplans.” She notes that the marginal impact method was not discussed at the October meeting. Cinnamond adds that the Scope 2 working group will have the opportunity to engage with the work of the Actions and Market Instruments group in the future, but “specific next steps for that engagement are still being determined.”

As a result, for many in the emissions – first camp, even if the marginal impact method is developed within the Actions and Market Instruments working group, it may not be sufficient. The mere prospect of a mandatory hourly matching requirement has led some companies, both tech and non – tech, to consider drastic measures. Multiple sources have reported rumors of disgruntled companies contemplating leaving the GHGP.

One day after the announcement of the Scope 2 public comment, a rival carbon – accounting coalition consisting of major Fortune 500 companies (including Exxon Mobil and Air Liquide), Carbon Measures, was announced. None of the corporate members listed seem to be part of the Emissions First Partnership. According to Shea Agnew, a spokesperson for Carbon Measures, the platform’s launch has been in the works for months and is unrelated to the GHGP’s activities. When asked if their companies were among those considering leaving the GHGP, both Amazon and Meta declined to comment. Sources familiar with their strategies suggest that they have no immediate plans to do so.

VI. The GHGP’s Existential Threats

A. Member Exodus Rumors

Beyond the rumors of members leaving, which endanger the GHGP’s position as a near – universal standard – setter in the carbon – accounting market, the GHGP is grappling with another existential threat: funding issues. A source with knowledge of the GHGP’s funding situation claims that the $9.25 million from the Bezos Earth Fund has been exhausted, despite the nonprofit still being listed as a current funder on the GHGP’s website. The Bezos Earth Fund did not respond to a request for comment.

B. Funding Challenges

Raising new funds has become increasingly difficult. As climate – related work in the private sector faces greater scrutiny from the Trump administration, companies are seeking more return on their investment in the GHGP. A source with in – depth knowledge of the GHGP’s funding situation remarks, “The Greenhouse Gas Protocol is undoubtedly in a financial bind. No one wants to support them because they don’t want their name associated with it, yet the GHGP depends on philanthropic and corporate funds to operate. And the direction it’s taking is not favored by many companies.”

The GHGP’s financial instability, coupled with internal unrest, has emerged at an inopportune time. Not only are regulatory regimes in the European Union and California codifying the GHGP’s standards into law, but the GHGP is also forging a new partnership with the International Organization for Standardization to further “harmonize” their respective carbon – accounting standards.