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TAC Public Meeting November 2025 Paper 7: GHG Scope 2 Project management plan and timeline
AGENDA PAPER 7
Executive summary
| Date | 11 November 2025 |
| Paper reference | 2025-TAC-051 |
| Project | GHG Protocol Revisions |
| Topic | Scope 2 Guidance consultation – project management plan and timeline |
| Objective of the paper | This paper presents the proposed project management plan and assessment approach to guide TAC's review and response to the two consultations issued by the GHG Protocol in October 2025. |
Decisions for the TAC
The TAC is asked to approve the project management plan and assessment approach.
Appendices
There are no appendices to this paper.
Context
1In 2024, the GHG Protocol started the process of updating the GHG Protocol Corporate Standard (2004) and its supporting documents including the Scope 2 Guidance (2015). Between November 2022 and March 2023, the public were invited to provide feedback on the current suite of materials. Based on this feedback the GHG Protocol and its technical working groups have been developing proposals to amend and update the GHG Protocol's suite of corporate standards and guidance (referred to as the GHG Protocol's materials).
2It is expected that the GHG Protocol will release a number of consultations in 2026 as it prepares to finalise the revisions to its suite of materials in 2027. The TAC will consider each consultation as part of a wider project on the GHG Protocol revisions. The initial part of this project is to consider the first two consultations released by the GHG Protocol.
3The TAC has been requested by DBT to consider providing feedback to the GHG Protocol on its consultations and proposed revisions to its materials, especially as they relate to the implementation of UK SRS S2. The GHG Protocol's materials are widely used by the market to calculate GHG emissions, and they are referenced in IFRS S2/UK SRS S2 and the UK's Environmental Reporting Guidelines which provide guidance for the disclosure of GHG emissions in accordance with the Streamlined Energy and Carbon Reporting (SECR) regulations.
4Given the references to the GHG Protocol's materials and its current use in the market, it is considered appropriate for the TAC to provide a response to the consultations. However, the TAC needs to consider how it can appropriately respond given the technical nature and length of consultation periods set by the GHG Protocol.
Project overview
5On 20 October 2025, the GHG Protocol released two consultations on the revisions to the Scope 2 Guidance (2015) and a request for feedback on consequential accounting methods for estimating avoided emissions from electricity-sector actions. Both consultations are open for a 60-day public consultation with the deadline for responses by 19 December 2025.
6In the context of the TAC's remit, the objective of this project is to provide a proportionate review and response to the GHG Protocol consultations. The project will involve an analysis of proposed changes and preparation of the TAC's response.
7When preparing a formal response to a consultation, the TAC is expected to follow its Due Process Policy which requires the TAC to undertake outreach with UK stakeholders. Given the short timeframe and the technical nature of the consultations the Secretariat believes that suitable stakeholder engagement is likely to be challenging. However, the Secretariat will seek to conduct bilateral interviews with UK companies and GHG reporting experts to obtain as much feedback as possible.
8The TAC's process for preparing the comment letters will include the following stages:
| Project stage | Description | Due Process Policy | Indicative timeline |
|---|---|---|---|
| Project initiation: present project management plan and assessment approach | * This paper, presented for November 2025 TAC meeting | Due Process Policy Paragraphs 29–30 | Published 4 November |
| Project initiation: approve project management plan and assessment approach | * TAC discussion on this paper in November 2025 TAC meeting | Due Process Policy Paragraphs 29–30 | 11 November TAC meeting |
| Project delivery: Initial technical assessment | * Paper 2025-TAC-052 (Agenda Paper 8), prepared by the Secretariat and presented for November 2025 TAC meeting | Due Process Policy Paragraph 31 | Published 4 November |
| Project delivery: discussion of initial technical assessment | * TAC discussion on Paper 2025-TAC-052 (Agenda Paper 8), in November 2025 TAC meeting | Due Process Policy Paragraph 31 | 11 November TAC meeting |
| Project delivery: Stakeholder outreach and analysis | * Carried out by the Secretariat * Identify key stakeholders and engage via interviews |
Due Process Policy Paragraph 31 | To be completed by end of November |
| Project delivery: Prepare analysis of stakeholder engagement findings for the TAC | * Prepared by the Secretariat * Analysis presented for December 2025 TAC meeting |
Due Process Policy Paragraph 31 | Published 2 December |
| Project delivery: discussion of findings of stakeholder engagement | * TAC discussion on Secretariat's analysis in December 2025 meeting | Due Process Policy Paragraph 31 | 9 December TAC meeting |
| Project delivery: Prepare draft response | * Prepared by the Secretariat * Drafts presented for December 2025 TAC meeting |
Due Process Policy Paragraph 31 | Published 2 December |
| Project delivery: discussion and approval of response | * TAC discussion and approval of draft response prepared by Secretariat in December 2025 meeting | Due Process Policy Paragraph 31 | 9 December TAC meeting |
| Project closure: draft due process summary | * Prepared by the Secretariat * Drafts presented at December 2025 TAC meeting |
Due Process Policy Paragraphs 37–40 | Published 2 December |
| Project closure: review due process summary | * TAC discusses draft due process summary | Due Process Policy Paragraphs 37–40 | 9 December TAC meeting |
| Project delivery: TAC submits comment letters | * Subject to any edits agreed in the December 2025 TAC meeting, the Secretariat will submit the approved responses to the GHG Protocol * Secretariat will publish the responses on the FRC website |
Due Process Policy Paragraph 31 | By 19 December |
| Project closure | * Due Process summary approved by the TAC in January 2026 meeting * Summary published on the FRC website |
Due Process Policy Paragraphs 37–40 | Draft published January Approved January TAC meeting |
Assessment approach
9Considering the scope and technical complexity of the proposed changes in the consultation documents, the TAC is asked how to approach its response.
10The technical assessment of the proposed revisions will only consider the implications of these revisions to the implementation of UK SRS S2. In some cases, the proposed revisions and the consultation questions require deep technical knowledge of GHG accounting methodologies and therefore might not be appropriate for the TAC to comment on. The Secretariat recommends that the TAC does not answer specific technical questions but instead provides general feedback to the GHG Protocol. Depending on the views provided by UK stakeholders the TAC could focus its response on the feasibility and cost-benefit of the proposals.
11However, the GHG Protocol has stated in the consultation documentation that it will only accept views shared using the online form. This means that it may not take into consideration a formal letter. This presents a potential challenge as the online form is inflexible and mostly asks closed questions with specific options. The TAC should consider the most appropriate way to respond to this consultation.
11.1Option 1 – respond to select specific questions in the online form 11.2Option 2 – prepare a formal comment letter to be sent to the GHG Protocol and published on the FRC website 11.3Option 3 – respond to specific questions in the online form and attach these to a formal letter which will be sent to the GHG Protocol and published on the FRC website
Questions for the TAC
- Does the TAC have any comments on the proposed assessment approach?
- Does the TAC agree to provide general feedback to the GHG Protocol rather than comment on specific questions?
- In regard to how the TAC will respond to the consultation, which option would the TAC like to take?
Assumptions, constraints and risks
12When developing the project management plan, the Secretariat has taken into consideration the following assumptions and constraints:
- The consultation is only open for 60 days, which means that the TAC will only be able to discuss its response in two public meetings. This short timeline also limits the amount of stakeholder engagement that can be completed.
- The capacity of the TAC, including agenda capacity and recognition that the TAC members are volunteers. Since the TAC members are volunteers, there is a limited amount of work that they can be expected to complete in the time allocated.
- The capacity of the TAC Secretariat. The Secretariat will be expected to write papers for public TAC meetings in addition to conducting research and stakeholder engagement to inform the final comment letters. The expected available resources are 1.5 FTE project directors and oversight from the Head of the Secretariat.
- The availability of suitable stakeholders to engage with in the time allocated. The proposals in the consultations are very technical and therefore we will need to focus on engaging with specialists who might be difficult to identify and liaise with in the short timeframe.
- This is the first time that the TAC and Secretariat will be engaging with the GHG Protocol's update process. The TAC and Secretariat might not have the knowledge or skills to be able to provide detailed feedback, and if stakeholder engagement is not possible, then the TAC might not have an adequate knowledge base to fully respond to the consultations.
Project management plans and target timeline
13Both GHG Protocol consultations have a 60-day comment period with a deadline for responses by the 19 December 2025. Therefore, the TAC will need to approve the responses at its December meeting which is currently scheduled for the 9 December 2025.
14Considering the resource capacity, the project does not include conducting a public consultation in the UK on a draft comment letter. Instead, the Secretariat will carry out stakeholder engagement through bilateral interviews.
15The timeline for the project is presented below. However, the timeline does not take into consideration the assumptions, constraints and risks that are uncertain. Given the GHG Protocol's deadline and the dates of the TAC meetings, no further adjustment can be made to the project timeline.
This timeline illustrates the project management plan and key milestones for the consultation process.
- Consultation commences: 20 October
- Public meeting (11 November): Focuses on project initiation (project management plan) and project delivery (initial technical assessment).
- Public meeting (9 December): Focuses on project delivery (approve comment letter).
- Deadline for comment letter: 19 December
The timeline progresses from October 2025 through November 2025 to December 2025, encompassing stages of Technical analysis, Stakeholder engagement, and Preparing the TAC response.
Questions for the TAC
- Does the TAC have any comments on the assumptions, constraints and risks?
- Does the TAC approve the project management plan?
This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) to discuss in a public meeting. This paper does not represent the views of the TAC or any individual TAC member.