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TAC Public Meeting December 2025 Paper 5: GHGP Scope 2 Draft Due Process Summary
Executive summary
| Date | 9 December 2025 |
| Paper reference | 2025-TAC-055 |
| Project | GHG Protocol Revisions |
| Topic | Draft due process summary |
Objective of the paper
This paper presents a brief summary of the due process followed in the development of the TAC's comment letter and responses to the online survey regarding the GHG Protocol's proposed revisions to the Scope 2 Guidance.
Decisions for the TAC
The TAC is asked whether it has any comments on, and whether it tentatively approves, the due process summary.
Appendices
Appendix – Draft due process summary
Due process summary
1The TAC's Due Process Policy (DPP)1 states that the TAC would usually publish a due process summary for its work developing comment letters. The due process summary should include a conclusion on whether the development of the comment letter complied with the TAC's Due Process Policy, along with an explanation of any noncompliance.
2This due process summary concerns the TAC's project, ‘GHG Protocol Revisions', which thus far has been included producing a comment letter and response to the online survey regarding the GHG Protocol's proposed revisions to the Scope 2 Guidance.
3A draft due process summary is tabled alongside the TAC's draft final comment letter for discussion and tentative approval in this meeting.
4The appendix includes a copy of the draft due process summary.
Next steps
5The final due process summary will be tabled at a future meeting for discussion and approval.
Questions for the TAC
- Does the TAC have any comments on the due process summary in the appendix?
- Does the TAC tentatively approve the due process summary?
Appendix – Due process summary for 'GHG Protocol Revisions'
Project initiation
| Due process tasks | Status | Comments |
|---|---|---|
| A project management plan, including target timeline, is prepared and approved by the TAC. The project management plan is published on the FRC website. | Expected | The project management plan was published (Paper 2025-TAC-051) and approved by a public meeting on 11 November 2025. It is available on the FRC website via the above link. |
Project delivery, including performing technical analysis
| Due process tasks | Status | Comments |
|---|---|---|
| The TAC, and FRC as TAC Secretariat, undertake outreach with UK stakeholders. | Expected | The FRC as TAC Secretariat undertook outreach with UK stakeholders by identifying key stakeholders and engaging with them via interviews. Stakeholders reached included preparers, academics, assurers and industry bodies (representing preparers and users). |
| A draft comment letter with an invitation to comment is prepared, approved by the TAC and published on the FRC website. | Optional | The TAC decided to undertake a proportionate approach to its consultation response based on time available, which was initially only 60 days. Therefore, it decided not to undertake a public consultation. The TAC undertook targeted outreach with UK stakeholders instead. |
| Research activities are reviewed and noted by the TAC. | Optional | The TAC Secretariat's research activities included:
|
| A final comment letter is prepared and approved by the TAC. | Mandatory | The TAC is asked whether it has any comments on and approves the comment letter and survey responses in Paper 2025-TAC-054. |
| The final comment letter is submitted to the ISSB or other consultative body and published on the FRC website. | Mandatory | The final comment letter will be submitted to the GHG Protocol once it has been approved and it will also be published on the FRC website. |
| A stakeholder feedback summary is prepared and approved by the TAC. The stakeholder feedback summary is published on the FRC website. | Expected if a draft comment letter has been published for consultation | Although the TAC decided not to undertake a public consultation on the draft comment letters, a summary of stakeholder feedback from the roundtable, survey and one-to-one interviews has been published as part of Paper 2025-TAC-054 for the 9 December TAC meeting. |
Project closure
| Due process tasks | Status | Comments |
|---|---|---|
| A due process summary is prepared and approved by the TAC. The due process summary is published on the FRC website. | Expected | The TAC is asked whether it has any comments on and tentatively approves the draft due process summary. The final due process summary will be tabled at a future meeting. |
| A lessons learnt exercise is performed by the TAC. | Optional | The TAC will not undertake a lessons learnt exercise for this project but may reflect on this project for future consultations issued by the GHG Protocol. |
TAC meetings
| Due process tasks | Status | Comments |
|---|---|---|
There are a number of requirements in the TAC's ToR relating to meetings, including that:
|
Mandatory | The project was discussed in the public meeting held on 11 November 2025 and will be discussed in the 9 December 2025 meeting.As of 25 November 2025 (the date of preparing this draft summary), the meetings have complied with due process.Meetings agendas, technical papers, summaries and recordings, are available on the FRC website. All agendas, papers and recordings were published within the timeframe specified by the TAC's Terms of Reference. |
Conclusion
As at 25 November 2025, the development of the comment letter has complied with due process.
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.
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The TAC's DPP is available at: https://www.frc.org.uk/library/external-groups/uk-sustainability-disclosure-tac/uk-sustainability-disclosure-tac-terms-of-reference/ ↩