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TAC Public Meeting March 2026 Paper 3 GHGP Scope 2 Draft Due Process Summary
Executive summary
| Key | Value |
|---|---|
| Date | 24 March 2026 |
| Paper reference | 2026-TAC-004 |
| Project | GHG Protocol Revisions |
| Topic | 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 its Scope 2 Guidance.
Decisions for the TAC
The TAC is asked to approve the due process summary.
Appendices
- Appendix: Due process summary
Context
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 included producing a comment letter and response to the online survey regarding the GHG Protocol's proposed revisions to its Scope 2 Guidance.
3The appendix includes a copy of the due process summary.
Questions for the TAC
- Does the TAC have any comments on the due process summary in the appendix?
- Does the TAC approve the due process summary?
Appendix: Due process summary for 'GHG Protocol Revisions: Scope 2 guidance'
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 at a public meeting on 11 November 2025. It is available on the FRC website via the above link. The project plan and timeline were based on the initial timelines set by the GHG Protocol, but these were extended during the consultation period. The TAC's timeline was therefore also extended to January 2026. |
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 put out a draft letter for public comment. 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 approved, subject to amendments, the final comment letter and online survey responses in its meeting on 19 January 2026 (Paper 2026-TAC-001). |
| The final comment letter is submitted to the ISSB or other consultative body and published on the FRC website. | Mandatory | The responses were uploaded onto the GHG Protocol's online survey, and a letter was submitted once approved by the Chair. The final letter has been 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 put out the draft comment letter for public comment, a summary of stakeholder feedback from the one-to-one interviews was published as part of Paper 2025-TAC-054 for the 9 December 2025 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 tentatively approved the draft due process summary in the 9 December 2025 meeting. [The final due process summary, this paper, was tabled for approval at the 24 March 2026 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 meetings held on 11 November 2025, 9 December 2025 and 19 January 2026. As of 12 March 2026 (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 of 12 March 2026, 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.
-
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/ ↩