The 2026 edition of “ZeroedIn: The Brand Marketing Pulse” is now live.

GHG Protocol Important Update September 2026:

Multi-Statement Framework and Market Instruments Get Public Approval.

What a Multi-Statement Framework Could Mean for Corporate Reporters

On 23 September 2026 the GHG Protocol published its summary of responses to the Actions and Market Instruments (AMI) Request for Information. The consultation asked for views on the AMI Phase 1 white paper, that would change how companies report under the Corporate Standard. The results will feed into a draft consolidated Corporate Standard, which is due for public consultation in Q2 2027. Final publication is planned for Q4 2028.

The Proposal

Today, a GHG Protocol inventory is a single physical account of Scope 1, 2 and 3 emissions. The AMI proposal would keep that inventory and add up to three statements alongside it:

  • Market-based GHG inventory: this would report contractual arrangements, certificates and environmental attributes across all three scopes. It would extend the logic of Scope 2 market-based reporting to Scope 1 and Scope 3.
  • GHG impact statement: this would use consequential accounting to report the real-world effect of a company’s actions inside and outside its value chain. That covers emissions avoided, reduced or removed, including impacts of sold products.
  • Non-GHG indicators: this would cover transition metrics that aren’t expressed in CO2e, such as low-carbon capex or procurement volumes.

What Respondents Said

Support for the overall structure was strong. 84% of respondents supported or strongly supported it, and that held across regions, company sizes and organisation types. 

  • The market-based inventory had 87% saying it should be included. 
  • The GHG impact statement followed at 80%. 
  • Non-GHG indicators split opinion: Only 33% backed inclusion, 44% were neutral or unsure, and the rest opposed it. Many respondents felt this area is already covered by frameworks such as ISSB, ESRS and CDP.

Support came with conditions. Respondents repeatedly asked for four things. 

  1. The physical inventory kept as the anchor. 
  2. Clear boundaries for each statement. 
  3. Safeguards against double counting and double claiming. 
  4. Firm ban on netting results from one statement against another.

What This Could Mean for Corporates

The physical inventory stays central to the standard. The physical inventory will remain the fundamental and mandatory basis for reporting emissions. The new statements would be in addition to location-based emissions accounting.

The new statements are likely to be optional at first. Following requests for phased and tiered implementation, the GHG Protocol expects the new statements ‘to remain optional for the foreseeable future’. That’s helpful for SMEs and less mature reporters for whom it could be an extra burden. Investors, customers and target-setting bodies may still come to expect them from larger companies.

Market instruments to be reported in their own statement. Under the current Corporate Standard, companies can’t use certificates to reduce their Scope 3 emissions at all (although SBTi allows sustainable aviation fuel (SAF) certificates to count against targets). Purchases of SAF certificates, low-carbon steel or other book-and-claim or mass-balance products don’t appear anywhere in the current standard. 

A market-based statement would give these scope 3 instruments a place to be reported. But it could also encourage companies to spend on certificates when that money would do more good invested in real reductions across their own operations and value chain. Respondents made clear that any market-based reporting would depend on strict evidence: eligibility criteria, registry controls, unique identifiers, retirement records and residual emission factors. 

Already buying low carbon certificates? If you’re buying these instruments now, keeping full contractual and registry documentation would put you in a stronger position.

How much benefit will this be to global heating? Having somewhere to report an instrument doesn’t prove it has a real-world benefit, and biofuels show the risks most clearly. Biofuel carbon accounting assumes that the CO2 released when the fuel is burned was absorbed by plants as they grew, so the CO2 released doesn’t get included in the main inventory (instead it’s reported as outside of scope – but rarely do companies do this). It relies on the crops grown to be ‘additional’ – meaning they wouldn’t have been grown unless needed for biofuel. 

The problems with SAF and biofuels. That assumption doesn’t hold up well against how supply actually works. There isn’t enough SAF to meet demand, and waste-derived fuels are especially scarce. That pushes production onto crops grown on land that would otherwise produce food. There are also reports of virgin forest being cleared, for example in Canada, to make wood pellets for biomass power stations that are then described as timber industry residues. In some regions, indigenous communities have been pushed off their land so it can be used for biofuel crops, food production or projects that generate carbon credits. So adding the need to grow biofuel crops to the queue of land uses will lead to more land clearance, and help force up emissions.

Checks and balances with certificates.Respondents asked that market-based instruments shouldn’t be presented as evidence of real-world reductions unless that impact is shown separately, and that the GHG impact statement should capture negative effects such as leakage and displacement. For companies buying biofuel certificates, that could mean checking where the feedstock comes from, what land it’s grown on and who’s affected, as well as the certificate paperwork.

Impact claims would face tighter scrutiny. The majority of respondents agreed that negative impacts, such as rebound or leakage, should be reported alongside positive ones. Many asked for transparent baselines, uncertainty disclosure and conservative assumptions. 

Netting certificates off emissions not allowed. Across every section, respondents rejected any approach that lets a company subtract contractual or impact figures from its physical emissions.

How the statements are used would be decided elsewhere. The GHG Protocol intends to stay policy neutral. It would define the accounting, and bodies such as SBTi, regulators and disclosure frameworks would decide what counts towards targets or compliance. SBTi, ISO and EFRAG sit on the technical working group, so alignment is intended. Even so, companies would need to track how each programme adopts the statements.

Next Steps for Reporters

It is a good time to take stock of the market instruments and supplier interventions you could make use of in 2028.

If you already gather supplier data, you could start using suppliers’ RECs against supplier electricity supplies, so that as suppliers reduce emissions, your market-based scope 3 inventory follows suit. But bear in mind it’s likely there will be a location-based only mandatory inventory at the core, akin to the SBTi’s Net Zero Standard V2.0, which goes live 1st February 2027 and becomes mandatory 1st February 2028.

The Q2 2027 consultation will be the main opportunity to comment on the actual requirements, and it’s worth planning to respond.

Emma Littlewood, Director of Policy and Research, 51toCarbonZero

Sustainability Made Simple.