Greenhouse gas emissions – Making standard setting fit for the future

As the future of global sustainability reporting takes shape, the long-established Greenhouse Gas (GHG) Protocol looks set to play an integral role. And its decision to solicit input to understand user needs and improve the standards and guidance is timely. As examples, the draft IFRS^® Sustainability Disclosure Standards, the EU’s draft European Sustainability Reporting Standards and the US SEC’s proposed rule on climate-related risk disclosure all reference the protocol in regard to measuring GHG emissions.

This level of cross-reference underscores the importance of the GHG Protocol in measuring and reporting GHG emissions, which is in effect acting as a standard setter in this area. But to play a full part, it needs to review how its standards are created and implemented, and to ensure its governance is ready to meet the demands of these new reporting frameworks moving forwards.

For nearly 20 years, the GHG Protocol has provided companies around the world with a firm basis for measuring and reporting the GHG emissions from their operations. The Protocol’s Standards and guidance are widely recognised and universally respected, which is why they are fundamental to the three major sets of sustainability disclosure requirements that are currently pending.

As we look to the future of global sustainability reporting, there are three key objectives the Protocol’s steering group could instill now to ensure it is fit for the future:

• adopting an interdisciplinary organisational structure and robust due process that provides continued confidence in the quality of the standards and guidance;
• a principles-based approach that allows a degree of flexibility and adaptation in this fast-evolving area, which is important to the interoperability of requirements that refer to the GHG Protocol; and
• an approach to organisational boundaries that aligns or facilitates alignment with the ‘reporting entity’ concept used for financial reporting.

In addressing these objectives, we recommend active engagement with the International Sustainability Standards Board (ISSB), European Financial Reporting Advisory Group (EFRAG) and the US Securities and Exchange Commission (SEC) in addition to the scientists and engineers who will be involved from a technical measurement perspective. Essentially, the update of the GHG Protocol requires a cross-functional team.

While the GHG Protocol pioneered the accounting and reporting of emissions, formal standard setters and regulatory bodies are establishing reporting and disclosure requirements for nonfinancial sustainability information with authority. These bodies establish standards for reporting that are intended to address the information needs of investors and a broad range of stakeholders.

To maintain its role as perhaps the preeminent body issuing guidance on how to measure GHG emissions, we believe the GHG Protocol requires a governance body comprising a range of stakeholders, with a constitution process that includes transparency and allows for stakeholder input. For example, the GHG Protocol could draw inspiration from the structure and due process of the IFRS Foundation in setting IFRS Accounting Standards and now IFRS Sustainability Disclosure Standards.
 

Although an update to the GHG Protocol will undoubtedly result in improvements to the accounting and reporting of GHG emissions, inevitably users will need interpretative guidance. Currently, organisations such as the Partnership for Carbon Accounting Financials (PCAF) and the Science Based Targets initiative (SBTi) build on the GHG Protocol to develop supplementary guidance for companies.

Financial reporting standard setters use authoritative bodies tasked with interpreting the standards and developing guidance that supports the objectives of consistency and comparability between companies. For example, the IFRS Interpretations Committee is the interpretative body of the International Accounting Standards Board. An interpretations body would allow the standards to be more principles-based with supplemental guidance reacting more quickly to changing technologies and available methodologies.

Setting up this infrastructure will obviously take time; meanwhile, ongoing and active collaboration with standard setters, industry groups (e.g. PCAF) and other relevant organizations (e.g. SBTi) would be beneficial – to provide a path for preparers to align GHG measurement with climate-related disclosure requirements as they develop.

Currently, the organisational boundaries available in the GHG Protocol align with the ‘reporting entity’ concept used for financial reporting more by chance than design. As the reporting of GHG emissions starts to play a role in companies’ annual reporting in conjunction with their financial reporting, aligning the two concepts would harmonise with emerging disclosure requirements and enhance connectivity between GHG emissions inventories and financial reporting.

We recommend exploring how the approaches to organisational boundaries could be updated to facilitate alignment with financial reporting, while taking into account the needs of other stakeholders.

Of course, any discussion about governance, process and institutions shouldn’t lose sight of the ultimate goal. By agreeing a global baseline for sustainability reporting, the organisations responsible for these new requirements aim to make companies properly accountable for their environmental impacts as never before.

These companies will be required to prepare their reports with diligence and rigour. That cuts both ways. Preparers will also expect to see the same rigour from their standard setters.

The GHG Protocol has played an integral part throughout this century in providing a common base for measuring and reporting these emissions. As it prepares for the future, and the first sustainability reporting standards, it should grasp the opportunity to harmonise its processes with the standard setters, and in so doing help realise its mission to establish comprehensive standardised frameworks for emissions reporting across the world.

A version of this article previously appeared in ESG Today.