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      A series of developments across the GHG Protocol, the Science Based Targets initiative and ISO is raising expectations for how organisations measure emissions, substantiate climate claims and demonstrate progress.

      The direction of travel is clear: credible climate performance will increasingly depend not only on the emissions reduction target an organisation sets, but on the integrity of the data, systems and decisions behind it.

      Shane O'Reilly

      Managing Director, ESG Strategy & Transition Planning Lead

      KPMG in Ireland


      GHG accounting is moving into mainstream business

      For many organisations, greenhouse gas (GHG) accounting began as a contained sustainability exercise: establish a baseline, calculate annual emissions and report the results in a sustainability report. That model is now changing.

      GHG emissions (their increase, reduction, intensity, etc.) have become the de facto proxy data for stakeholders throughout their value chain to evaluate the sustainability performance of a corporate. GHG emissions data is now used not just to educate stakeholders, but also to make decisions: on sourcing raw materials, to considering future tax liabilities and sustainability-linked financial instruments, corporates have realised the importance of collecting and disclosing verifiable, comparable, timely and understandable GHG emissions data.

      Recent updates to the GHG Protocol, the publication of the Science Based Targets Initiative (SBTi) Corporate Net-Zero Standard Version 2.0 and the development of ISO 14060 (Net Zero Aligned Organisations) collectively point towards a more demanding approach.

      The direction of travel points towards more complete emissions inventories, greater transparency over data quality, and stronger governance.

      Furthermore, the standards require clearer evidence over how GHG emissions reduction targets are supported by practical delivery plans.



      Scope 2: From flexibility to greater precision

      The GHG Protocol’s proposed Scope 2 updates represent a potential shift in how companies account for GHG emissions of purchased electricity. Based on the public consultation, which ran from October 2025 to January 2026, the new requirement will retain both the location-based and market-based reporting methods, but with more exacting requirements for the data and contractual instruments underpinning them.

      Under the proposed changes, the location-based method would place greater emphasis on using the most precise and relevant local grid emissions factor available, such as a regional grid factor instead of a national average where it better reflects actual electricity consumption.

      Key changes to the market-based method include: matching energy attribute certificates with electricity consumption on a more granular time basis (e.g. every hour) and demonstrating that electricity represented by those certificates could physically be delivered to the location where it is consumed.


      What may change

      Why it matters for Irish businesses

      More granular consumption data and tighter evidence requirements for market instruments.Existing meter data, supplier statements, Guarantees of Origin or renewable contracts may not provide all information needed under a revised framework.

      The practical implications could be significant; sustainability and energy-procurement teams may need to work more closely as a renewable electricity arrangement that supports a market-based claim under the current rules may not provide all the evidence required under the revised framework.

      The final Scope 2 Standard is expected to be released in Q4 of 2027, meaning that for Irish businesses, the immediate priority is not to renegotiate electricity contracts based on draft proposals, but to understand exposure to forthcoming changes.

      Organisations should determine what electricity-consumption data they currently hold, how they can evidence renewable electricity claims and whether energy procurement decisions can be traced through to the Scope 2 inventory.



      Scope 3 revisions: Phase 1 progress update

      In March 2026, the GHG Protocol published its Scope 3 Standard Revisions Phase 1 Progress Update. Importantly, this is not a final standard and is not itself a consultation draft and It remains subject to change.

      However, the progress update provides a useful indication of the areas under consideration: data quality; inventory boundary; investments; and a possible new category for value-chain activities not captured by the current 15 categories.


      Increased transparency over data quality


      One of the clearest themes is increased transparency over data quality. The proposals would make the composition of a Scope 3 inventory more visible by requiring emissions to be disaggregated by data type (e.g. indicating what GHG emissions are calculated based on primary and on secondary data).

      This would allow users to distinguish emissions calculated using more specific data from those based on spend, economic proxies or other secondary sources.

      The progress update also considers clearer disclosure of verification status, meaning that companies aiming to verify their Scope 3 emissions, will need to publicly disclose the type of verification applied to their emissions profile (e.g., Fully verified, partially verified, not verified).


      What this means: By disaggregating data by type, stakeholders will be better able to make informed judgements about the completeness and accuracy of GHG emissions data.


      Spend-based methods remain valuable for establishing a baseline and identifying hotspots, especially where primary data are unavailable.

      However, they are affected by factors such as inflation, currency movements and broad sector averages, which may result in them under- or over-reporting actual GHG emissions.


      Inventory boundary and completeness


      Proposed changes to setting the inventory boundary are also aimed at enhancing the completeness of published data. The Phase 1 update considers a quantitative approach under which companies would report at least 95% of required Scope 3 emissions, rather than relying solely on qualitative explanations for exclusions.

      It also proposes clearer separation of required and optional emissions.


      Supplier engagement moves higher up the agenda


      This proposal places supplier engagement firmly on the agenda for Irish businesses.

      Organisations should apply a practical approach: use the current inventory to identify material hotspots, and focus engagement on the suppliers and categories that matter most.

      This way organisations can improve data quality over successive reporting cycles, one supplier or category at a time. Non-financial reporting teams will have to work with procurement specialists to engage suppliers as well as to help them improve the availability and sharing of GHG emissions data.


      Investments


      The proposals concerning investments are also relevant beyond the financial sector.

      Irish organisations with subsidiaries, joint ventures, minority holdings, pension-related structures or other investments should assess whether their current screening captures all potentially relevant activities.


      Key proposal: Under the proposed revisions, Category 15 is divided into 11 investment subcategories, accompanied by enhanced methodological guidance aligned with the Partnership for Carbon Accounting Financials (PCAF) standard for financed emissions.



      SBTi Version 2.0: From ambition to implementation

      Published in June 2026, the SBTi Corporate Net-Zero Standard Version 2.0 places a stronger focus on implementation, progress and the actions companies take to deliver their net zero GHG emissions targets.

      The new standard, furthermore, differentiates requirements based on business size and operational context (e.g. geography and industry).

      The pivotal change in the SBTi standard is that target setting is now treated as the beginning of the process of decarbonisation rather than its conclusion. Governance arrangements, transition planning, progress reporting and implementation barriers now sit more prominently within the framework.

      Companies are expected to identify and use available decarbonisation levers, prioritising action close to the GHG emissions source before relying on less direct interventions, to substantiate progress towards their GHG emissions targets.

      For Irish companies using, renewing or considering SBTi targets, the implications extend well beyond the sustainability team: a credible transition plan must connect emissions targets with operational decisions, investment priorities, procurement, technology, research and development, and the organisation’s wider strategy. 



      ISO 14060: A developing framework for credible net-zero alignment

      ISO 14060 is currently at DIS (Draft International Standard) stage and undergoing public consultation since June 2026.

      The new ISO standard as it stands aims to establish requirements through which organisations can demonstrate that their net-zero strategies, targets and progress are credible, verifiable and aligned with the Paris Agreement.

      In line with the new SBTi standard, the draft ISO 14060 places transition planning at the centre of organisational net-zero alignment, and to provide a structured basis for targets, delivery, monitoring and verification.

      To reflect the position of each organisation on the journey to net zero, the draft ISO 14060 proposes progressive claims that distinguish between starting a net-zero journey, establishing an aligned transition plan, demonstrating progress and achieving net zero.

      The new ISO standard is relevant for Irish organisations irrespective of existing or planned certification. ISO reinforces the wider convergence around credible transition plans, deep emissions reductions, transparent use of removals and independently verifiable progress.

      Companies should monitor the standard as it moves through the ISO process, while recognising that its requirements may change before final publication.


      What should Irish businesses do now?

      The standards are at different stages: SBTi Version 2.0 has been published, while the Scope 2 changes, Scope 3 proposals and draft ISO 14060 remain subject to further development.

      Irish organisations should plan for a future state in mind where the potential changes listed above could be a reality and explore what this means for their business, customers and suppliers alike. We would suggest the following:


      Priority action

      Practical focus

      Assess the current GHG inventory

      Review organisational and operational boundaries, exclusions, calculation methodologies and potential duplication between categories.

      Map data quality by emissions source

      Record where calculations use primary, supplier-specific, activity, average or spend-based information; identify material gaps.

      Review electricity data and procurement evidence

      Understand what meter data, contractual instruments and certificate information are available for each material site.

      Prioritise supplier and investee engagement

      Focus first on material emissions hotspots and integrate emissions considerations into existing relationship-management processes.

      Connect targets to business decisions

      Translate climate targets into a transition plan with named owners, milestones, dependencies and links to budgets and capital allocation.


      Take the opportunity to prepare

      The current wave of change is not simply adding more disclosure; it is changing what credible GHG emissions is expected to represent.

      Irish organisations have the opportunity to move from fragmented annual calculations towards a controlled, repeatable and decision-useful carbon accounting process before the updates to the GHG Protocol and the ISO 14060 standard are finalised.

      Furthermore, organisations that understand their emissions in sufficient depth will be better placed to manage climate transition risks, respond to customers and investors, make informed procurement and capital decisions, and support climate claims with evidence.


      The organisations that prepare early will not necessarily be those with perfect data today.

      They will be those that understand their gaps, prioritise improvements and build the governance and systems needed to turn carbon accounting into business action.


      Contact our team

      Shane O'Reilly

      Managing Director, ESG Strategy & Transition Planning Lead

      KPMG in Ireland

      Anikó Kraft

      Associate Director, ESG Strategy & Transition Planning

      KPMG in Ireland

      Yazan Najy

      Senior Consultant

      KPMG in Ireland


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