Scope 2 emissions – is your reporting complete?

Whether you are reporting your emissions to comply with the mandatory framework or making voluntary disclosures, if you are an organisation operating in New Zealand and stating compliance with the GHG Protocol Standards, your Scope 2 emissions from purchased energy should be reported under both the location-based and market-based methods - dual reporting.

This is because the GHG Protocol Standard Scope 2 Guidance requires that if you are operating in a region where product or supplier-specific data is accessible, then you must report both location-based and market-based Scope 2 emissions. 

From a review of published FY23 climate reports, 8 reports stated GHG emissions were prepared in accordance with the GHG Protocol Corporate Standard, and only 1 out of the 8 reports disclosed Scope 2 emissions under the market-based method.

Dual reporting is required even if you have not entered into any energy-related contractual instruments. This means that even if your entity has not purchased energy attribute certificates, or specific renewable energy, you should still be reporting Scope 2 emissions under the market-based method. In our view, this also aligns with the objective of reporting the impact of an entity’s purchasing decisions.

Not necessarily. The guidance requires you to use a residual mix factor in the first instance if there is one available. Only if a residual mix factor is not available would you use the location-based method emissions factor, which can be sourced from the Measuring Emissions Guide published by the Ministry of Environment. 

The residual mix factor is typically higher than the location-based grid-average emission factor because it excludes renewably generated electricity sold under contractual instruments like RECs and represents the mix of electricity that remains. Hence, this typically leads to higher Scope 2 emissions reported under the market-based method. But this is expected as the market-based method reflects an entity’s purchasing decisions. In New Zealand, there is a residual mix factor publicly available for use.

Since residual mix factors are available for use in New Zealand, we believe that entities should be using these to report market-based Scope 2 emissions even if they have not purchased renewable energy certificates or similar. 


In our latest GHG Emissions Reporting Brief, we illustrate what dual reporting would look like for organisations who haven’t entered into any energy-related contractual instruments using a residual mix factor that is available for use in New Zealand.


Get in touch with Melinda Ponnampalam, our GHG Emissions Accounting Centre of Excellence Lead on ghgaccounting@kpmg.co.nz to learn more about how our team can help you with your GHG emissions reporting.

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