Greenhouse Gas Protocol is surveying stakeholders on the need for updates or additional guidance related to GHG Protocol’s reporting standards. IEMA members attended a workshop during which this was debated and IEMA has submitted the findings to GHG Protocol. In this blog, Chloë Fiddy, IEMA’s Policy and Engagement lead on climate change and energy matters, reports on the key issues that IEMA members raised.

The workshop concluded that while the GHG Protocol has a solid foundation, improvements are needed to streamline the process and provide clarity to make it more accessible, prescriptive, and consistent.

One of the main areas for improvement is the length and complexity of the guidance. Complexity can lead to inconsistent and unrepeatable reporting which in turn undermines the reported outcomes, so overall, a more concise and prescriptive approach would improve the guidance.

Simple suggestions for clarifying the guidance include (in no particular order):

  • Reducing the jargon and summarizing instructions
  • Providing a list of examples for categorising out-of-scope emissions
  • Providing worked examples and case studies
  • Creating a special guide and reporting standard for SMEs, in acknowledgment of the fact that SMEs are increasingly being required to report on their GHG emissions to secure access to supply chains.
  • How to treat working from home

Other matters which will require more detailed debate and international agreement include:

  • Sector-specific guidance, noting that many sectors are writing their own guidance
  • Defining and clarifying control within joint ventures
  • Defining and clarifying control for arrangements such as facilities management where ownership of data and control can be blurred
  • Guidance for outsourced projects
  • Stratifying sample types by typology
  • Accounting for embodied carbon
  • Providing guidance (and possibly restrictions) on Scope 4 value chain emissions
  • Clarity on treatment of market-based and location-based emissions, to avoid the risks of double or under-counting and greenwashing

Developing these more nuanced matters should not escape rigorous debate and clarity of output. As recognised by GHG Protocol, GHG accounting is increasingly being used as the foundation for transition planning. In turn, transition planning is intended to inform financial decision making. As the basis of investment-grade data, GHG accounting must be as rigorous as financial accounting, leaving no space for grey areas.

Photo of Chloe 033
Chloë Fiddy

Policy and Engagement Lead

Chloë is the Policy and Engagement Lead for Climate Change and Energy and Social Sustainability at IEMA. Within this remit she works on projects relating to greenhouse gas reporting and transition planning and reporting, including adaptation, as well as social sustainability and just transition issues. She is particularly interested in finding practical solutions and approaches which lead to standardised, replicable and trustworthy reporting, so that decision-makers have better data to work with. Previously Chloë has worked at senior levels in the manufacturing and retail sectors, and in climate and sustainable development planning roles in the public sector.

Her prior business experience and her understanding of the way that the public sector functions inform her approach to climate change and energy and social sustainability policy and engagement at IEMA. She is a Trustee on the board of Uttlesford Citizens Advice and a District Councillor and is active in her community. In her spare time she enjoys live music and cooking for family and friends.


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