Stay ahead of compliance Part 2: Understanding the GHG Protocol's action and market instruments standard

In Part 1, we covered Scope 2 revisions of the Greenhouse Gas Protocol. However, the Action and Market Instruments Standard (AMI) promises a bigger shift to multi-statement reporting, allowing companies to report climate actions that fall outside traditional inventories. The AMI Standard will allow companies to clearly communicate the full scope of their decarbonization efforts – both within and beyond their operational boundaries. As part of this process, the GHG Protocol has launched its AMI Request for Information. The RFI will be open until 31 May 2026. The stakeholder feedback provided will help to draft a public consultation currently planned for Q3 2027. The White Paper summarizing the current progress of the AMI Standard Development Process can be found here: https://ghgprotocol.org/sites/default/files/2026-03/AMI-Phase1-WhitePaper-RFI.pdf. It provides stakeholders with information on key topics and developments.

Background

The Greenhouse Gas (GHG) Protocol is a comprehensive global standardized framework for emissions accounting. It sets the emission calculation method and scope description. It is used by various reporting standards as reference (RE100, SBTi, ISO 50 001, etc.). The GHG Protocol has developed several key standards that work together to provide a comprehensive approach to corporate GHG accounting and reporting:

• The GHG Protocol Corporate Standard establishes requirements and guidance for companies to account for and report on their Scope 1, Scope 2, and Scope 3 emissions. It serves as the foundation for corporate GHG accounting.
• The Scope 2 Guidance provides additional requirements and guidance for accounting and reporting on Scope 2 (purchased electricity) emissions using both location-based and market-based methods.
• The Corporate Value Chain (Scope 3) Standard helps companies account for and report on their indirect (Scope 3) emissions across the value chain.
• The GHG Protocol for Project Accounting provides requirements and guidance for quantifying the GHG reductions from specific mitigation projects.
• The GHG Protocol Product Standard (also known as the Product Life Cycle Accounting and Reporting Standard) offers an approach to quantify GHG emissions and removals attributed to the unit of analysis of a product throughout its life cycle. It aims to harmonize organizational – and product-level – GHG reporting, especially for Scope 3 categories
• The Land Sector and Removals (LSR) Standard sets requirements and recommendations for corporate GHG accounting for emissions and carbon removals from agricultural and land use activities

The GHG Protocol standards are regularly revised and updated to reflect the evolving needs of the corporate sustainability landscape. The ongoing development of the Actions and Market Instruments (AMI) Standard is the latest example of the GHG Protocol's efforts to enhance the comprehensiveness and integrity of corporate GHG reporting. This new standard is being developed to build on and complement existing GHG Protocol standards. The GHG Protocol standards have focused on the physical inventory to show a best estimate of the ‘real’ corporate operational and value chain emissions, but they do not capture the broader climate impacts of corporate activities. Many companies are now undertaking impactful decarbonization efforts that go beyond their own emissions inventory, such as investing in renewable energy projects, supporting emissions reductions in their supply chains, or developing innovative low-carbon products. As it stands today, these actions are not always reflected in a company's reported GHG footprint.

The AMI Standard seeks to address this gap by introducing a multi-statement reporting structure. This approach is designed to ensure transparent and disaggregated reporting of unique elements, without netting, to strengthen the integrity of GHG accounting and reporting and allow for better integration with various voluntary and regulatory GHG programmes.

What changes are proposed in the AMI standard?

Physical inventory:

The physical inventory following the Corporate Standard will stay as the foundation of the GHG accounting and reporting. It will provide the organization’s annual GHG emissions from Scopes 1, 2 and 3.

Market-based inventory:

This would make procurement and market choices visible and complement the physical inventory. Emissions will be reported based on contractual arrangements across all scopes. An example of a market instrument would be a contractual agreement or commodity certificates for the purchase of low-carbon fuels/commodities (subject to eligibility criteria). The market-based GHG inventory may incorporate the existing Scope 2 market-based method and is expected to introduce new approaches for Scope 1 and Scope 3 according to the GHG protocol.

GHG impact statement:

The GHG impact statement would provide a dedicated statement for reporting the emissions impacts of actions taken by the company inside and outside its value chain, like emissions avoided, reduced or removed. It aims to quantify the global change in GHGs in the atmosphere resulting from a given action. This involves estimating the GHG impacts of an action relative to a credible baseline scenario in which the action did not occur.

Non-GHG indicators:

The focus of the non-GHG indicators would be on KPIs not expressed in CO2, which still might influence the organization’s decarbonization actions and aims to standardize the reporting. An example could be financing contributions to mitigation projects.

Source: https://ghgprotocol.org/sites/default/files/2026-03/AMI-Phase1-WhitePaper-RFI.pdf

Why this matters for your organization

The introduction of the multi-statement reporting structure under the Actions and Market Instruments (AMI) Standard marks a significant evolution in corporate GHG accounting. While the current revisions to Scope 2 and other standards are important, the AMI framework extends reporting beyond traditional physical inventories, aiming for greater transparency and a more comprehensive view of climate action. By implementing a standard including quality requirements, greenwashing will be avoided, and contributions will not only be visible but comparable, too.

This shift will have important consequences for the reporting itself as well as for various functions within your organization.

On the reporting side: Based on the changes proposed, the reporting will be broader. While currently your company might report on Scope 1, 2 and 3, you would need to include up to four distinct statements.

Looking at the newly proposed GHG Impact Statement under which you will report on emissions avoided, reduced or removed from actions taken inside and outside the value chain, you will very likely need to gather data from suppliers and potentially clients. This could include data related to baseline scenarios, project-level emissions reductions, and various impact categories (e.g., value chain-associated impacts, sector-associated impacts).

For Sustainability managers

With the AMI Standard widening the reporting, there will be potential to look broader than just electricity and gas. While currently there might be a high focus on GHG reporting on how to reduce the emissions to report under Scope 1–3, sustainability managers can seek efforts outside their own operations and even supply chain. This can open an opportunity to finally report on a climate investment that has an effect beyond its own operations.

For Energy procurement teams

The changes can open access to more market-based instruments for Scopes 1 and 3. Within the current standard, there is only a market-based option for electricity, accepting, for example, Energy Attribute Certificates. Moving the market-based reporting under Contractual Inventory and adding their Scopes 1 and 3 could result in similar rules for all scopes as for Scope 2. The quality criteria are still to be defined in the next phase, though. Still, from an organizational perspective, this can have an impact on how to proceed with the decarbonization of, for example, gas, and it is important to get a proper understanding of the options available.

For Finance directors

The AMI Standard would give finance directors a framework for quantifying investment impacts. It allows for transparent reporting of how financial contributions lead to emissions avoided, reduced, or removed, beyond what is captured in the traditional physical inventory. For investment decisions for renewable energy, it will be crucial to closely follow the quality criteria once further defined.

What’s next?

The Actions and Market Instruments Technical Working Group have worked out the new AMI Phase 1 White Paper. This was approved by the Independent Standards Board (ISB). Stakeholders are invited to provide feedback on the proposed concepts. It is to be noted that this does not constitute a formal public consultation on a draft standard, as it was on the Scope 2 Revision.

The expected timeline would be:

• March–May 2026: RFI
• Q3 2027: Consultation
• Late 2028: Final AMI Standard publication (estimated)
• 2029–2031: Phased implementation (estimated)

1. Participate in the RFI by 31 May: This is a good moment for corporates to help shape how climate action is accounted for going forward. Keep in mind that the GHG protocol is the standard for other reporting standards, too.
2. Consider the AMI implications for procurement decisions to ensure these would be potentially aligned with changes in the GHG reporting. Specifically, bring yourself up to speed with market-based greening for Scope 1 and Scope 3 to not miss the boat in case of changes.
3. Prepare your reporting and upgrade your data collection: as the reporting will become even broader, the basis can be set today already to make the access to data as smooth as possible. When you need to report under the GHG Impact Statement and non-GHG indicators, you should at least have your physical inventory as well as contractual inventory automated for Scope 1–3. You can start working on this today. A good energy portfolio data management will be essential.
4. Follow up on the eligibility criteria (phase 2) as they develop and again consider these for procurement decisions.

Related Resources:

Part 1: Navigating the GHG Protocol Scope 2 Revisions: Learn how hourly matching and deliverability requirements are changing Scope 2 electricity reporting.

Stay ahead of GHG Protocol changes. Our team is monitoring both the Scope 2 and AMI consultations. If you'd like to assess how these standards will affect your organization's reporting and procurement strategy, [get in touch](contact link).