Carbon Accounting Framework
GHG Protocol and UK SRS: greenhouse gas accounting foundation
The GHG Protocol Corporate Standard provides the methodological foundation for UK SRS S2 climate disclosures. Published in 2004 and currently under revision, it defines how companies quantify and report Scope 1, 2, and 3 greenhouse gas emissions. Here's how the framework works, what the 2027 revision changes, and how UK companies should prepare.
The GHG Protocol framework
The Greenhouse Gas Protocol Corporate Accounting and Reporting Standard, published by the World Resources Institute and World Business Council for Sustainable Development in 2004, provides the global methodology for corporate carbon accounting 34. It establishes the foundational concepts of operational boundaries, organisational boundaries, and the three scopes of emissions that underpin virtually all corporate climate disclosure frameworks.
UK SRS S2 explicitly builds on GHG Protocol methodology for emissions quantification and reporting 4. Companies must follow GHG Protocol approaches for defining organisational boundaries, categorising emissions, and applying quantification methodologies — making understanding of the GHG Protocol essential for UK SRS compliance.
The framework operates on five key principles: relevance (capture all sources that matter to decision-making), completeness (include all relevant sources), consistency (use methodologies that allow meaningful comparisons), transparency (disclose assumptions and methodologies), and accuracy (reduce bias and uncertainties) 34.
Scope 1, 2, 3: the three categories explained
The GHG Protocol categorises emissions into three scopes based on whether they are direct or indirect, and where they occur in the company's value chain 34. This categorisation helps companies understand their complete carbon footprint and prioritise reduction efforts.
| Scope | Definition | Examples | UK SRS Status | Complexity |
|---|---|---|---|---|
| Scope 1 | Direct GHG emissions from owned/controlled sources | Fuel combustion in boilers, company vehicles, industrial processes | Mandatory from 2027 | Low - direct measurement |
| Scope 2 | Indirect GHG emissions from purchased energy | Electricity, steam, heating/cooling purchased for operations | Mandatory from 2027 | Medium - location/market-based |
| Scope 3 | All other indirect emissions in value chain | Business travel, purchased goods, waste, investments | Comply-or-explain from 2028 | High - 15 categories, estimation |
Scope 1 emissions are direct emissions from sources that are owned or controlled by the company — fuel combustion in company boilers, company-owned vehicles, industrial processes, and fugitive emissions from equipment 34. These are typically the most straightforward to measure and manage.
Scope 2 emissions are indirect emissions from the generation of purchased energy consumed by the company — primarily electricity, but also steam, heat, or cooling 36. The 2015 Scope 2 Guidance introduced dual reporting: location-based (average grid emissions) and market-based (reflecting energy purchasing choices) methods.
Scope 3 emissions include all other indirect emissions that occur in the company's value chain, categorised into 15 specific categories from purchased goods and services to investments and downstream transportation 35. These often represent 70-90% of total emissions but are the most challenging to quantify accurately.
How UK SRS integrates GHG Protocol methodology
UK SRS S2 requires companies to quantify and disclose greenhouse gas emissions following GHG Protocol methodology, making the Protocol's approaches mandatory for UK listed companies from 2027 4. This includes organisational boundary definitions, emission factor applications, and the scope categorisation framework.
For organisational boundaries, companies must follow either the equity share or control approach as defined in the GHG Protocol, consistently applied across all scopes 34. Most UK companies use the operational control approach, which includes 100% of emissions from operations they control regardless of ownership percentage.
UK SRS requires separate disclosure of Scope 1, 2, and 3 emissions, with Scope 2 reported using both location-based and market-based methods where applicable 4. Companies must also disclose significant changes in emissions and explain methodological changes between reporting periods, following GHG Protocol transparency principles.
The 2027 GHG Protocol revision: what's changing
The GHG Protocol is undergoing its first major revision since 2004, with a final suite of updated standards expected by end 2027 34. The revision addresses technological changes, methodological improvements, and integration with newer frameworks like science-based targets and nature-related disclosures.
Key areas under review include updated emission factors for emerging technologies, improved Scope 3 quantification methodologies, integration with digital reporting systems, and alignment with the IFRS sustainability standards and other global frameworks 34. The revision also addresses challenges companies face with data availability and estimation approaches for Scope 3 categories.
For UK companies, the timing is significant: UK SRS implementation begins in 2027, the same year the revised GHG Protocol is expected. Companies may need to adapt their methodologies as both frameworks evolve, potentially requiring systems that can accommodate both current and updated approaches during the transition period.
Implementation guidance for UK companies
UK companies preparing for UK SRS S2 compliance should establish GHG Protocol-aligned emissions accounting systems covering all three scopes, even where Scope 3 disclosure follows comply-or-explain initially 4. Building comprehensive baseline data enables faster progression to full disclosure and demonstrates commitment to climate transparency.
For Scope 1 and 2 emissions, companies should implement direct measurement where possible, using consumption data and appropriate emission factors 34. For Scope 2, both location-based and market-based calculations should be prepared, with market-based reflecting renewable energy purchasing or other contractual arrangements.
Scope 3 preparation should focus on the most relevant categories for the business, typically purchased goods and services, business travel, and employee commuting as starting points 35. Companies should develop supplier engagement strategies to improve data quality over time, moving from spend-based estimates to activity-based calculations where feasible.
- Establish organisational boundary definitions following GHG Protocol control or equity approaches
- Implement data collection systems for direct energy consumption and fuel use (Scope 1)
- Set up dual Scope 2 reporting using both location-based and market-based methodologies
- Prioritise material Scope 3 categories and develop supplier data collection processes
- Create documentation systems that support GHG Protocol transparency requirements
- Monitor GHG Protocol revision updates and UK SRS technical guidance for methodology changes
Companies should also prepare for the methodological transparency that UK SRS requires, documenting calculation approaches, emission factors used, estimation methods, and assumptions made 4. This documentation supports both compliance and credible climate disclosures that meet investor information needs.