The Greenhouse Gas Protocol has taken a decisive step towards modernising carbon accounting with the release of its Actions and Market Instruments (AMI) Phase 1 White Paper.
This marks the beginning of a 60-day Request for Information (RFI), inviting global stakeholders to weigh in on what is widely considered one of the most complex frontiers in climate disclosure. The initiative seeks to bridge the gap between a company’s physical emissions footprint and the real-world impact of its broader decarbonisation investments.
Historically, corporate reporting has centred on the “physical reality” of emissions via Scope 1, 2, and 3 inventories. However, as businesses increasingly invest in mitigation efforts that exist outside these direct silos—such as purchasing sustainable aviation fuel certificates or funding value-chain emission reductions—existing frameworks have struggled to capture these actions consistently.
The AMI White Paper addresses this by proposing a fundamental transition: moving from a single inventory to a more comprehensive multi-statement reporting structure.
Under this proposed framework, the traditional physical GHG inventory would remain the foundation, but it would be supplemented by three new pillars. First, a market-based inventory would track emissions linked to contractual choices, such as low-carbon cement or green steel certificates. Second, a GHG impact statement would use “consequential accounting” to quantify how specific company actions, such as projects to avoid emissions, change the global atmosphere relative to a baseline. Finally, the proposal introduces non-GHG indicators to track vital metrics that are not measured in tonnes of carbon, including the percentage of electric vehicles in a fleet or total financial investment in renewable energy.
This shift is designed to eliminate the “invisibility” of high-impact climate strategies. Currently, investors often lack the granular data needed to differentiate between superficial claims and credible interventions. By establishing rigorous quality criteria and safeguards, the GHG Protocol aims to provide a standardised language for climate action, effectively reducing the risk of greenwashing while allowing companies to tell a more complete story of their environmental contributions.
The RFI period is now open and will run until 31 May 2026. This feedback phase is critical for refining the principles laid out in the White Paper before a full draft standard is released for public consultation in 2027.
