In connection with the public consultation on the topic of the proposed changes to Scope 2 Guidance running until January 31, 2026, MATERIALITY has submitted its position on the proposed shape and definitions set forth in the consultation materials.
The opinion highlights:
- Lack of systemic solutions to ensure the availability of the data required by location-based and market-based methods, particularly in terms of the required benchmarks.
- Increased effort and costs on the part of reporting companies, without a commensurate improvement in data accuracy. In our opinion, this is due to:
- lack of hourly data management tools
- Limited access to benchmarks covering national and local contexts
- ambiguous definition of „accessible” in the context of identifying reliable and accessible benchmark databases
- increased cost of data auditing.
- The lack of a clear hierarchy indicatesźniemission factors and pathways for emissions calculations, which will result in a lack of comparability of data.
- The need to introduce a legacy clause and revise the approach to the proposed exemption thresholds.
In MATERIALITY's view, it is crucial to use an approach that allows for the inventory of GHG emissions without losing voluntary reporting entities and while maintaining the transparency of the standard.
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