A new chapter in corporate carbon accounting
For years, companies have poured money into climate action that simply doesn’t show up anywhere in their GHG inventories. Green steel procurement, sustainable aviation fuel (SAF) purchases, power purchase agreements, nature-based carbon programs: these investments are real, they are material, and yet most corporate sustainability reports cannot account for them in a credible, standardized way.
That gap is exactly what the GHG Protocol is now targeting. On March 31, 2026, the GHG Protocol released its Actions and Market Instruments (AMI) Phase 1 White Paper, opening a 60-day public consultation (running through May 31, 2026) that could reshape how companies measure and communicate their full climate contribution.
This is not a minor procedural update. The AMI framework proposes moving beyond the single-inventory model that has defined corporate GHG accounting since the original Corporate Standard was published in 2001. Understanding what is being proposed, and why it matters for your sustainability strategy, is essential for any company that takes climate reporting seriously.
Why the existing framework falls short
The current Corporate Standard divides emissions into Scope 1 (direct), Scope 2 (purchased energy), and Scope 3 (value chain). This model is powerful, but it was designed for a world where the primary objective was measuring what a company emits. It was not designed to capture what a company actively does to drive decarbonization beyond its own operations.
Consider a manufacturing company that co-funds a green steel pilot program with a supplier, purchases SAF certificates to support aviation decarbonization, or invests in a regenerative agriculture initiative in its supply shed. None of these activities reduce that company’s Scope 1, 2, or 3 numbers in a way that is transparent or comparable. The money moves, the climate outcomes may be real, but the existing reporting structure has no consistent home for them.
The result is a reporting environment full of “beyond value chain” claims that vary wildly in methodology, quality, and credibility. This creates problems for investors trying to assess climate ambition, regulators trying to police greenwashing, and companies themselves trying to differentiate genuine action from marketing noise.
What the AMI framework proposes
The AMI White Paper introduces a multi-statement reporting architecture built on four complementary components:
Physical GHG inventory. This is the existing Scope 1/2/3 model, unchanged. It remains the foundation.
Market-based inventory. This captures the emissions impact of contractual procurement decisions: electricity certificates, SAF, green hydrogen, green steel, and similar market instruments. Companies would report how their procurement choices affect the emissions trajectory of the markets they participate in.
GHG impact statement. This applies consequential accounting methods to measure the real-world climate impact of investments and interventions. Rather than attributing emissions to a company, it asks: what would the emissions trajectory look like without this company’s action?
Non-GHG indicators. Technology adoption rates, financial investment flows, and other metrics that do not reduce to a CO2-equivalent number but still carry meaningful climate signal. For example, a company funding early-stage green hydrogen infrastructure is contributing to a transition that will reduce emissions over time, even if the immediate CO2 impact is not yet measurable.
The framework is explicit that these four components are complementary, not competing. The physical inventory stays central. The additional statements provide context, demonstrate intent, and create a credible space for companies to communicate climate investments that currently live in an unregulated grey zone.
What this means for companies in practice
The consultation window closes May 31, 2026. A full draft standard is expected in 2027. That timeline may feel distant, but the strategic implications for companies are immediate.
Your climate investment strategy is now on notice. If you are funding interventions outside your direct value chain and calling them “climate action,” expect that the standards framework will soon require you to account for them rigorously. Companies that design their programs with robust methodology now will be far better positioned than those who scramble to retrofit claims later.
The greenwashing risk is real and rising. The AMI framework is explicitly designed to distinguish credible climate investments from superficial ones. The “solid quality requirements” mentioned in the White Paper signal that the GHG Protocol intends to draw a clear line. Companies whose climate narratives rely on poorly-documented market instruments should treat this consultation as a warning signal.
Scope 2 and the electricity sector are central. The AMI initiative builds directly on the GHG Protocol’s ongoing Scope 2 and electricity sector consequential accounting consultations. If your company has significant renewable energy procurement, you should be tracking both workstreams in parallel, not treating them as separate conversations.
Sector-specific implications vary. For energy-intensive industries, market-based accounting for green procurement will likely become a compliance expectation, not just a reporting option. For financial sector companies, the GHG impact statement methodology could transform how they measure portfolio-level climate contributions.
How Dcycle helps companies navigate the transition
At Dcycle, we work daily with companies navigating the gap between what their GHG inventories show and what their climate investments actually represent. The AMI consultation formalizes a problem our customers have been asking us about for years: how do you account for climate action that falls outside the traditional Scope 1/2/3 box?
Our automated data collection infrastructure is built to handle exactly this kind of structural evolution. When standards frameworks expand their scope, the data challenge grows with them: new data types, new suppliers, new contractual instruments that need to be tracked, validated, and reported. The companies best positioned for AMI implementation will be those with flexible data pipelines today, not those building from scratch in 2027.
If you are currently managing green procurement programs, renewable energy certificates, SAF purchases, or beyond-value-chain investments, now is the time to ensure your data architecture can support the reporting requirements that are coming. Request a demo to see how Dcycle handles multi-framework carbon accounting and prepares companies for evolving standards.
The broader context: harmonization as a strategic objective
The AMI initiative does not exist in isolation. It is part of a broader global effort to harmonize carbon accounting standards that has accelerated significantly since the COP30 Action Agenda. The GHG Protocol’s partnership with ISO, the ongoing Scope 2 consultations, and the AMI framework are all threads in the same tapestry: building a global system for corporate climate transparency that is rigorous enough to support regulatory enforcement and credible enough to withstand investor scrutiny.
For sustainability teams, this means the standards landscape will continue to evolve rapidly through 2027 and beyond. The Carbon Footprint Collection on our resource hub tracks these developments as they unfold. The companies that stay ahead of this curve will have a structural advantage: their reporting will be credible before it is required, their data systems will be compliant before regulators mandate it, and their climate narratives will be grounded in methodology that survives scrutiny.
What to do before May 31, 2026
The GHG Protocol consultation is open to all stakeholders. If your company has a perspective on how market instruments or climate investments should be accounted for, this is the moment to contribute. The standards that emerge from this process will shape corporate reporting for a generation.
More immediately, every sustainability team should be doing three things:
- Audit your current climate investment claims. Identify which claims rest on robust methodology and which are vulnerable to scrutiny under tighter standards.
- Map your market instrument exposure. Understand which certificates, PPAs, SAF purchases, and green procurement contracts you hold and how they would be classified under the multi-statement framework.
- Assess your data infrastructure. The AMI framework will require more granular, more diverse data than the existing Corporate Standard. Now is the time to identify gaps before they become compliance problems.
The GHG Protocol’s AMI initiative is a fundamental shift in how corporate climate action will be measured and communicated. The 60-day consultation window is short. The implementation timeline is longer, but the companies that treat 2026 as a preparation year rather than a waiting year will be the ones best positioned when the standard arrives.