The GHG Protocol's plan to add three new emissions ledgers alongside Scope 1, 2, and 3 drew endorsement from 84% of more than 430 respondents, the standard-setter said last week, teeing up a contested draft for the second quarter of next year.

The proposals, set out in a March white paper on Actions and Market Instruments, would create statements covering:

• Market-based instruments — credits that extend renewable energy certificate logic to industrial inputs including steel and cement
• Consequential accounting — capturing investments in low-carbon technology and the sale of low-carbon products
• Non-GHG metrics — such as the share of procured products classified as low-emissions

Why does steel and cement lead the response?

The market-based ledger is the most consequential piece for circular-economy operators. Steel and cement makers have spent years building attribute certificates modeled on renewable energy certificates, aiming to give buyers a verifiable climate profile tied to material sourcing.

Scrap processors and downstream buyers see value in such instruments to differentiate secondary output from virgin production, both in industrial customer bids and in their own Scope 3 accounting. Whether those credits can carry claims against a buyer's overall footprint depends largely on how the GHG Protocol writes the market-based statement.

Where did respondents split?

Support for the multi-statement approach held across company size, region, and nonprofit status. Respondents told the GHG Protocol the framework brings clarity and accountability to the many forms of corporate climate action.

The non-GHG metrics statement broke the consensus. Just 33% of respondents said it should be included. Forty-four percent stayed neutral. Twenty-two percent opposed it, urging the GHG Protocol to keep its focus on greenhouse gas accounting.

Will the four ledgers net out?

The relationship between the four statements remains unresolved. Most respondents told the GHG Protocol the statements should remain separate, because they count different things and follow different accounting rules.

That stance puts pressure on the market-based statement, which some corporate buyers plan to use specifically to lower their reported footprint. The GHG Protocol noted in its summary that some respondents warned "market-based reporting should not obscure the physical emissions profile."

How much complexity is too much?

David Spitzley, a director on Starbucks' global sustainability team, raised the capacity risk at a recent market-based instruments event. "I can see a future in which we have six different climate targets and four different ledgers," Spitzley said. The result gets "complex really fast," he added.

Respondents echoed him. They flagged the time, resources, data systems, verification costs, and technical capacity required to run a multi-statement framework alongside existing inventory work.

Will the framework align with CSRD, ISO, and SBTi?

Respondents called interoperability with the EU's Corporate Sustainability Reporting Directive, the International Organization for Standardization's net-zero guideline, and the Science Based Targets initiative a critical test. Companies operating across multiple jurisdictions already face overlapping verification regimes; adding new statements that duplicate existing ones would raise costs without raising signal.

The technical experts leading the Actions and Market Instruments work flagged interoperability and the relationship between the statements as the questions they will resolve. A draft standard opens for consultation in the second quarter of next year — the milestone recyclers and downstream buyers should watch as they weigh whether to align Scope 3 strategies with the new framework.