2.5 Change in the Approach to Consolidating GHG Emissions
The GHG Protocol is silent on whether an entity can change its
approach to consolidating GHG emissions and, thus, its organizational boundary.
However, the Corporate Standard contemplates that an entity may make changes to the
inventory boundary, methods, data, or any other factors affecting emission
estimates. In this scenario, the Corporate Standard requires such changes to be
transparently documented and justified.
A change in the approach to consolidating GHG emissions may result in a change to
inventory and reporting boundaries. Accordingly, an entity may change its approach
to consolidating GHG emissions if the new approach would be “best suited to [its]
business activities and GHG accounting and reporting requirements,” as stated in the
Corporate Standard.
Judgment is required to determine whether a change in the approach to consolidating
GHG emissions is justified. Among other considerations, an entity would need to
consider the GHG accounting and reporting principles to determine whether the change
in approach is justified. For instance, it would be inappropriate to change the
approach simply to avoid reporting emissions. If there is a change in facts and
circumstances necessitating a change in the approach, an entity would need to apply
judgment when considering the seven factors included in the Corporate Standard (see
Section 2.4) for determining the
appropriate approach. In addition, an entity would need to consider other regulatory
requirements that may preclude it from changing its approach or limit the
circumstances in which such a change is permitted.
If a change in the approach to consolidating GHG emissions is justified, the entity
would need to disclose this change along with the rationale for the change to meet
the objectives of the Corporate Standard’s consistency principle.
Further, upon making such a change, the entity would need to reconsider its emission
inventory and changes to its operational boundary resulting from the change in its
organizational boundary. If changes in the approach to consolidating GHG emissions
compromise the consistency and relevance of the reported GHG emission information,
the historical periods (e.g., base year) would need to be restated.