Response to GHG Protocol’s latest consultation on ‘Action and Market Instruments Standard’

The GHG Protocol launched the next stage of development for a new Actions and Market Instruments (AMI) Standard on 31st March 2026, launching a public request for feedback. This consultation is part of a broader process which, ultimately, aims to provide a cross-sector industry standard that enables companies to account for and report on decarbonisation actions and market instruments to incentivise impactful investments.

The International Gas Union has made its position consistently clear: any proposed industry standards, such as the GHG Protocol, must fully recognise established market-based instruments such as renewable gas certificates that provide clarity to investors and, therefore, can realistically support the decarbonisation of the global Gas value chain. Thus, the current AMI White Paper draft is commendable for its explicit inclusion of market-based instruments as part of the GHG Protocol’s proposed multi-reporting structure.

In its response to the GHG consultation, IGU further recommends that:

• an appropriate balance is set between reporting reliability and reporting workload, so that the requirements for the market-based GHG inventory statement do not become overly complex.

• the GHG Protocol’s definitions are aligned with existing frameworks and regulations to avoid fragmentation and reduce compliance costs for organisations.

• the GHG Protocol should provide examples based on real-world case studies, across sectors, to demonstrate how the framework can be applied in practice.

• market-based reporting using certified instruments should be permitted in scopes 1 and 3, with disclosed emissions values and appropriate quality criteria.

• fuels made from captured CO2 – i.e. synthetic or e-fuels - are explicitly recognised in the definitions of low-emissions fuels. This will increase business predictability and contribute to encouraging investment decision-making.

IGU also applauds its many members who are currently deploying their capital, skills, experience and partnerships to accelerate the deployment of zero and low-emissions gases, such as renewable natural gas, biomethane, hydrogen and e-methane.

Well-designed policies and standards will play a critical role in incentivising investment to support the more rapid scaling of these technologies.

Mr Mark McCrory, the IGU’s Director of Policy and Analysis said:

“A prerequisite for deployment of renewable and low-emissions gases across economies is the use of a market-based approach as it uniquely overcomes economic, technical and environmental barriers, and inefficiencies that arise from the requirement for a physical (local) connection. Robust market instruments can enable the supply of decarbonised products to a much wider pool of consumers, thus enabling the creation of commercial value chains at scale.”