As the Greenhouse Gas Protocol undergoes a significant standard development and revision process to its corporate suite of standards and guidance, Akamai is following closely and sharing our perspective. The Scope 2 proposed revisions place further restrictions on the temporal and locational matching of clean energy procurement and energy accounting. 

Together with a broad coalition of corporate energy consumers and environmental organizations, Akamai advocates for policies that accelerate, rather than constrain, renewable energy procurement. We believe that maintaining flexible, accessible procurement mechanisms is essential to sustaining the momentum of corporate climate action and advancing the shared goal of global grid decarbonization.

A central consideration regarding the proposed regulatory frameworks is the potential requirement that organizations source clean energy exclusively from within their local grid regions. While we understand the desire to stimulate local infrastructure development, such geographic constraints could inadvertently curtail a highly effective decarbonization strategy currently utilized by corporate buyers like Akamai. Maintaining the flexibility to aggregate energy load across geographies allows us to maximize both environmental and economic impact by funding large-scale, net-new renewable projects.

Frequently, these investments are strategically directed toward regions with a more carbon-intensive energy mix. In these locations, introducing new renewable capacity displaces a significantly higher volume of fossil-fuel emissions compared to building similar projects in areas where the grid is already highly decarbonized. By prioritizing rigid geographic boundaries over systemic atmospheric impact, the proposed guidelines risk limiting the scale of investment, increasing procurement complexity, and potentially slowing the broader, global transition to a net-zero economy.

Furthermore, highly localized mandates may not fully reflect the interconnected nature of modern energy networks. They could unintentionally disincentivize organizations from taking a holistic, impact-driven approach to climate action — an approach designed to ensure that investments result in genuine, additional clean energy capacity exactly where it provides the greatest environmental benefit.

Akamai advocates for preserving flexible procurement mechanisms and supports the deeper integration of consequential accounting, ensuring that measurable, real-world emissions reductions remain at the forefront of global greenhouse gas standards. Based on our analysis of the proposed changes and our commitment to maximizing our positive impact, we recommend the following:

• Pausing the proposed mandate for universal hourly and restrictive geographic matching to allow for a more collaborative revision process.
• Formally developing a consequential accounting pathway and giving it equal weight and validity to attributional methods.
• Maintaining annual matching as a foundational and valid option, particularly for companies with distributed operations that depend on it.
• Engaging in a co-design process with market participants to build a flexible, multipath standard that balances accounting rigor with market viability and maximum decarbonization impact.

With so much at stake, Akamai is following the proposed revisions closely and engaging our peers to share our perspective. We participated in a case study, written in partnership with the Pragmatic Carbon Accounting Alliance, highlighting the challenges of the proposed changes. As we continue the discussion with our peers, we have refined our own internal guidelines among many other initiatives to ensure that consequential emissions are closely considered.