Navigating the Future of Scope 2: Balancing Impact and Practicality

The revision proposals emphasize enhanced temporal and geographic fidelity in accounting: matching energy consumption with clean energy attributes on an hourly basis and within precise market boundaries. In principle, this level of granularity can deepen confidence in emissions claims.

Yet, mandating these requirements without close calibration with stakeholders can introduce complexity in data collection, reporting, verification and could ultimately slow the development of new clean energy supported by corporations. This is especially true for organizations that are still scaling their clean energy portfolios.

At Akamai, our sustainability strategy prioritizes meaningful, measurable impact over rapid, fragmented progress. We run a global network that makes life better for billions of people trillions of times a day, and is actively tracking toward net-zero emissions by 2030. 

Akamai is aligning every phase of our operations across our 4,300+ locations globally — at data centers that support our mission to power and protect life online from the core out to the deepest edge — with clean electricity to drive down our emissions footprint.

We accomplish this through:

• Holistic integration: We integrate renewable energy considerations into network planning where possible to ensure that each new site and service is directly contributing to reducing our overall emissions footprint.
• Scalable practices: By focusing on scalable accounting approaches, such as monthly, quarterly, or yearly matching during the grid transitional phases, we can responsibly expand renewable procurement with a focus on emission reduction impacts without sacrificing data integrity.
• Customer enablement: Our customers rely on Akamai’s network to meet their own sustainability goals. By emphasizing robust, flexible metrics and providing customizable reporting, we enable our customers to confidently report emissions reductions tied to the Akamai services they consume across our platform.

When building new compute regions around the world, we partner with our data center operators when possible to secure power with attached energy attribute certificates (EACs) that deliver verifiable emissions reductions. In areas where impact-driven certificates are not available, we catalyze the development of net-new renewable energy projects to broaden access to high-integrity EACs.

Recognizing that strict local deliverability can take time to mature, Akamai has adopted a phased approach: applying volumetric matching to build out a consistent baseline while progressively integrating higher-resolution accounting as the data fidelity and market structures can demonstrably enhance the emissions reduction outcomes.

This deliberate approach ensures that each EAC attributed to a clean megawatt-hour (MWh) of electricity drives a tangible emissions reduction claim. This ensures our efforts continue to be aligned with our 2030 net‑zero ambition without diverting internal resources focused solely on aligning updated accounting protocols before there is an optimized environmental benefit.

Robust emissions accounting frameworks should accommodate diverse buyer profiles, from multinational enterprises to the smallest local businesses. A rigid mandate on sub-hourly matching may inadvertently exclude organizations that lack mature data systems or operate in emerging markets.

Preserving optionality and allowing organizations to adopt a right-sized, individualized emissions-reduction strategy will enable the GHG Protocol to foster broader participation and will help sustain corporate investment in clean energy.

In alignment with the detailed recommendations from the Clean Energy Buyers Association (CEBA), Akamai supports the principles outlined in the letter to the GHG Protocol’s Independent Standards Board (May 23, 2025).

CEBA’s advocacy for balanced, feasible accounting practices reflects deep market expertise and a clear mandate from corporate buyers. We echo and commend their three core requests to ensure the revision process remains inclusive, transparent, and impact-driven:

• Enhanced buyer engagement: As CEBA emphasizes, ongoing dialogue with energy buyers is critical. We endorse their call for active representation in Technical Working Group discussions to validate feasibility across diverse market contexts.
• Preconsultation feasibility adjustments: CEBA urges that operational concerns be addressed before the public comment phase. We stand behind this recommendation, believing that incorporation of buyer feedback will strengthen the draft’s credibility.
• Alignment with consequential metrics: CEBA requests an accelerated development of consequential (impact) metrics alongside Scope 2 revisions. We believe this will provide a holistic view of both emissions accounting and real-world climate impact clean energy procurements are having.

By closely heeding CEBA’s guidance, the GHG Protocol can ensure that revised Scope 2 standards drive meaningful emissions reductions while remaining accessible to buyers of all scales helping to create demand to drive new clean energy development across the globe.

Through seeking a balanced approach to the Scope 2 revisions, the protocol can be enabled for all businesses including supporting Akamai’s extensive customer community to chart credible emissions reductions in their use of our platform across the globe. 

Whether our partners are in the entertainment, hotel and travel, ecommerce, or healthcare sector, they all benefit from transparent, adaptable reporting that supports their emissions reductions and net-zero value chain commitments that help communicate their progress to stakeholders with confidence.

A balanced approach will support the world’s largest and smallest businesses in creating the next generation of 100 GW+ clean energy additionality for the global grid.