Introduction: The Context of the GHG Protocol Update Process

In corporate greenhouse gas (GHG) accounting and disclosure, the GHG Protocol serves as the most widely used global framework. In response to evolving expectations around emissions reporting, the GHG Protocol undertook a multi-year update process. Over the course of approximately two years, it received more than 1,400 stakeholder submissions and over 230 new proposals.

One proposal that emerged during this update process is E-Ledgers. Rather than representing a revision to the existing corporate inventory approach, E-Ledgers introduces a different way of structuring and using emissions data. This article explains the E-Ledgers concept, outlines how it differs from the GHG Protocol Corporate Standard, and clarifies its current positioning based on publicly available information.

What Are E-Ledgers: The Core Concept

E-Ledgers is a ledger-based carbon accounting approach inspired by financial accounting principles.

Purpose

The stated purpose of E-Ledgers is to provide mutually exclusive, comparable emissions data in order to clearly assign emissions responsibility. The approach is designed to support a liabilities-based view of emissions, where responsibility for emissions is explicitly attributed.

How the Concept Is Structured

To achieve this purpose, E-Ledgers proposes recording GHG emissions at the product level, rather than aggregating emissions solely at the corporate level. Emissions associated with a product are treated as E-liabilities. When a product is sold, the associated emissions liability is transferred to the buyer as part of the transaction.

In parallel, verified carbon removals are defined as E-assets, which may be recorded on the same ledger and, conceptually, netted against emissions liabilities.

How the E-Ledgers Approach Is Intended to Work

Under the E-Ledgers concept, a company would first quantify its direct GHG emissions. These emissions, together with product-level emissions data received from direct suppliers, would then be allocated to the company’s products. When products are sold, the emissions associated with those products would be transferred downstream to the purchasing entity.

The approach is described as recursive, meaning that it does not require complete or perfect data from the outset. Initial use of estimates or averages is contemplated, with the expectation that data quality improves over successive reporting cycles as more primary data becomes available.

For assurance, E-Ledgers relies on a distributed auditing model. Each company is responsible for verifying its own direct emissions and the allocation of those emissions to its products, rather than requiring a single audit covering an entire value chain.

How E-Ledgers Compare with the GHG Protocol Corporate Standard

The E-Ledgers proposal and the GHG Protocol Corporate Standard differ primarily in purpose and design philosophy.

The GHG Protocol Corporate Standard is designed to support comprehensive corporate and value-chain-wide GHG management. It provides a framework for emissions disclosure, target-setting, and emissions reduction across Scope 1, Scope 2, and Scope 3.

By contrast, E-Ledgers is designed to clarify emissions responsibility by producing mutually exclusive, comparable emissions data and assigning those emissions through transactions.

The table below summarizes key differences between the two approaches.

Dimension	E-Ledgers	GHG Protocol Corporate Standard
Purpose	Provide mutually exclusive, comparable emissions data to clearly assign emissions responsibility	Support corporate and value-chain-wide GHG management, disclosure, and emissions-reduction target setting
Primary accounting unit	Product-level	Corporate-level
Emissions scope	Primarily cradle-to-gate	Cradle-to-grave (Scopes 1, 2, and 3)
Treatment of double counting	Seeks to eliminate double counting	Manages double counting through scope definitions
Maturity	Proposal and conceptual framework	Established international standard

What This Means for Companies: Current Positioning and Open Questions

Based on publicly available information, E-Ledgers represents a conceptual framework rather than a codified international standard. It does not currently define detailed emissions calculation methodologies or standardized rules for emissions data exchange between companies.

The E-Ledgers concept emphasizes the use of primary emissions data, and its design assumes that companies across a value chain would quantify and register their emissions liabilities. How this assumption could be met in practice, particularly in complex global supply chains, remains an open question.

At the same time, challenges related to emissions data exchange and interoperability are being addressed through other initiatives. For example, the World Business Council for Sustainable Development, a co-convenor of the GHG Protocol, is advancing the Partnership for Carbon Transparency (PACT) to support consistent, comparable Scope 3 data exchange across value chains.

Conclusion: E-Ledgers as One Proposal Among Many

E-Ledgers is one of several proposals put forward during the GHG Protocol update process. It is not positioned as a replacement for the GHG Protocol Corporate Standard, but rather as an alternative way of structuring emissions data with a focus on responsibility and comparability.

For companies, the key consideration is not whether to adopt a specific accounting proposal, but how to build emissions data systems that can adapt to evolving disclosure expectations, regulatory requirements, and value-chain demands. Discussions around E-Ledgers contribute to this broader conversation by highlighting different ways emissions data might be organized and used in the future.

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