The GHG reporting ecosystem continues to develop and update, but the core GHG Protocol which now underpins most GHG reporting frameworks and laws has had very little change since 2011.

This article provides a brief comparison of how the state of GHG reporting in Australia, Canada, USA, UK and Europe.

United States – SEC Climate Disclosure Rule

In March 2024, the U.S. Securities and Exchange Commission (SEC) decided to adopt a new rule requiring publicly listed companies to disclose climate-related risks and GHG emissions.

Requirements:

• Disclosure of Scope 1 and 2 GHG emissions for most entities.
• Disclosure of climate-related risks, governance, strategy, and risk management, broadly aligned with TCFD.
• Phased-in assurance requirements for emissions data, starting with limited assurance.

GHGRP (Greenhouse Gas Reporting Program):

• In parallel, the U.S. EPA operates the GHGRP, which requires facilities emitting 25,000+ tonnes of CO2e per year to report GHG emissions.
• This is separate from SEC disclosures but provides a facility-level emissions inventory for more than 8,000 facilities.

GHG Protocol Alignment:

• The SEC rule requires companies to use GHG Protocol standards for calculating and reporting emissions. The rule cites the Protocol as the foundational framework for ensuring consistency and comparability in emissions data.
• The GHGRP uses EPA-specific methodologies that are compatible but not identical to GHG Protocol.

Canada – Federal and Provincial Reporting

Canada uses a combination of federal facility-based reporting and corporate-level ESG disclosure guidance.

Requirements:

• Facilities emitting 50,000+ tonnes of CO2e annually must report under the Greenhouse Gas Reporting Program (GHGRP).
• Canada was preparing for mandatory climate disclosures aligned with ISSB standards but announced on 30 April 2025 that this was "paused".

GHG Protocol Alignment:

• The GHGRP uses a methodology-based approach, and while it is not explicitly GHG Protocol-based, it is compatible with it.
• Corporate-level disclosures under CSA guidance reference the GHG Protocol for Scope 1, 2.

Australia – Australian Sustainability Reporting Standards (ASRS)

Australia has significantly upgraded its sustainability disclosure regime through the creation of the ASRS, developed by the Australian Accounting Standards Board (AASB) in line with ISSB’s IFRS S1 and S2.

Requirements:

• Mandatory for large entities beginning 1 January 2026, phased in based on size and emissions.
• Disclosure of Scope 1, 2, and 3 emissions.
• Climate-related risk, governance, and strategic disclosures are also required.
• Limited assurance for 2025–26 period; reasonable assurance by 2027–28 for large entities.

GHG Protocol Alignment:

• The ASRS explicitly mandates that emissions must be reported using GHG Protocol standards, ensuring compatibility with global practices and enhancing comparability.

United Kingdom – TCFD and SDR Framework

The UK was among the first countries to mandate TCFD-aligned climate disclosures for both listed and large private companies.

Requirements:

• TCFD-aligned reporting of Scope 1 & 2 is mandatory for large companies (≥£500m turnover and 500 employees).
• During 2025, the upcoming UK SRS is expected to be implemented. It is expected to include smaller organisations and broaden reporting to include material Scope 3 emissions. It will be based on ISSB standards.

GHG Protocol Alignment:

• Both TCFD and SRS frameworks are aligned with the GHG Protocol.
• Scope 3 disclosures rely on GHG Protocol's Corporate Value Chain (Scope 3) Standard.

European Union – CSRD

The EU has attempted to implement one of the most advanced sustainability reporting regime through the Corporate Sustainability Reporting Directive (CSRD).

Requirements:

• Intended to apply to all large EU companies and EU-listed SMEs, phased in starting in 2025.
• Disclosure of Scope 1, 2, and 3 emissions, including detailed GHG intensity metrics.
• Emphasis on double materiality – reporting both financial and impact materiality.
• External limited assurance required initially, with reasonable assurance to follow.
• In February 2025, the European Commission revised the CSRD requirements, pushing back reporting for large (>500 staff) organisations to 2028 and indefinitely suspending mandatory requirements for smaller entities.

GHG Protocol Alignment:

• ESRS adopts accounting methodologies consistent with the GHG Protocol, although it adds additional granularity and prescriptive requirements.
• Companies are expected to use GHG Protocol or ISO 14064 for emissions measurement and disclosure.

GHG Reporting by country status