Governing the Greenhouse Gas Protocol

Summary

The Greenhouse Gas Protocol is a prominent accounting standard that companies around the world use to publicly report their greenhouse gas emissions. The Protocol is privately governed by its two co-host organizations, the World Resources Institute (a nonprofit environmental NGO based in Washington, D.C.) and the World Business Council on Sustainable Development (a nonprofit business association based in Geneva). Beyond its foundational use in voluntary corporate disclosures and target-setting process, such as the Science Based Targets initiative, the Protocol is also being integrated into mandatory climate disclosure policies in the European Union and California.

This report provides an overview of the Protocol’s governance structure, describes two problems with this structure, and identifies potential solutions. The first problem is that the Protocol’s decision-making bodies are not adequately representative. Specifically, the Steering Committee lacks scientific representation, and the Independent Standards Board lacks environmental NGO representation. These gaps contribute to structural bias in the organization’s decision-making process that can be mitigated with more balanced representation. The second problem is that the Protocol does not have adequate transparency requirements or norms, with secret ballot voting, an opaque procedure for addressing formal complaints, and no public records of the Independent Standards Board meetings. Recent rule changes also permit the formation of non-public Joint Working Groups to develop and revise Protocol standards in collaboration with the International Organization for Standardization (ISO). To improve outcomes, some policies must change to require transparency and promote integrity; others are adequate on paper but are not yet implemented and should be put into effect.

Disclosure: The author of this report is a member of the Greenhouse Gas Protocol’s Independent Standards Board and has filed a formal complaint alleging multiple violations of the Protocol’s governance rules. The author is writing in his personal capacity and not as a representative of the Greenhouse Gas Protocol or its Independent Standards Board. It is the author’s express intent to support the ongoing improvement of a critically important standard-setting body.

Full Paper

Governance Overview

The Greenhouse Gas Protocol (or “Protocol”) is the leading technical standard by which companies assess and report their greenhouse gas emissions. The Protocol was launched and continues to operate as a joint initiative of its two co-host organizations, the World Resources Institute, a nonprofit environmental NGO based in Washington, D.C., and the World Business Council on Sustainable Development, a nonprofit business association based in Geneva. Its flagship Corporate Standard brings together a suite of technical standards to provide a comprehensive resource and rulebook for how a company should account for its own emissions, carbon removals, and associated impacts across its broader supply chain.

University of Toronto political scientist Jessica Green has described the Protocol as a leading example of private entrepreneurial authority in climate policy (Green 2014). As businesses and environmental groups began to contemplate the potential for climate regulation in the late 1990s, yet governments remained deadlocked on the right approach for corporate reporting in international climate negotiations, a coalition of actors in the private sector recognized the absence of public authority in the domain of corporate emissions reporting and began to collaborate on a potential solution. Their goal was to develop a standard for emissions accounting that would parallel widely used financial accounting standards like the Generally Accepted Accounting Principles (GAAP).

As the Protocol matured, it was widely adopted by companies that choose to track and disclose their emissions for a variety of purposes, including internal management objectives and voluntary public accountability for climate-related targets and claims. Its user base now includes over 90% of Fortune 500 companies (Salzman et al. 2024). The Protocol also forms the basis for prominent target-setting standards, such as the Science Based Targets initiative, by which companies set and evaluate net-zero targets.¹ More recently, governments have begun to integrate the Protocol into legally binding compliance regimes, including financial regulatory measures in the European Union and a mandatory disclosure regime for companies doing business in California.

The Protocol’s own governance process has begun to mature as well, shifting from a more informal collaboration between its co-host organizations and hundreds of technical experts drawn from industry and civil society into a formalized governance structure that launched in 2024. This report analyzes the new governance structure and identifies two critical challenges that, if left unaddressed, threaten to undermine the goodwill and legitimacy its co-hosts have built over decades. It concludes with recommendations to improve the representation and transparency of the Protocol’s governance regime, with the goal of promoting an institutional structure that can support the expectations of a diverse stakeholder community spanning business, scientific, environmental, and regulatory interests as the Protocol’s reach continues to expand.

Governance Structure

The Greenhouse Gas Protocol governance structure has four constituent bodies:

• The Steering Committee
• The Independent Standards Board
• Technical Working Groups
• The Secretariat

The Steering Committee, which comprises 11 members as of this writing, is the highest-level governing body (GHGP 2024a). It provides overall strategic advice on the Protocol’s work and oversees the Independent Standards Board. It approves terms of reference for the Board (GHGP 2024a, section 3.1.6), appoints and removes Board members (GHGP 2024a, sections 3.1.7 and 3.1.8), approves the Standard Development and Revision Procedure (GHGP 2024a, section 3.2.1), and ratifies standards approved by the Board, each of which is accompanied by a formal Basis for Conclusions document (GHGP 2024a, section 5.5.4). Committee members are publicly listed on the Protocol’s website.

The Independent Standards Board, comprising 11 members as of this writing, is the Protocol’s substantive decision-making body (GHGP 2025a). Its duties include approving the composition of all Technical Working Groups and reviewing the materials they produce, including deciding between competing proposals (GHGP 2025a, section 3.2.1). The Board must approve all interim documents and final standards (GHGP 2025a, section 3.2.1), using a decision-making hierarchy that prioritizes scientific integrity (GHGP 2024c, Annex A). When approving a standard for the Steering Committee’s review and potential ratification, the Board also produces a draft Basis for Conclusion that documents its substantive rationale (GHGP 2025a, section 5.5.4). The Board also includes non-voting observers to represent key organizational partners and Protocol user communities (GHGP 2025a, section 4.3 and Annex A).² Board members are publicly listed on the Protocol website.

Technical Working Groups, which comprise anywhere from 17 to 63 members as of this writing,³ are the primary sources of external technical input in the standard development and revision process (GHGP 2024b). Their membership is intended to include “roughly balanced representation” from academia and research organizations, civil society, the private sector, and government bodies (GHGP 2024b, section 4.1.8). Their membership should also be balanced across geographic regions, ethnicity, gender identity, institutional background, and professional backgrounds (GHGP 2024b, section 4.1.9). To promote transparency, a list of current and former Technical Working Group members is published on the Protocol website (GHGP 2024b, section 4.1.13).

The Secretariat is the administrative team charged with facilitating and managing the Technical Working Groups as well as liaising between the Steering Committee, Independent Standards Board, and each Technical Working Group (GHGP 2024c). There are 37 secretariat staff members listed on the Protocol website as of this writing. The Secretariat is tasked with drafting standards based on the input of the Technical Working Groups and the Independent Standards Board (GHGP 2024c, section 1.1.4). All secretariat team members work for one of the two co-host organizations, the World Resources Institute or the World Business Council on Sustainable Development.

Standard Development and Revision

The process for developing or revising a Greenhouse Gas Protocol standard begins when the Independent Standards Board approves a Standard Development Plan and the Steering Committee approves the commencement of work (GHGP 2025d, sections 3.2.1 and 3.2.5; GHGP 2025a, section 3.2.1; GHGP 2024a, section 3.2.3). In most cases, the Independent Standards Board then approves the composition of a Technical Working Group for the approved scope (GHGP 2025a, section 3.2.1).

To date, five Technical Working Groups have been appointed to work on:

• The Corporate Standard
• Scope 2 (purchased energy)
• Scope 3 (corporate value-chain impacts)
• Actions and Market Instruments
• Forest Carbon Accounting

The Secretariat manages individual Technical Working Groups to develop specific proposals. The intended mode of work is for the Technical Working Groups to achieve consensus, or at least broad agreement, on a proposed course of action (GHGP 2024b, section 6.2.1). When it is not possible to reach this level of agreement—whether on overall concepts or individual details—the Technical Working Group and the Secretariat may end up developing multiple alternatives for the Independent Standards Board’s consideration (GHGP 2024b, section 6.2.2).

The Secretariat also facilitates informal exchanges between Technical Working Groups and the Independent Standards Board (GHGP 2024b, sections 6.2.3 through 6.2.6). This could include, for example, the sharing of survey results concerning the level of support for different proposals from one body with the other. In addition, the Board can approve the publication of multiple interim work products, such as white papers, initial concept proposals, and proposed standards for public stakeholder consultation.

The Independent Standards Board reviews any proposed standards for feedback, revision, and potential approval (GHGP 2025a, section 3.2.1). Approval from the Board requires a supermajority vote of at least two-thirds of its members (GHGP 2025a, section 6.2.2). When the Board approves a standard, it must also develop a Basis for Conclusions document (GHGP 2025a, section 5.5.4).

The Steering Committee then reviews and must ratify that a standard approved by the Independent Standards Board had been developed in accordance with the overall governance process requirements before that standard can be made final (GHGP 2024a, section 3.1 and 3.2). Notably, this final review is not intended to be substantive, in the sense that the Steering Committee is not charged with expressing an independent view of a standard’s technical or scientific merits; instead, the review only serves to establish conformity with the Standard Development and Revision Procedure and the relevant Standard Development Plan (GHGP 2024a, sections 3.2.4 through 3.2.6).⁴

Legal Governance Considerations

In addition to the normal standard development process, there has also been one standard development process that did not involve the formation of a Technical Working Group. In early 2026, the Greenhouse Gas Protocol published the Land Sector and Removals Standard (GHGP 2026a), which extended the Protocol’s coverage to include methodologies that apply to the land sector and non-land-sector carbon removals.

The reason this Standard was different is that it was produced in part under a predecessor body called the Land Sector and Removals (LSR) Advisory Committee (GHGP 2026b, section 1.1.1). Participants in this process reached agreement on some issues, with three areas left unresolved and to be decided under the current governance regime:

• Agricultural Leakage
• Forest Carbon Accounting
• LSR Advisory Committee “Red Flag” Review⁵

Following the conclusion of the predecessor governance regime, the agricultural leakage issues were resolved directly by the Independent Standards Board without the appointment of a Technical Working Group. In contrast, the Independent Standards Board appointed a Technical Working Group for the Forest Carbon Accounting issue. Because the Board was unable to reach a decision on Forest Carbon Accounting in time for the publication of the Land Sector and Removals Standard (GHGP 2026b), however, the published Standard did not address forest carbon accounting issues. Most of the “Red Flag” review items were resolved as part of the published material on the Agriculture Leakage agenda item or deferred to future work under the Forest Carbon Accounting agenda item (GHGP 2026b, section 3.3).

Emerging Governance Considerations

In the fall of 2025, the Protocol and the International Organization for Standardization (ISO) announced a partnership to develop harmonized greenhouse gas accounting standards that integrate the Protocol’s standards with those of the ISO 1406X family of standards (GHGP 2025c). As part of this process, the Protocol developed new terms of reference for Joint Working Groups that involve participation from Protocol-appointed experts and existing ISO expert processes (GHGP 2025e).

Like Technical Working Groups, Joint Working Groups are also intended to produce technical input from a range of interested stakeholder-participants for decision-making bodies’ consideration. Nevertheless, although Joint Working Groups appear to fit into the Protocol’s organizational structure as if they were Technical Working Groups, their respective Terms of Reference are substantively different in two key respects.

The first concerns transparency. As discussed above, Technical Working Group members are publicly listed on the Greenhouse Gas Protocol’s website (GHGP 2024b, section 4.1.13). In contrast, there is no requirement for Joint Working Groups to publicly disclose their memberships.

The second concerns representation. The membership of Technical Working Groups “should” be balanced across stakeholder groups (GHGP 2024b, section 4.1.8) and the Board “shall, in consultation with the Secretariat, use its best efforts to achieve balance” (GHGP 2024b, section 4.1.9). In contrast, there is no “should” requirement to achieve balance among stakeholder groups in the composition of Joint Working Groups nor any “shall” requirement to make best efforts to achieve this outcome. Instead, these Groups are only “expected to ensure a … balance of representation and diverse perspectives” (GHGP 2025e, section 4.1.4) and their co-conveners (the Greenhouse Gas Protocol and International Organization for Standardization) “will make every effort to ensure the [Joint Working Groups] are balanced” (GHGP 2025e, sections 2.1.2 and 4.1.6).⁶

As a result, it is conceivable that the Protocol could approve an anonymous Joint Working Group with well over 100 members, the vast majority of whom are appointed by the ISO and with fewer than 20% of total membership representing academic or civil society perspectives.⁷ As of this writing, 23 members of a Joint Working Group for Product Carbon Accounting are listed on the Protocol website, apparently reflecting the Board-nominated members; there is no record of members appointed through the ISO process.

Critique #1: Representation

In any governance process, representation is a key consideration. This is particularly true with respect to multi-stakeholder organizations that aim to build working consensus across civil society NGO and industry perspectives (Salzman et al. 2024, pages 56-60), as the Protocol does.

For example, the American National Standards Institute (ANSI) requires that the standards development process not be dominated by any single interest category or organization, and that it reflects a balance of interests (ANSI 2025, sections 1.2 and 1.3). ANSI defines balance as requiring that no single interest category constitute a majority of a consensus body (ANSI 2025, section 2.3) and requires additional outreach when this definition is not achieved (ANSI 2025, section 1.3).⁸ In the context of public regulators, the Organisation for Economic Co-operation and Development (OECD) notes that the presence of industry stakeholders in a regulator’s governance body creates a potential for conflicts of interest and can create the appearance of impropriety (OECD 2014, 73).

To assess the balance of the Protocol’s governance structure, I analyzed the composition of the Independent Standards Board and Steering Committee. I collected members’ current affiliations from their official Protocol biographies and grouped them into four categories to illustrate structural patterns of representation (Table 1).⁹

Category	Independent Standards Board	Steering Committee
Business / finance	5	8
Academia / research	4	0
Environmental NGO	0	2
Government / standards	2	1
Total	11	11

In both bodies, business and financial perspectives are over-represented relative to the other categories while government and standard-setting bodies are under-represented. In contrast, the representation of research and environmental NGO perspectives varies starkly across the two bodies, as discussed below.

Independent Standards Board

The Board is primarily composed of members with backgrounds in business / finance or academia / research, with one private-sector governance representative and one former government expert. Notably, there are no environmental NGO representatives on the Board. This results in two sources of decision-making bias.

First, if there is an issue on which the business community has a perspective or interest that is at odds with what the environmental NGO community would prefer, then the Board might not adequately anticipate or resolve these tensions. Similarly, if environmental NGOs were aware of information that was not known to Board members from other backgrounds, then the absence of environmental NGO representation could reduce the quality of information available for a Board decision.

The second and potentially more deleterious impact is the downstream effect on scientific perspectives in the decision-making process. In theory, the Board operates using a decision hierarchy in which scientific integrity is the first and top priority (GHGP 2024c, Annex A). A well-balanced Board would include representatives from environmental organizations alongside representatives from business. Its scientist members could then help mediate stakeholder disagreements—or at least inform them with independent perspectives on scientific matters. But because the body lacks environmental NGO representation, disagreements will likely arise between business and scientific member perspectives directly. This two-party setting pitches scientific perspectives against business perspectives as though scientific Board members are stakeholders themselves, rather than elevate scientific perspectives to reflect the official decision-making hierarchy. As a result, the absence of environmental NGO representation risks making the work of scientist Board members seem political and thus undermines the Protocol’s decision-making hierarchy.

Steering Committee

Unlike the Independent Standards Board, the Steering Committee has two environmental NGO representatives. This helps ensure that environmental NGO perspectives are integrated into a multi-stakeholder process. However, the Steering Committee does not include any members with an academic or research affiliation.

The lack of scientific representation may affect the Committee’s ability to review Board decisions for conformity with Protocol requirements. It is unclear whether any Steering Committee Board members would be personally familiar with the norms of scientific evidence and argumentation, which could be necessary to evaluate whether the Board has in fact prioritized scientific integrity consistent with its official decision-making hierarchy (GHGP 2024c, Annex A). For example, governing bodies are usually familiar with public stakeholder letters but may not be familiar with what it means to receive a public position from an official academic organization or scientific society. Similarly, understanding whether conflicting public letters or Technical Working Group materials accurately represent the scientific literature requires familiarity with academic publishing practices and consensus-building within scientific disciplines, which might not be present on a governing body that lacks representation from the scientific community.

Joint Working Groups

Although there is no public information to describe the full composition of any Joint Working Groups that exist or may be appointed in the future, the lack of any membership disclosure requirement suggests that standards developed jointly between the Protocol and the ISO may be conducted without adequate representation from either scientific experts or civil society. Such an approach would conflict with the generally accepted requirement of balanced representation in private standards-setting processes (ANSI 2025, sections 1.3 and 2.3), the requirements of federal government advisory committees (under the Federal Government Advisory Committee Act, 5 U.S.C. § 1004(b)(2)), and the requirements of negotiated federal rulemaking procedures (under the Negotiated Rulemaking Act, 5 U.S.C. § 563(a)).

Critique #2: Transparency

Technical Working Group Documents

To the Protocol’s credit, the activities of the Technical Working Groups are generally documented in detail on the Protocol’s website. For example, one can access summary slide decks and other substantive materials prepared for each Technical Working Group meeting. Some of these materials also include public disclosures about feedback from the Independent Standards Board, such as slide deck materials indicating that the Board reviewed a certain proposal or provided “pulse check” survey results indicating a general level of support for a proposed direction.

Although the Greenhouse Gas Protocol has published most of the key documents from Technical Working Groups, there is one important exception. The Protocol has not published any of the substantive proposals developed by the Forest Carbon Accounting Technical Working Group in the spring of 2025.

Board Meeting Records

The Protocol website does not include any meeting records from the Independent Standards Board. Although the Board’s terms of reference explicitly require the preparation, approval, and publication of official meeting minutes (GHGP 2024a, section 5.5; GHGP 2025a, section 5.5), and although the Steering Committee has regularly published quarterly meeting minutes, no Board meeting minutes have been published—despite Board meetings having begun in September 2024.

Furthermore, voting on the Independent Standards Board is done by secret ballot, such that votes are not attributed to individual members, even within internal Board meetings. With the exception of the Basis for Conclusions published for the Land Sector and Removals Standard (GHGP 2026b), which provides final voting outcomes but not member-level attributions, there are no public records of Board votes.

Publishing member-level voting records is important to disclose whether a proposal’s support or opposition is concentrated among Board members coming from science or business backgrounds. These details are particularly important to implement the Board’s decision-making criteria, which prioritize scientific integrity (GHGP 2024c, Annex A) but provide no mechanism for the public to see whether Board members’ votes align. Anonymous voting also contrasts sharply with public regulatory practice, where it is generally presumed that each member of a decision-making body casts a public vote.

Complaints Procedure

In May 2025, the Protocol approved a formal Complaints and Concerns Procedure (GHGP 2025b), which is the formal mechanism for addressing grievances in the governance process. This document sets out some process for how complaints are to be received and reviewed but is primarily oriented around complaints received from external stakeholders. It does not describe how to handle complaints about the conduct of Board members or internal allegations of violations of the Protocol’s terms of reference, other than that such complaints are to be “forwarded” to the Steering Committee chair “for adjudication” without elaboration (GHGP 2025b, section 4.3.1).

As written, the Protocol’s grievance procedure lacks the elements necessary for external accountability. There is no requirement that internal governance complaints and their official Protocol responses be publicly disclosed, unlike the requirement that applies to external complaints from stakeholders (GHGP 2025b, section 4.5.2).¹⁰ Nor is there any detail on how adjudication of internal complaints or appeals will be conducted. These approaches are inconsistent with best practices. For example, the American National Standards Institute requires that standards developers have an “identifiable, realistic, and readily available mechanism for the impartial handling of procedural appeals regarding any action or inaction” (ANSI 2025, section 2.8.1). Similarly, best practice in public regulation is to require both internal and external review opportunities, with an outline of each process made publicly accessible (OECD 2015, 84-85). Requiring “adjudication” without elaboration is insufficient, particularly if the underlying complaint and its resolution are kept confidential.

The lack of accountability mechanisms risks undermining the enforcement and integrity of the Protocol’s own governance rules. In January 2026, I and another colleague on the Independent Standards Board filed a formal complaint concerning the Forest Carbon Accounting agenda item, which was left unresolved in the Land Sector and Removals Standard. We also made timely written objections to the Land Sector and Removals Standard Basis for Conclusions document (GHGP 2026b), noting that a complaint had been filed alleging violations of the Board’s terms of reference on this matter and that these violations undermined the scientific integrity of the Board’s deliberations.

Although the Board’s terms of reference require all Basis for Conclusions documents to record any Board member’s objection (GHGP 2025c, section 5.54), the published Basis for Conclusions did not refer to our objections nor document the fact that we had filed a formal complaint prior to the document’s publication. Beyond violating the Protocol’s internal rules, this outcome is also inconsistent with best practices adopted by the American National Standards Institute, which requires that negative votes be reported along with any reasons provided (ANSI 2025, section 2.7).

Our complaint was still under review when this report was first published. In late April 2026, however, the Chair of the Steering Committee adjudicated our complaint. My colleague and I were provided with a brief official response document but were told that we are not allowed to share it with anyone else, including other Board members. The Chair of the Steering Committee decided that there will be no public disclosure of the complaint or the official Protocol response. As of this writing, it is unclear whether any of the documents developed by the technical working group or the Board will be made public.

These developments raise significant concerns about the integrity of the Protocol’s governance. Because Independent Standards Board members are subject to legally binding non-disclosure agreements, there is no means by which Board members can raise concerns if they perceive that the standard development process has deviated from its mandatory terms of reference, other than to file a formal internal complaint or resign. But if formal complaints can be adjudicated in private without any transparency or public accountability, then the Protocol’s grievance mechanism does not provide for any external mechanism to ensure that the Protocol’s overall governance rules are being followed in practice. And without any substantive standards for how complaints about Board operations are to be adjudicated, there is no basis to conclude that the internal grievance process is sufficiently robust to uphold the Protocol’s governance rules.

ISO Standard Development

Much of the work of standard development occurs in the context of Technical Working Groups. Going forward, some and perhaps much of this work will shift instead to co-branded Joint Working Groups operated jointly by the Protocol and the ISO. As discussed above, however, the terms of reference for the new Joint Working Groups do not require reasonable balance between stakeholder groups and they do not require public disclosure of membership. As a result, without additional process changes, standard development could shift to confidential modes of work in which a non-public group of experts would develop proposed rules.

Recommendations

The Greenhouse Gas Protocol develops and maintains a critically important greenhouse gas accounting standard. The Protocol has demonstrated the ability to improve the quality of its standards over time and expand its influence within the private and public sectors. As the broader impact and relevance of the Protocol’s work grows, it is all the more important for the Protocol’s governance mechanism and grievance procedure to rise to meet the level of stakeholder expectations and best practices for standards development. But a lack of stakeholder representation in decision-making bodies and the lack of consistent transparency practices puts the Protocol’s legitimacy at risk. To improve the Protocol’s governance regime, I recommend the following changes:

• Expand environmental and scientific representation in the Protocol’s decision-making bodies. The terms of reference for the Steering Committee and Independent Standards Board should be modified to include mandatory representation from individuals working for environmental nonprofit organizations as well as independent scientists. Having representation from both stakeholder groups in each decision-making body is essential to maintaining balance, ensuring that scientific perspectives can be heard independently from business and environmental perspectives, and implementing the Protocol’s stated commitment to scientific integrity as the top criterion in the decision-making hierarchy.
• Require transparent and balanced working groups. The terms of reference for Joint Working Groups and Technical Working Groups should be aligned and reformed, such that all members are publicly disclosed on the Protocol’s website and there is a mandatory requirement to achieve reasonable balance across stakeholder groups. Commitments to make best efforts are insufficient. Secret and/or unbalanced working groups undermine confidence in the Protocol’s work and risk creating greater tensions in the stakeholder community.
• Publish meeting minutes with transparent votes. The Independent Standards Board should publish regular meeting minutes, as is already required by its terms of reference but not achieved in practice. Meeting minutes from the Board and Steering Committee should record how each member voted on each decision item.
• Publish formal complaints and official responses. The Greenhouse Gas Protocol should publicly disclose all formal complaints and the official response to any such complaints. The complaints procedure should be amended to require this outcome in all cases and to set forth a formal process for adjudication.
• Board members should not be subject to non-disclosure agreements. To ensure that governance requirements are respected and to illustrate that the Protocol is operating with integrity, Board members should not be subject to legally binding non-disclosure agreements. It might be reasonable to provide for the dismissal of Board members who violate a voluntary confidentiality commitment through public disclosure, but a well-functioning organization that follows its own rules does not need to restrict Board members’ legal ability to speak about their experiences.

References

ANSI (American National Standards Institute). 2025. “ANSI Essential Requirements: Due Process Requirements for American National Standards.” January. https://www.ansi.org/resource-center/american-national-standards.

Green, Jessica F. 2014. Rethinking Private Authority: Agents and Entrepreneurs in Global Environmental Governance. Princeton University Press. (See Chapter 5.)

GHGP (Greenhouse Gas Protocol). 2024a. “Steering Committee: Terms of Reference.” Version 1.0, July 18. https://ghgprotocol.org/sites/default/files/2024-09/03_Steering%20Committee%20ToR_vfinal.pdf.

———. 2024b. “Technical Working Groups: Terms of Reference.” Version 1.0, September 19. https://ghgprotocol.org/sites/default/files/2024-09/Technical-Working-Group-Terms%20of%20Reference.pdf.

———. 2024c. “Governance Overview.” Version 1.1, November 26. https://ghgprotocol.org/sites/default/files/2024-09/Governance-Overview.pdf.

———. 2025a. “Independent Standards Board: Terms of Reference.” Version 1.1, March 18. https://ghgprotocol.org/sites/default/files/2024-09/04_Independent%20Standards%20Board%20ToR_vfinal.pdf.

———. 2025b. “Complaints and Concerns Procedure.” Version 1.0, May 28.  https://ghgprotocol.org/sites/default/files/2025-08/Complaints-and-Concerns-Procedure.pdf.

———. 2025c. “Release: ISO and GHG Protocol Announce Strategic Partnership to Deliver Unified Global Standards for Greenhouse Gas Emissions Accounting.” September 9. https://ghgprotocol.org/blog/release-iso-and-ghg-protocol-announce-strategic-partnership-deliver-unified-global-standards.

———. 2025d. “Standard Development and Revision Procedure.” Version 1.2, November 25. https://ghgprotocol.org/sites/default/files/2024-12/Standard-Development-and-Revision-Procedure-20241126.pdf.

———. 2025e. “Joint Working Group between GHG Protocol and ISO: Terms of Reference.” Version 1.0, December 15. https://ghgprotocol.org/sites/default/files/2026-04/JointWorkingGroup_ToR_20251215.pdf.

———. 2026a. “Land Sector and Removals Standard: Agriculture and CO2 Removal Technologies.” Version 1.0, January 30. https://ghgprotocol.org/sites/default/files/2026-01/Land-Sector-and-Removals-Standard.pdf.

———. 2026b. “Basis for Conclusions for Land Sector and Removals Standard v1.0.” January 23. https://ghgprotocol.org/sites/default/files/2026-01/LSR-BasisforConclusions-20262301.pdf.

Organisation for Economic Co-operation and Development (OECD). 2014. “The Governance of Regulators OECD. Best Practice Principles for Regulatory Policy.” http://dx.doi.org/10.1787/9789264209015-en.

Salzman, James, Sarah E. Light, and Michael P. Vandenbergh. 2024. Private Environmental Governance. Foundation Press. (See Chapter 8.)

Welton, Shelley. 2022. “Neutralizing the Atmosphere.” Yale Law Journal 132(1), 171-249. https://www.yalelawjournal.org/feature/neutralizing-the-atmosphere.  

Supplemental Graphics

Name	Affiliation	Classification
Alexander Bassen (Chair)	University of Hamburg	Academia / research
Anthony Cheung	Polymer Capital Management	Business / finance
Inhee Chung	Samsung Electronics	Business / finance
Danny Cullenward	University of Pennsylvania	Academia / research
Pieter Gagnon	National Renewable Energy Laboratory	Academia / research
Suzanne Greene	Dow	Business / finance
Owen Hewlett	Gold Standard Foundation11	Government / standards
Stuart Jefford	The LEGO Group	Business / finance
Heather Keith	Griffith University	Academia / research
Viola Lutz	Moody’s	Business / finance
Paul Munter	No current affiliation given; formerly U.S. Securities and Exchange Commission	Government / standards

Name	Affiliation	Classification
Wataru Baba	Green Impact Labs	Business / finance
Yamide Dagnet	National Resources Defense Council	Environmental NGO
Craig Hanson	World Resources Institute	Environmental NGO
Richard Manley	CPP Investments12	Business / finance
Julia Maris	ENGIE	Business / finance
Geraldine Matchett (Chair)	ABB, Nestlé, and Swiss Re	Business / finance
Kathleen McGinty	Johnson Controls	Business / finance
Ovais Sarmad (Vice Chair)	No current affiliation given; formerly United Nations Framework Convention on Climate Change	Government / standards
Ann Tracy	Colgate-Palmolive	Business / finance
Dominic Waughray	World Business Council on Sustainable Development	Business / finance
Yongping Zhai	Tencent	Business / finance

1. For a thorough critique of the corporate net-zero paradigm, which is built on top of the Protocol’s greenhouse gas accounting rules, see Welton (2022). [↩]
2. To the best of my knowledge, there is no public information about the identity of Board observers or the organizations they represent. [↩]
3. There are no minimum or maximum membership numbers for Technical Working Groups, though the terms of reference provide an expectation of at least 30 members (GHGP 2024b, section 4.1.1). [↩]
4. For example, in the only ratified decision taken as of this writing, the Steering Committee’s Basis for Conclusions states that its “remit does not include revisiting the content of the standard and shall be limited to whether due process was followed” (GHGP 2026b, section 4.2). [↩]
5. The Red Flag review provided an opportunity for the LSR Advisory Committee to express views about the work the secretariat team conducted. For additional detail, see GHGP (2026b, sections 3.3 and 5.3). [↩]
6. The text of these provisions is grammatically distinct from other Protocol governance documents, which use “may” / “should” / “shall” language to indicate permissive, recommended, and mandatory outcomes, respectively. Although the substantive outcome in both cases depends on how the Board and Secretariat implement their roles, the shift away from the commonly understood “may” / “should” / “shall” terminology is notable and technically requires less of both the Board and Secretariat. [↩]
7. As discussed below, the Independent Standards Board is required to publish public meeting minutes, which would presumably document the fact of any Joint Working Group formation, but no such meeting minutes have been published to date. Thus, the fact of any potential appointment might not be publicly disclosed, in addition to the potentially confidential membership of any such hypothetical appointment. [↩]
8. Because the Protocol is not an ANSI-Accredited Standards Developer, it is not required to follow these provisions. They are nevertheless relevant, both because the Protocol may seek to become accredited in the future and because ANSI is considered an authority on best practices in standards development. [↩]
9. In classifying individual members, I do not intend to express a value judgment about their contributions. Nor do I draw any inferences about my colleagues’ motivations. The sole purpose of this exercise is to evaluate the representation of different stakeholder communities. Full details are provided in Table 2 and Table 3.   [↩]
10. These complaints can be found at the Protocol’s governance repository by selecting “Overarching” as the entry for “Governing Body.” [↩]
11. Gold Standard is a carbon credit standard-setting mechanism and registry. It is classified as “Government / standards” here to reflect its nature as a private-sector governance body. [↩]
12. CPP Investments is a Canadian Crown Corporation that manages the Canadian Pension Plan. It is classified as “Business / finance” here because it is fundamentally an investment management organization, rather than a government body. [↩]