Companies already generate environmental data from procurement contracts, energy certificates, supplier agreements, and climate investment records. The GHG Protocol’s Actions and Market Instruments (AMI) framework aims to turn that scattered evidence into structured reporting that goes beyond the traditional Scope 1, 2, and 3 inventory model.
For years, green steel procurement, sustainable aviation fuel (SAF) purchases, power purchase agreements, and nature-based carbon programs have not appeared consistently in corporate GHG inventories. The money moves, the climate outcomes may be real, but most reports have no standardized home for these investments. That gap creates inconsistent “beyond value chain” claims, weak comparability for investors, and rising greenwashing risk for regulators and procurement teams.
On March 31, 2026, the GHG Protocol released its Actions and Market Instruments (AMI) Phase 1 White Paper, opening a 60-day public consultation through May 31, 2026 that could reshape how companies measure and communicate their full climate contribution. This is not a minor procedural update. The AMI framework proposes moving beyond the single-inventory model that has defined corporate GHG accounting since the original Corporate Standard was published in 2001.
This guide explains why the existing framework falls short, what the four-component AMI reporting architecture proposes, what it means for your operations and reporting, savings, and operational decisions in practice, how to prepare before the consultation closes, and how to build the data foundations that a 2027 draft standard will require.
Why the GHG Protocol AMI framework matters for corporate carbon accounting
The current Scope 1, 2, and 3 model has a structural blind spot
The current Corporate Standard divides emissions into Scope 1 (direct), Scope 2 (purchased energy), and Scope 3 (value chain). This model is powerful, but it was designed for a world where the primary objective was measuring what a company emits. It was not designed to capture what a company actively does to drive decarbonization beyond its own operations.
Consider a manufacturing company that co-funds a green steel pilot program with a supplier, purchases SAF certificates to support aviation decarbonization, or invests in a regenerative agriculture initiative in its supply shed. None of these activities reduce that company’s Scope 1, 2, or 3 numbers in a way that is transparent or comparable. The result is a reporting environment full of beyond-value-chain claims that vary wildly in methodology, quality, and credibility. See our scope emissions complete guide for how the current inventory model works today.
Investors, regulators, and buyers expect more than a single inventory
This creates problems for investors trying to assess climate ambition, regulators trying to police greenwashing, and companies themselves trying to differentiate genuine action from marketing noise. The AMI initiative is part of a broader global effort to harmonize carbon accounting standards that has accelerated since the COP30 Action Agenda. The GHG Protocol’s partnership with ISO, the ongoing Scope 2 consultations, and the AMI framework are all threads in the same effort: building a global system for corporate climate transparency that is rigorous enough to support regulatory enforcement and credible enough to withstand investor scrutiny.
For sustainability and finance teams, this means the standards landscape will continue to evolve rapidly through 2027 and beyond. The Carbon Footprint Collection tracks these developments as they unfold. Companies that stay ahead of this curve will have a structural advantage: their reporting will be credible before it is required, and their climate narratives will be grounded in methodology that survives scrutiny.
AMI connects directly to Scope 2 and electricity sector work
The AMI initiative builds directly on the GHG Protocol’s ongoing Scope 2 and electricity sector consequential accounting consultations. If your company has significant renewable energy procurement, you should be tracking both workstreams in parallel, not treating them as separate conversations. Read our analysis of the GHG Protocol Scope 2 and EFRAG response to understand how market-based accounting is already shifting.
What the AMI framework proposes and why implementation often fails
Four complementary reporting components
The AMI White Paper introduces a multi-statement reporting architecture built on four complementary components:
Physical GHG inventory. This is the existing Scope 1/2/3 model, unchanged. It remains the foundation.
Market-based inventory. This captures the emissions impact of contractual procurement decisions: electricity certificates, SAF, green hydrogen, green steel, and similar market instruments. Companies would report how their procurement choices affect the emissions trajectory of the markets they participate in.
GHG impact statement. This applies consequential accounting methods to measure the real-world climate impact of investments and interventions. Rather than attributing emissions to a company, it asks: what would the emissions trajectory look like without this company’s action?
Non-GHG indicators. Technology adoption rates, financial investment flows, and other metrics that do not reduce to a CO2-equivalent number but still carry meaningful climate signal. For example, a company funding early-stage green hydrogen infrastructure is contributing to a transition that will reduce emissions over time, even if the immediate CO2 impact is not yet measurable.
The framework is explicit that these four components are complementary, not competing. The physical inventory stays central. The additional statements provide context, demonstrate intent, and create a credible space for companies to communicate climate investments that currently live in an unregulated grey zone.
Why companies struggle to prepare today
Most organizations treat climate investments as marketing narratives or isolated procurement line items rather than governed environmental data. Certificates, PPAs, SAF purchases, and green procurement contracts sit in finance systems, sustainability spreadsheets, and supplier portals with no shared taxonomy. When the AMI standard arrives, those fragmented records will not support the granular, multi-statement reporting the White Paper describes. Without a carbon footprint data backbone that can absorb new statement types, teams will rebuild from scratch under deadline pressure.
Tip: Before you respond to the AMI consultation, freeze a written inventory of every market instrument and beyond-value-chain investment your company claims today. Map each item to a data owner and evidence source. Ambiguous ownership is what turns a credible climate narrative into a greenwashing finding when standards tighten.
From data to use cases: one base for AMI and multi-framework reporting
One dataset, multiple outputs
The same environmental and procurement data base can feed your physical GHG inventory, emerging AMI statements, SBTi emission reduction targets, and regulatory disclosures such as double materiality under CSRD. Defining contractual instruments, investment evidence, and calculation methods once and reusing them avoids duplication. That is especially important when market-based accounting for green procurement will likely become a compliance expectation for energy-intensive industries, not just a reporting option.
Sector-specific implications vary
For energy-intensive industries, market-based accounting for green procurement will likely become a compliance expectation. For financial sector companies, the GHG impact statement methodology could transform how they measure portfolio-level climate contributions. In all cases, the AMI framework is explicitly designed to distinguish credible climate investments from superficial ones. The “solid quality requirements” mentioned in the White Paper signal that the GHG Protocol intends to draw a clear line.
Automated data collection from ERP, procurement, and supplier systems reduces manual work and improves consistency for AMI readiness and for multi-framework reporting from the same governed dataset.
Mapping green procurement, certificates, and climate investments for AMI readiness? We show how Dcycle links source contracts to inventory and reporting outputs.
Talk to our teamCommon challenges when preparing for AMI and how to address them
Fragmented market instrument data
Challenge: Environmental data and evidence for PPAs, RECs, SAF certificates, green steel contracts, and beyond-value-chain investments are spread across finance, procurement, sustainability, and supplier systems.
Approach: Define ownership per instrument type and process. Map where data and evidence live; then introduce a central layer that consolidates and versions records. Schedule regular reviews so AMI-related claims stay proactive and defensible, not reactive before each reporting cycle.
Greenwashing risk and weak documentation
Challenge: The AMI framework is explicitly designed to distinguish credible climate investments from superficial ones. Companies whose climate narratives rely on poorly documented market instruments face rising scrutiny.
Approach: Audit current climate investment claims. Identify which rest on robust methodology and which are vulnerable under tighter standards. Align narrative claims with traceable evidence before the 2027 draft standard arrives.
Scope 2 and AMI workstreams running in parallel
Challenge: Renewable energy procurement teams often track Scope 2 market-based rules separately from broader climate investment programs, creating inconsistent methodologies.
Approach: Connect Scope 2 procurement data with AMI-relevant instruments in one governed layer. Track both the GHG Protocol Scope 2 consultations and AMI development as a single standards roadmap, not two unrelated projects.
How to start: first steps before May 31, 2026
Respond to the consultation if you have a perspective
The GHG Protocol consultation is open to all stakeholders through May 31, 2026. If your company has a perspective on how market instruments or climate investments should be accounted for, this is the moment to contribute. The standards that emerge from this process will shape corporate reporting for a generation.
Audit claims, map instruments, and assess data infrastructure
Every sustainability team should be doing three things now:
- Audit your current climate investment claims. Identify which claims rest on robust methodology and which are vulnerable to scrutiny under tighter standards.
- Map your market instrument exposure. Understand which certificates, PPAs, SAF purchases, and green procurement contracts you hold and how they would be classified under the multi-statement framework.
- Assess your data infrastructure. The AMI framework will require more granular, more diverse data than the existing Corporate Standard. Identify gaps before they become compliance problems.
A full draft standard is expected in 2027. That timeline may feel distant, but the strategic implications are immediate. Companies that design programs with robust methodology now will be far better positioned than those who scramble to retrofit claims later.
Closing the consultation window on May 31? Book a session to see how others structure market instrument data before the 2027 draft standard lands.
See the demoWhy Dcycle is the right solution for AMI readiness
Choosing a data platform for AMI readiness means centralizing environmental data, contractual instruments, and investment evidence from procurement, finance, and supplier sources, keeping full traceability, and producing content aligned with evolving GHG Protocol standards without unsustainable manual effort.
We are not auditors or consultants. We are a data platform for companies that need to centralize, manage, and report environmental data with rigour and efficiency. Our goal is for each organisation to collect all its inventory data, market instruments, and investment evidence once and use it for physical inventories, emerging AMI statements, SBTi targets, CSRD, and internal use without duplication.
How Dcycle works for AMI readiness
Centralise environmental data from any source (sites, energy, procurement, ERP, suppliers) and structure them by scope, instrument type, and evidence with traceability from source to reporting outputs.
Generate and maintain content compatible with GHG Protocol inventories, multi-framework reporting, CSRD, and double materiality under CSRD from the same dataset.
At Dcycle, we work daily with companies navigating the gap between what their GHG inventories show and what their climate investments actually represent. The AMI consultation formalizes a problem our customers have been asking us about for years: how do you account for climate action that falls outside the traditional Scope 1/2/3 box?
Why companies choose Dcycle for evolving carbon standards
Built for rigour and traceability: Every piece of evidence links to its source and process. The same level of control required for audits and investor scrutiny, applied to market instruments and climate investments.
One base for inventories and emerging AMI statements: Use one dataset for physical inventories, procurement instruments, regulatory reporting, and internal dashboards. No duplication, no inconsistency.
Integration with existing systems: We connect to ERP, procurement, sites, and supply chain sources to automate collection and reduce manual effort.
Explore the full Carbon Footprint Collection for guides on scope accounting, SBTi, and standards updates as AMI moves toward a 2027 draft.
3 critical success factors for AMI readiness
Before you invest in tools or consultants, three capabilities determine whether your organization can adopt the four-component AMI architecture when the draft standard arrives.
1. Market instrument data integration
Data for PPAs, RECs, SAF certificates, green steel contracts, and beyond-value-chain investments lives in finance systems, procurement platforms, supplier portals, and sustainability spreadsheets. A proper data platform must integrate directly with these sources, not rely on manual assemblies before each reporting cycle.
What to look for:
- Connectors to ERP, procurement, and supplier systems
- Automated extraction from contractual and operational sources
- Data validation and reconciliation capabilities
- API capabilities for custom integrations
Automated data collection is the starting point for any company that wants consistent instrument records across sites and business units.
2. Multi-statement reporting architecture
The AMI framework requires four complementary outputs from overlapping data: physical inventory, market-based inventory, GHG impact statement, and non-GHG indicators. You need hierarchical reporting (site to group), consistent methodologies across jurisdictions, and the ability to link each claim to underlying evidence.
What to look for:
- Multi-site data architecture
- Instrument-level traceability and versioning
- Consolidated and segmented reporting
- Support for evolving GHG Protocol statement types
3. Evidence management and quality controls
The White Paper’s “solid quality requirements” signal that superficial claims will not survive. Evidence includes procurement contracts, certificate registries, investment agreements, supplier attestations, and calculation methodologies. Investors and auditors need consistent evidence and clear methodology.
What to look for:
- Document repository with metadata and search
- Evidence linking to specific instruments, investments, and claims
- Version control and expiration tracking
- Audit trail and access controls
Conclusion
The GHG Protocol’s AMI initiative is a fundamental shift in how corporate climate action will be measured and communicated. The 60-day consultation through May 31, 2026 is short. A full draft standard is expected in 2027, but the companies that treat 2026 as a preparation year rather than a waiting year will be the ones best positioned when the standard arrives.
The firms winning on climate credibility are not just tracking Scope 1, 2, and 3. They use governed environmental data to document market instruments with traceable evidence, align Scope 2 and AMI workstreams, turn climate investments into structured statements instead of marketing claims, and serve reporting, savings, and operational decisions from a single source of truth. Preparation time drops because data flows from operational systems instead of annual spreadsheet scrambles, and contradictions between inventory numbers and investment narratives disappear when one dataset feeds every output.
Dcycle helps you collect environmental information once and distribute it to every use case that matters: physical inventories, emerging AMI statements, SBTi targets, CSRD disclosures, and internal dashboards. With Dcycle, companies can control their carbon accounting evolution, shorten standards-transition preparation, and ensure full traceability of market instruments through the AMI implementation timeline and beyond.
Ready to prepare market instrument data for the AMI framework and 2027 draft standard? Request a demo tailored to your procurement and reporting setup.
Request a demoFrequently asked questions (FAQs)
What is the GHG Protocol AMI framework and when was it published?
The Actions and Market Instruments (AMI) framework is a GHG Protocol initiative to expand corporate carbon accounting beyond the traditional Scope 1, 2, and 3 inventory. On March 31, 2026, the GHG Protocol released its AMI Phase 1 White Paper, opening a 60-day public consultation through May 31, 2026. A full draft standard is expected in 2027. The framework addresses climate investments such as green steel procurement, SAF purchases, PPAs, and nature-based programs that currently lack a standardized reporting home. See the Carbon Footprint Collection for related guides.
What are the four components of AMI reporting?
The AMI White Paper proposes four complementary components: a physical GHG inventory (the existing Scope 1/2/3 model, unchanged), a market-based inventory (capturing contractual procurement impacts such as RECs, SAF, green hydrogen, and green steel), a GHG impact statement (using consequential accounting to measure real-world climate impact of investments), and non-GHG indicators (metrics like technology adoption rates and financial investment flows that carry climate signal without reducing to CO2 equivalents). These components are designed to work together, not replace the physical inventory. Read our scope emissions complete guide for the current inventory foundation.
How does AMI relate to Scope 2 and market-based accounting?
The AMI initiative builds directly on the GHG Protocol's ongoing Scope 2 and electricity sector consequential accounting consultations. The market-based inventory component extends the logic of market-based Scope 2 accounting to a broader set of contractual instruments. Companies with significant renewable energy procurement should track both workstreams in parallel. Our GHG Protocol Scope 2 and EFRAG response explains how market-based rules are already evolving.
What should companies do before the May 31, 2026 consultation closes?
Three priorities: audit current climate investment claims to identify which rest on robust methodology, map market instrument exposure (certificates, PPAs, SAF, green procurement contracts) and classify them under the multi-statement framework, and assess data infrastructure for the more granular reporting AMI will require. Stakeholders with perspectives on how market instruments should be accounted for should also submit consultation responses before the deadline. Companies that prepare in 2026 will be better positioned for the 2027 draft standard.
Does AMI increase greenwashing risk for companies?
The AMI framework is explicitly designed to distinguish credible climate investments from superficial ones. The White Paper references solid quality requirements that signal tighter scrutiny of beyond-value-chain claims. Companies whose climate narratives rely on poorly documented market instruments face rising risk as standards mature. Treating the consultation as a warning signal and strengthening evidence now reduces exposure when the draft standard arrives. Aligning claims with traceable data also supports SBTi emission reduction targets and regulatory reporting.
Why is Dcycle a strong fit for AMI readiness?
Because Dcycle is built for environmental data rigour with enterprise-grade capabilities. Unlike generic platforms, Dcycle centralises inventory data, market instruments, and investment evidence from the systems teams already use: ERP, procurement, sites, and supplier records. Multi-statement reporting architecture, automated evidence collection, complete audit trails, and multi-framework reporting from one dataset make standards transitions a routine update, not an emergency scramble. Explore the Carbon Footprint Collection or request a demo to see how it works for your operation.