COP26 Action Plan: Three Urgent Steps to Standardize Emissions Reporting

The report argues that current GHG accounting systems rely too heavily on approximations and are unsuitable for comparing scope 3 emissions between companies. To resolve this, RMI proposes a framework consisting of unified accounting principles that prioritize primary data, a technical architecture based on distributed ledger technology to track embodied carbon at the product level, and the creation of "digital twins" of carbon emissions to enable emissions to function as a unit of trade. This system aims to transform climate intelligence into actionable business intelligence and support the development of a global carbon market under Article 6 of the Paris Agreement.

• The existing GHG Protocol is insufficient for inter-company comparisons because it was "not designed to support comparisons between companies based on their scope 3 emissions" and provides multiple options for allocating the same emissions.
• To improve reporting accuracy, the document advocates for a shift toward "upstream primary data"—information collected directly from a plant or process—rather than relying on averages or standard "emissions factor" calculations.
• For the steel sector specifically, the report suggests two critical harmonization steps: adopting a "fixed-boundary approach" for product-level comparability regardless of ownership, and creating separate allocation rules for ore- and scrap-based production to drive decarbonization investments.
• RMI proposes a technical architecture for tracking embodied emissions using "distributed ledger technology," which would allow emissions to be digitized as a "digital twin" of a product, effectively making emissions a "unit of trade."
• The report notes a trend toward integrating GHG inventories into financial disclosures, citing that the International Financial Reporting Standards Foundation and the US Securities and Exchange Commission are considering such requirements.

APA

Natali, P. (2021). COP26 Action Plan: Three Urgent Steps to Standardize Emissions Reporting. RMI. https://rmi.org/app/uploads/2021/11/rmi_cop26_action_plan.pdf

Chicago

Natali, Paolo. COP26 Action Plan: Three Urgent Steps to Standardize Emissions Reporting. RMI, 2021. https://rmi.org/app/uploads/2021/11/rmi_cop26_action_plan.pdf.

Wikipedia

{{cite report |last1=Natali |first1=Paolo |title=COP26 Action Plan: Three Urgent Steps to Standardize Emissions Reporting |publisher=RMI |date=October 2021 |url=https://rmi.org/app/uploads/2021/11/rmi_cop26_action_plan.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{natali2021cop26, author = {Natali, Paolo}, title = {{COP26 Action Plan: Three Urgent Steps to Standardize Emissions Reporting}}, institution = {RMI}, year = {2021}, month = oct, url = {https://rmi.org/app/uploads/2021/11/rmi_cop26_action_plan.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }