“You can’t manage what you can’t measure,” or so the axiom goes. Whether one believes in the absolute truth of that statement, its underlying logic has long caused handwringing among climate experts seeking a way to count and curb greenhouse gas emissions generated by countries, companies, and cities.
Yet, a milestone was reached this summer. On July 29th, two technical expert bodies, the GHG Protocols and the International Organization of Standards (ISO), made a breakthrough in the decades-long collective project to build a common, consistent and comprehensive set of rules to measure carbon emissions. Both bodies announced that they “will combine their corporate carbon accounting standards into a single, harmonized global accounting standard.”
The process to forge these standards has been imperfect and the alarm has been sounded by scientists and other experts around the amount of corporate influence that have shaped the rules particularly around how land-based emissions will be counted.
The criticisms of the emerging GHG Protocol–ISO standard must be taken seriously, and close scrutiny will be needed to prevent weak rules and loopholes from eroding the considerable benefits of a strong unified framework. Done well, harmonization can, as the CEO of the GHG Protocol put it, “simplify reporting, reduce duplication, and provide greater consistency across markets and jurisdictions…in turn allow[ing] companies to spend more time reducing emissions.”
But alongside this push toward a common standard, a separate corporate campaign has inserted itself into the debate — seeking to fundamentally dilute and recast carbon accountability by shifting responsibility away from major emitters and their financiers.
Most of the world welcomed the move when the GHG Protocol and ISO previewed their historic partnership last September. ExxonMobil — one of the world’s largest fossil fuel producers and super emitters — instead co-engineered Carbon Measures, a project to establish a competing emissions-accounting framework that threatens to splinter support for a common global standard before that consensus is fully locked in.
Carbon Measures launched with a first cohort of fossil energy and other heavy-emitting corporate giants, including ADNOC, as well as major industrial companies involved in manufacturing, mining, and transport. A single major global bank, Banco Santander, also lined up to endorse this rival and ill-defined initiative. Within the same week as Carbon Measures’ launch, ExxonMobil sued the state of California over its climate risk and emissions disclosure regulations in a lawsuit that challenged the accuracy and authority of the GHG Protocols as an underlying framework for the laws.
The presence of a major bank in that founding coalition matters. For financial institutions, Scope 3 emissions are not peripheral: they include the emissions associated with lending, underwriting and investment portfolios, which can account for an estimated 95 to 100% of a financial institution’s climate footprint. Any accounting system that narrows, transfers, or minimizes responsibility for Scope 3 emissions therefore has enormous consequences not only for fossil fuel producers, but for the banks financing them.
Santander would soon provide an early illustration of why that matters. In 2026, the bank replaced its existing 2030 target for reducing absolute oil and gas emissions with a weaker approach that shifted toward carbon-intensity metrics and narrowed its commitments to operational emissions, leaving Scope 3 — including financed oil and gas emissions — outside any specific alignment target. More on that below.
Since first launched, Exxon-Mobil has worked to disguise the oil major’s involvement with Carbon Measures by stacking its secretariat with a battery of credentialed and “neutral” experts, forming a technical panel, and deliberately recruiting other heavy emitters and major global companies to endorse the project. Yet despite this smokescreen, Carbon Measures is an invention of Exxon-Mobil and its purpose is to confuse, divide, distract, and delay efforts to measure and disclose emissions. Exxon has run this playbook before, and they have been called out for it. Thanks to the painstaking FOIA and investigative work of the #ExxonKnew project, it is now public record that Exxon was aware of the dangers and harms of the emissions caused by its products and covered up that knowledge for decades with a well-monied and elaborately orchestrated campaign to cast doubt on the science and spread disinformation to discourage climate policy and action.
Exxon ran out the clock on denying that human-caused burning of fossil fuels is driving global heating and climate change, which is now an established fact backed by the consensus of at least 99% of world scientists and grounded in peer-reviewed scientific literature, so they evolved their strategy while preserving many of their tactics. Exxon also understands that it is hard to manage what you can’t measure and so its new target is to undermine the emerging consensus methodology for counting emissions. Carbon Measures has particularly taken aim at ‘Scope 3’ emissions, best explained as the emissions produced along a company’s or a financial institution’s value chain.
That makes Scope 3 the crux of the fight for both fossil fuel producers and their financiers: for oil and gas companies, it captures the emissions generated when their products are ultimately burned; for banks, it captures the emissions associated with the companies and projects they finance.
What Exxon’s Carbon Measures Would Actually Measure
Although Carbon Measures is yet to publish any detailed guidance for the accounting framework they are advocating is needed beyond a landscape review published in August, the concept of an “e-ledger” or “e-liability” model is peppered throughout the initiative’s website, document and blog post repository, and press and public remarks. Furthermore, the founders of the E-ledgers Institute co-chair Carbon Measures’ Technical Expert Panel.
In an e-ledger model the emissions are packageable units that can be transferred and passed down a value chain. In other words, emissions created at each stage in a product value chain are inherited by the next supplier (or purchaser) in the chain and then transferred when they sell or hand over the product to the next stakeholder in the supply chain, transferring not only the volume of emissions they inherited but any additional emissions produced at their stage of the value chain.
In this system, emissions stay with a product, accumulating as the product moves through its value chain, becoming an embedded part of the product that a buyer agrees to take over the responsibility for from the seller until they in turn sell the product, this cycle will repeat until you reach the end user. Defenders of e-ledgers claim it is easier to count accumulated emissions at the end of product chains rather than trying to count, attribute and categorize the emissions at every point along the value chain.
Critics of e-ledgers emphasize that transferring emission units when a product is sold from the seller to the buyer eventually lands “emissions liability” with the end consumer and erases it from the corporate accounts of the seller or the actual producer of the product.
You can see why a fossil fuel company, like Exxon, or a carbon-intensive industrial corporation, like Honeywell (an early endorser of Carbon Measures), would support this model. Under an e-ledger model the “downstream emissions” of their products, including all the emissions released when fossil fuels are burned or appliances are switched on, would be transferred off the “balance sheets” or corporate accounts of corporate producers and would need to be accounted for by the individuals and governments using the products.
The same shift has potentially enormous consequences for banks. If responsibility for financed or value-chain emissions can be narrowed, transferred, or treated as primarily belonging elsewhere in the economy, financial institutions can substantially shrink the portion of their climate footprint for which they accept direct responsibility.
E-ledger systems are, therefore, not neutral — they change who is accountable, not just how emissions are counted. The upshot of an e-ledger system is that they can make any fossil fuel major, company, or financial institution with sizable scope 3 (or value chain emissions) look a lot cleaner than they are and facilitate these companies in evading responsibility for the costs and damages intrinsic to the use of their products. By promoting an e-ledger system Carbon Measures is pursuing an agenda that:
- Allows companies to avoid accountability for downstream emissions, especially fossil fuel combustion.
- Reframes responsibility as belonging to consumers rather than producers.
- Introduces a parallel system at the exact moment the world is moving toward unified global standards.
The companies involved in the Carbon Measures project are either knowingly complicit in this agenda or they have been naively taken in by the slick marketing and public relations campaign waged to enlist more supporters. It is deeply concerning that Carbon Measures has been growing its supporter ranks and making inroads with large mainstream brands including financial institutions whose climate commitments depend heavily on how Scope 3 emissions are counted. Bank of America quietly joined Carbon Measures, becoming the second major global bank to enlist. According to the latest Banking on Climate Chaos report, Bank of America is the world’s fourth-largest cumulative financier of fossil fuels since 2021 and was the second-largest fossil fuel financier in 2025. By throwing its support behind Carbon Measures, Bank of America has either deliberately or unintentionally aligned itself with an initiative associated with accounting tricks to write off downstream emissions — including the Scope 3 portfolio emissions where its huge carbon footprint is concentrated— not only conferring powerful brand validation on Carbon Measures but building cover for other banks and financial institutions to increasingly dodge accountability for their massive climate impact.
Santander Shows Why the Accounting Fight Matters
What’s worse is that the e-ledger underpinnings of Carbon Measures are already showing its fingerprints in the climate and decarbonization policy revisions of certain endorsers. Earlier this year, Santander dropped its existing 2030 target for reducing its absolute oil and gas emissions and supplanted it with a much weaker approach that shifts away from absolute emissions reductions toward carbon-intensity targets, while narrowing Santander’s commitments to its operational emissions (Scopes 1 and 2) and leaving its Scope 3 emissions — including its oil and gas financing — outside any specific alignment target.
These changes echo rhetoric and themes used by Carbon Measures:
In the oil & gas sector, we have also evolved our methodology by moving from absolute financed emissions to two intensity-based metrics: (i) an alignment target for operational emission intensity (scope 1+2), and (ii) monitoring of the primary energy mix, which reflects the carbon intensity of our global energy supply portfolio. This approach recognizes the role of producers in reducing operational emissions while acknowledging that fossil fuel consumption is primarily driven by demand-side dynamics – such as electrification of transport, heating and industrial processes, where we already have targets in the relevant sectors for Santander.”
The above paragraph is an excerpt from page 56 of Santander’s 2025 Annual Report. Climate watchdogs caught these changes and traced their influences to Carbon Measures’ doorstep when Santander released its annual report in February 2026.
In meetings with climate finance campaigners Santander has denied that its policy changes have any connection to Carbon Measures and points to its previous and continuing engagement with the GHG Protocol. But in practice, the changes move a significant share of emissions off Santander’s books, making the bank’s climate footprint — and its responsibility for reducing it — look smaller.
The same level of vigilance must now be applied to every single company that has signed onto Carbon Measures and Bank of America must not be exempted from that scrutiny.
Santander is a cautionary tale: the language the bank used in revising its policies now exemplifies the kind of wording that proponents of ambitious climate action should watch for in companies’ public statements and policy updates.
Keeping eyes and ears on alert will be especially important at the proliferating number of climate and clean energy conferences and convenings that dot the calendar.
In June, Carbon Measures staff and advisors turned out in force for London Climate Week. Carbon Measures was one of many sponsors to the Climate Innovation Forum securing name and logo inclusion on promotional materials. Public pressure kept Carbon Measures CEO Amy Brachio off the Forum’s mainstage, though she still recorded and posted interviews from the event. More broadly, Carbon Measures remained active throughout the week, with public and private engagements that allowed the initiative to continue promoting its work and building visibility even while being barred from a headline speaking slot.
Regional climate weeks are perfect hunting grounds for Carbon Measures to spread their ideas, win converts, and sow confusion, especially within the business community. But growing evidence suggests that Carbon Measures has grander aims with plans to sway regulators and insert “product-level carbon intensity standards” and “ledger-based accounting methodologies” into multiple national and regional rule-making processes where it will be harder to unravel. A well-funded and oil-tongued (pun-intended) lobby effort to capture or neuter regulation raises the threat posed by Carbon Measures to a new stratosphere.
New York Climate Week, running from September 20-27th in parallel to the United Nations General Assembly, will be a particularly noisy environment where everyone should have their antennas primed to detect mentions of ‘e-ledgers’ and other Carbon Measures rhetoric.
So to every company, policymaker, regulator, and supervisory body out there: do your due diligence and be clear-eyed that when Carbon Measures knocks at your door the agenda they champion is designed to weaken the emerging global standard, muddy responsibility for emissions, and give major emitters like Exxon-Mobil more room to avoid accountability.
At this year’s Climate Week, don’t fall for oil industry PR dressed up as an emission accounting tool. It’s time to adopt the GHG Protocol and ISO global standard, fix the flaws and close the loopholes corporate interests have already carved into the rules, and get onto the hard part: actually reducing the emissions we can now more rigorously and reliably measure.