Josh Archer, Corporate Accountability Campaigner
2026.06.17
October 2025 was a big month for fossil fuel giant ExxonMobil.
In an audacious lawsuit, the company argued the state of California is violating its First Amendment right to free speech by requiring disclosure of its climate-wrecking emissions. Put a pin in this, because we will be coming back to it.
At the same time, ExxonMobil was also leading the launch of a glossy new coalition called Carbon Measures with a promise to fix how companies measure carbon emissions.
On the surface, these two moves seem at odds. Why would a major company argue against disclosure on the one hand, and claim to want to improve carbon accounting on the other?
Carbon Measures claims to complement existing carbon accounting standards. Dig deeper, and it becomes clear that this initiative challenges the foundational principles of existing standards while pushing a replacement that moves carbon accountability off polluters’ own books.
What is Carbon Measures?
ExxonMobil and 18 other companies launched Carbon Measures pledging to build a new “ledger-based” carbon accounting framework. The new model claims to operate on the principles of financial accounting.
The coalition of companies responsible for the launch and promotion of Carbon Measures raises some significant questions about its real objectives. Among its members are some of the world’s largest polluters and their backers. To name a few:
- Linde, an industrial gas giant that consumes as much electricity as Denmark and Ireland
- Financial institutions, including Bank of America, one of the top fossil fuel financiers in the world, and Europe’s leading funder of oil and gas in the Amazon, Banco Santander
- Some of the world’s largest greenhouse gas emitters, including Abu Dhabi National Oil Company (ADNOC), TotalEnergies, a French oil and gas major found by a French court in October 2025 to have misled consumers over its carbon-neutrality claims—and, of course, ExxonMobil, the world’s largest investor-owned polluter
These are among the companies that stand to lose the most from honest accounting of carbon emissions.
So what does Carbon Measures want? The stated goal of this initiative is “product-level carbon intensity standards, based on verifiable data informed by an enhanced emissions accounting framework.” In its launch materials, members call for harmonized carbon intensity standards to “reward low-carbon solutions and harness the power of markets.”
This sounds like a laudable goal. Does it translate into reality? Keep reading.
What the Carbon Measures Approach Means for Climate Accountability
Despite its fanfare, Carbon Measures has not published a proposed standard or framework for carbon accounting. That said, from what we have seen so far from the initiative, we can identify four major problems for emissions reduction efforts.
Problem 1: Moving accountability downstream
ExxonMobil and its Carbon Measures allies are championing an approach to carbon accounting called E-Liability, developed by Oxford professor Karthik Ramanna and Harvard’s Robert Kaplan. Ramanna now co-chairs the Carbon Measures technical expert panel, which is tasked with establishing “a global carbon emissions accounting system based on financial accounting principles.” That mandate matches E-Liability in everything but name.
The E-Liability approach moves climate accountability downstream, away from the producer and toward the buyer. At the end of the chain, it’s the individual consumer who is ultimately responsible for the carbon impact of a product.
Under this approach, a product’s buyer ultimately takes on the embedded carbon that went into making it as a liability. An oil and gas company that releases 100 units of carbon to extract and transport an amount of oil will have the same ledger as a renewable energy company that also releases 100 units of carbon to install a wind turbine.
The oil company generates much larger downstream emissions from the combustion of its product, which are not counted anywhere within its ledger. The renewable provider’s avoided emissions also go unrecognized. The result is a distorted equivalence between fundamentally different climate impacts.
Problem 2: Withering of Scope 3
The E-Liability approach that Carbon Measures is likely to advocate for would also sideline a critical category in carbon accounting: Scope 3 emissions.
First, a primer. Scope 1 is a company’s own operations. Scope 2 is the energy it buys. Scope 3 is everything else across the value chain, including the emissions from the products a company sells, once customers use them.
The Carbon Measures project is built on Scope 1 and the cradle-to-gate carbon emissions embedded in products. It sets aside the largest component of oil majors’ climate impact: Scope 3 emissions.
For a big oil company like ExxonMobil, Scope 3 is the whole ballgame. The pollution ExxonMobil generates from its gasoline, diesel, and jet fuel dwarfs emissions from its own operations, including crude extraction and refinement.
In its disclosure covering full-year 2024, ExxonMobil estimated its Scope 3 emissions at roughly 630 million metric tonnes of CO₂e. Its Scope 1 and 2 emissions, meanwhile, totaled about 98 million tonnes. That’s a gap of more than six to one.
And ExxonMobil is not the only member with a Scope 3 problem to bury. When Greenpeace France recalculated fellow Carbon Measures member TotalEnergies’ 2019 real carbon footprint, it estimated the company was responsible for roughly 1.6 billion tonnes of CO₂e, or nearly four times what Total reported. That massive gap between real and reported carbon emissions overwhelmingly comes from Scope 3, or the emissions from burning the oil and gas it sells.
By using an E-Liability accounting approach to make Scope 3 disappear, ExxonMobil, Total, ADNOC, and all the other major fossil fuel companies could make the “double counting” they complain of go away.
Problem 3: Legitimizing carbon intensity over absolute carbon emissions
Another arrow in the ExxonMobil and Carbon Measures quiver is aimed straight at the heart of emissions reduction efforts. The objective is to lift up reductions to carbon intensity and brush aside the need for real, absolute carbon emissions cuts.
Carbon intensity measures emissions per unit of product. That means volume of CO2 per tonne of steel, barrel of oil, and so on.
This is the tricky part: a company can hit every one of its intensity targets while still raising its total emissions. Carbon intensity reduction only really matters if the goal is to get intensity to zero, or if production stops growing. Neither of these scenarios is on offer from Carbon Measures.
Problem 4: A rulebook written by the polluters
Another significant problem relates to the question of who controls Carbon Measures, and who gets to determine the rules of the game going forward.
Credible standards depend on independent, multi-stakeholder governance. This is the model we see with leading standard-setters. The Greenhouse Gas Protocol is stewarded by civil society and built through technical working groups of experts, academics, and government and business representatives from more than 20 countries. The International Organization for Standardization, or ISO, works through mechanisms of formal international consensus.
Carbon Measures is different. It is an industry-led coalition, funded and steered by the very companies it would cover. Furthermore, its methodology is still up in the air. Analysts note that it lacks codified rules for what counts, where the boundaries sit, and how the emissions are allocated.
Why polluters benefit from the elimination of Scope 3
Given the massive size of their Scope 3 emissions relative to their operational emissions, we have established a clear reason why companies behind the coalition would prefer to have Scope 3 out of the picture. Erase the Scope 3 category, and most of their climate impact vanishes from the books.
So why would regulators ever allow that to happen? In short, it’s unlikely they would. That is why ExxonMobil appears to be working both ends.
A little history lesson
ExxonMobil has spent decades denying, delaying, and distracting from the magnitude and causes of climate change.
Back in the 1970s, the company’s own scientists understood the challenge and what it meant for the company. ExxonMobil then spent years sowing doubt and denying the problem. When denial stopped working, it changed its message. Today, it brands itself as a “carbon solutions” company. It even calls its annual climate report “Advancing Climate Solutions.” Think about the audacity it takes for a fossil fuel company to position itself as a climate leader.
About that California lawsuit
Whereas Carbon Measures could be ExxonMobil’s subtle approach to undermining international climate standards, its California lawsuit shows that the company is also more than willing to be bold-faced about its intentions where necessary.
At issue in the lawsuit is California’s disclosure law requiring large companies to report Scope 1, 2, and 3 emissions using the GHG Protocol. Beginning in 2027, this will include Scope 3 emissions. To stop this requirement from coming into force, ExxonMobil took the state of California to federal court. In its filing, it called the GHG Protocol “misleading and counterproductive,” and argued that the law is in violation of ExxonMobil’s free speech rights, forcing the company to “serve as a mouthpiece for ideas with which it disagrees.”
There is no contradiction between what ExxonMobil support for Carbon Measures and its objectives in the California lawsuit. They are part of the same strategy to eliminate Scope 3 reporting in an effort to obscure the impact of their fossil-fuel business.
The real solution to Scope 3 challenges
The insidiousness of Carbon Measures is that it identifies real challenges in carbon accounting.
For one thing, Scope 3 data can be rough. For years, many companies have leaned on crude “spend-based” estimates that determine emissions by multiplying money spent in a given category by an average emissions factor for that category. A more accurate estimate would rely on primary data from suppliers, which is the direction in which GHG Protocol revisions are pushing.
The timing of Carbon Measures arriving on the scene also betrays its cynical motives, coming at the exact moment the international community is converging on a single standard—the GHG Protocol. In 2025, more than 22,000 companies disclosed using the GHG Protocol through CDP, and regulators are building on it. For example, the EU’s Corporate Sustainability Reporting Directive now requires tens of thousands of companies to report Scope 1, 2, and 3 emissions using the GHG Protocol. The ISSB global disclosure baseline is also grounded in the GHG Protocol methodology, and over 35 countries have adopted or are on track to adopt those ISSB standards. Meanwhile, GHG Protocol is working with international standard-setter ISO to harmonize their approaches, further solidifying GHG Protocol as the international standard for carbon disclosure.
GHG Protocol is also currently enhancing its approaches, including through its biggest Scope 3 overhaul in over a decade. The process is open, and experts from more than 20 countries are involved in it. The proposals under consideration fix the weaknesses Carbon Measures claims to care about—better data, fewer loopholes. The work is on track to finish by 2027.
Additionally, the GHG Protocol and ISO are co-developing a unified product-level carbon accounting standard, directly undercutting a pillar of the Carbon Measures argument about the need for product-level accounting. More than 450 experts from over 50 countries have been nominated to build it through an open, multi-stakeholder process rather than one steered by the polluters it would cover.
What about so-called double counting in Scope 3? Carbon Measures treats this as a flaw to engineer away. In truth, what is described as double counting is actually creating shared responsibility. When both the steelmaker and the auto manufacturer carry a share of the same emissions, both have a reason to act.
So the real solution to Scope 3 challenges already exist. Carbon Measures should be rejected outright as the distraction that it is, and companies and organizations should focus their efforts on strengthening the standard the world is adopting.
