The guidance states the baseline data must be within 2 years of the submission date. If an FI is looking to submit their target in 2022, their options for their baseline operational emissions (scope 1 & 2) are 2020 or 2021. Due to the pandemic, scope 1 and 2 emissions from these years are not likely to be representative, and emissions may be considerably lower. Is it possible for FIs to use 2019 baseline instead, or inflate 2020 or 2021 emissions based on what they would have been if not for the impact of the pandemic. Otherwise, the operational targets will require a much lower level of emissions to be achieved, which will be a lot more challenging for companies to achieve, if their emissions already dropped significantly during the pandemic and will increase again in 2022 in comparison.
Finally, does the same baseline year for financed emissions need to be used as the year for the operational emissions?