GHG Protocol Scope 2 revision: what could change for renewable electricity buyers?
The GHG Protocol is revising its Scope 2 Guidance, which defines how companies account for emissions from purchased electricity, steam, heat and cooling.
On 29 July 2026, it published the results of a major public consultation on the proposed changes. Nearly 1,100 stakeholders from 56 countries responded, including companies, industry groups, consultants, energy suppliers, NGOs and academics.
The consultation shows broad support for improving the credibility of Scope 2 reporting. However, it also reveals serious concerns about whether some of the proposed requirements are practical, proportionate and equally accessible across different markets.
For renewable electricity buyers, the revision could affect which energy attribute certificates can be used, how closely purchases must match consumption and what data companies need to support their claims.
How Scope 2 reporting currently works
Scope 2 covers indirect emissions associated with the energy a company purchases and consumes.
The existing guidance requires two forms of reporting:
- The location-based method reflects the average emissions intensity of the electricity grid where energy is consumed.
- The market-based method reflects contractual electricity purchases and energy attributes, including Guarantees of Origin and other energy attribute certificates.
The GHG Protocol proposes retaining this dual-reporting structure while revising the requirements for both methods.
For the location-based method, companies could be required to use more precise emission factors based on location, time and data quality, where these are accessible.
For the market-based method, the most significant proposals concern hourly matching and deliverability.
What would hourly matching mean?
Most renewable electricity procurement is currently matched on an annual basis. A company calculates its annual electricity consumption and acquires an equivalent volume of qualifying renewable electricity attributes.
Hourly matching would introduce a much closer relationship between when electricity is consumed and when the associated renewable electricity is generated.
Under the consultation proposal, larger organisations using the market-based method would have to match contractual instruments with their electricity consumption on an hourly basis. Companies below a defined threshold could remain eligible for annual matching.
Where actual hourly consumption data is unavailable, the proposal would allow companies to use standardised load profiles to estimate how their consumption is distributed.
The rationale is that annual matching can conceal significant differences between renewable generation and electricity demand. Solar generation during the day, for example, can currently support an annual renewable electricity claim even when much of the buyer’s consumption occurs at night.
Hourly data could provide a more accurate picture and create demand for a broader mix of technologies, including storage, geothermal energy and other sources capable of supplying low-carbon electricity when wind and solar generation are limited.
Among respondents who supported hourly matching, 96% said it would better reflect grid operations and reduce the misallocation of generation. A further 93% believed it would improve the accuracy and scientific integrity of market-based reporting.
However, overall support for making hourly matching a requirement was low. Only 22% of respondents supported the proposal, while 70% expressed low or no support. Among companies, support was just 12%.
The main concerns included limited access to hourly consumption data, inconsistent registry infrastructure, higher procurement costs and more complex verification.
How could deliverability affect certificate sourcing?
Deliverability would introduce a stronger geographical connection between renewable generation and electricity consumption.
Under the proposal, the generation associated with a contractual instrument would need to be plausibly deliverable to the market where the electricity is consumed. The exact implications would depend on how market boundaries are ultimately defined.
This could restrict the geographical areas from which companies are permitted to source qualifying certificates for Scope 2 reporting.
The principle is intended to prevent renewable electricity claims based on generation that is physically or economically disconnected from the buyer’s consumption. It could also make market-based reporting more consistent between companies operating on the same electricity grid.
The consultation nevertheless found limited support for the proposed requirement. Only 19% of responding companies supported it, while 71% expressed low or no support.
Respondents questioned whether the proposed boundaries accurately reflect interconnected electricity markets. They also warned that narrower sourcing areas could reduce certificate availability, increase prices and limit investment in regions where renewable energy development may have the greatest impact.
Among respondents concerned about deliverability, 87% said narrower boundaries could restrict companies’ ability to invest in areas with strong decarbonisation potential. Another 72% were concerned that buyers could move away from long-term power purchase agreements and towards shorter-term certificate purchases.
This illustrates an important challenge: a geographically tighter accounting rule may improve the connection between reported emissions and local electricity consumption, but it does not automatically lead to greater investment in new renewable capacity.
What could change for the location-based method?
The proposed revision also affects location-based reporting.
The GHG Protocol has proposed a hierarchy of emission factors that would prioritise more precise data. Depending on availability, this could mean using emission factors that more closely reflect the location and timing of electricity consumption instead of relying on broad annual grid averages.
Companies would be required to use the most precise accessible emission factor. In the proposal, accessible data is generally defined as data that is free, publicly available and obtained from a credible source.
Stakeholders were divided on whether this would improve comparability. Some supported the greater accuracy. Others noted that companies on the same grid could still use different emission factors because they have access to different consumption data.
The change could therefore increase the data requirements for corporate reporting without immediately producing fully comparable results.
What does this mean for Guarantees of Origin and other certificates?
Energy attribute certificates will remain central to market-based Scope 2 reporting, but buyers may need more information about the underlying generation.
Annual volume and technology may no longer be sufficient. Depending on the final requirements, companies could also need to consider:
- The hour or period in which the electricity was generated
- The location of the generating asset
- Whether the generation is considered deliverable to the point of consumption
- The availability and quality of registry data
- The treatment of residual electricity not matched with eligible instruments
- Whether existing contracts qualify for transitional protection
This does not mean every company should immediately replace its current procurement strategy. The proposals are still being developed and may change following the consultation.
It does mean that buyers should start examining how their portfolios would perform under more granular reporting rules.
Accounting accuracy and environmental impact are different questions
The revision has brought a longstanding issue to the surface: Scope 2 accounting and the environmental impact of procurement are related, but they are not the same.
Scope 2 is an attributional inventory. It allocates emissions to a company according to a defined set of accounting rules.
The impact of a renewable electricity purchase depends on other factors. These may include whether the purchase supports new generation, improves the economics of an existing project, provides revenue certainty or directs capital towards a market where renewable development is particularly valuable.
Hourly matching can create a more precise relationship between reported consumption and renewable generation. Precision alone, however, does not demonstrate that a purchase caused new capacity to be built.
Conversely, a long-term agreement supporting a new renewable energy project may have a meaningful market impact without matching every hour of the buyer’s consumption.
A revised framework should make this distinction clear. Companies need credible rules for reporting their allocated emissions, but they should communicate the wider effects of their procurement separately and with appropriate evidence.
Why transitional protection matters
Around 90% of respondents supported a legacy clause for existing contracts.
This is particularly important for companies that have entered into long-term power purchase agreements or other multi-year procurement arrangements under the current guidance.
Retrospectively changing the accounting treatment of these contracts could undermine confidence in renewable energy investments. It could also place companies in a position where they are contractually committed to a purchase that no longer supports their reporting objectives.
A well-designed legacy clause would protect market confidence while giving buyers time to adapt future procurement decisions to the new requirements.
What should renewable electricity buyers consider now?
The final standard is not yet available, so companies should avoid treating the consultation proposal as an adopted requirement.
Nevertheless, buyers can begin assessing their readiness by considering the following questions:
- Do we have access to hourly electricity consumption data?
- Can our suppliers and registries provide more granular certificate information?
- Where are the generating assets behind our certificates located?
- How would narrower market boundaries affect certificate availability and cost?
- Which existing contracts may require transitional protection?
- How much of our consumption could be matched hourly with the products currently available?
- Are we clearly distinguishing our Scope 2 accounting claims from claims about environmental impact?
Companies operating across several countries should review these questions market by market. Data availability, registry capabilities and renewable electricity supply differ considerably between regions.
Finding a workable balance
Greensteps supports the ambition to improve the credibility of renewable electricity reporting. Greater transparency around the time, location and characteristics of generation can help buyers make better-informed procurement decisions.
However, the revised framework must also recognise differences in market maturity, data availability and company resources.
If the minimum requirements are set beyond what most organisations and markets can reasonably implement, participation could decline. That would risk concentrating advanced renewable procurement among a relatively small number of large buyers.
A proportionate framework could combine a credible minimum standard with phased implementation, appropriate exemptions and additional recognition for companies adopting more advanced procurement strategies.
The strongest Scope 2 framework will not simply be the most technically precise. It will be the one that strengthens trust, supports better procurement decisions and keeps renewable electricity markets accessible to a broad range of buyers.
The final requirements are still under development. Greensteps will continue to monitor the revision and its implications for energy attribute certificates and corporate renewable electricity procurement.
Source: GHG Protocol Scope 2 Public Consultation Summary of Feedback, 29 July 2026.
The proposals discussed in this article are subject to further review and should not be treated as final GHG Protocol requirements.
