GHG Protocol Scope 2: The Future of Clean Energy Claims

The Greenhouse Gas (GHG) Protocol has launched its long-awaited public consultation on revisions to Scope 2 guidance, the global standard for reporting emissions from purchased electricity. The proposed ambitious changes aim to align corporate carbon inventory reporting with how clean power is generated and consumed in real time. This would enable more accurate abatement planning, strengthen emissions reduction targets, and improve transparency of how entities source and account for low-carbon power.

For energy suppliers, investors and corporate buyers alike, the consultation represents a defining moment. The new framework moves the market closer to a future where claims of “100% renewable electricity” are backed by hourly, traceable and deliverable data aligned with stringent geographical boundaries, it’s a major leap in Scope 2 accountability, but also a challenge for many entities and jurisdictions. If adopted it would redefine the role of contractual instruments (renewable energy certificates and power purchase agreements (PPAs) alike), and how clean energy is tracked, contracted and claimed.

What’s changing and why it matters

While organisations will continue to report using both location-based and market-based methods, the bar for data precision and credibility is rising sharply

Under the new proposals:

• Location-based method must reflect actual grid conditions - accounting for locally generated, stored, imported and exported electricity - reflected in both consumption- and production-based emission factors matched to specific geographical boundaries and most granular time of electricity use
• Market-based method must ensure that contractual instruments used to facilitate reductions in reported Scope 2 emissions, such as REGOs, GOs and I-RECs, are matched to energy consumption on an hourly basis and linked to electricity that is physically deliverable to the reporting load at the first point of grid connection. The latter is significantly shifting the pool of eligible instruments. And, although designed for large electricity consumers (>50 GWh/year), the new criteria for hourly matching could also apply to medium-sized consumers that fall into 5–10 GWh/year range of electricity consumption, who otherwise would be subject to monthly or annual matching. The exemptions for the latter as well as SMEs are part of the consultation process.

The subsidised electricity, that denotes most of government mandated or supported renewable programmes as well as government owned public utilities that consumers contribute to through electricity bills will fall under a new Standard Supply Service (SSS). To prevent double counting such clean electricity can be claimed only by consumers that it is supplied to on a pro-rata basis relative to the share of SSS in a supplier’s portfolio. To be eligible for claims under SSS electricity certificates must be hourly matched, issued and retired.

For any consumption not matched with SSS or voluntary contractual instruments companies must use residual mix emission factor. Residual mix must exclude all claimed and SSS allocated contractual instruments. Under new proposals if no residual mix emission factor is available, companies must default to either a fossil-only grid-average or fossil emission factor, such as gas, oil, or coal.

Altogether, these updates will drive a shift away from the current practice of matching procurement with generic unbundled cross-border certificates toward granular matching and verifiable sourcing from local grids, exclusive claims over guarantees of origin at the hourly level, and focus shifting towards physical PPAs.

A more transparent energy future

Across the sector, we’re seeing growing momentum toward granular data and verifiable disclosure. For example, initiatives like Matched’s Clean Power Index, which recently featured SmartestEnergy, are encouraging half-hourly transparency in renewable supply portfolios. While such indices offer valuable insights into supplier-level performance, they do not yet establish customer-specific traceability or rely on evidence of exclusive claims over guarantees of origin.

This distinction matters because the proposed Scope 2 standard, and related frameworks such as RE100, increasingly require exclusive, auditable proof of renewable energy use. True credibility depends on matching clean generation to consumption with temporal and geographic precision.

At SmartestEnergy, we continue to support developments that strengthen transparency and integrity across the market, while ensuring our customers have access to robust, verifiable data on their renewable sourcing. Our Traceable Renewable Supply product already provides half-hourly alignment between renewable generation and customer consumption, giving businesses a clear line of sight into the provenance and timing of their electricity use, an approach well aligned with the principles set out in the proposed Scope 2 update.