The rules governing how organisations account for renewable electricity are on the brink of change.
Following the closure of the Greenhouse Gas (GHG) Protocol’s Scope 2 consultation, momentum is building toward more granular – potentially half-hourly or hourly – matching of electricity consumption with renewable generation.
While final guidance is still in development, the direction of travel is unmistakable: greater accuracy, transparency, and credibility in renewable electricity claims, half-hourly or hourly matching of electricity consumption with renewable generation.
For businesses, this is not simply a technical accounting update. It represents a structural shift in how renewable procurement, reporting, and risk management intersect.
Why is the Status Quo being challenged?
For over a decade, most organisations have relied on annual matching of electricity use with energy attribute certificates (such as REGOs, GOs, or RECs) to support “100% renewable” or “zero-carbon electricity” claims.
While this approach has accelerated corporate participation in renewable markets, it has also exposed a growing gap between what is claimed and what happens on the grid.
Electricity is consumed in real time, yet renewable generation is variable. Annual certificates can obscure periods where organisations draw power from fossil fuel-dominated grids –particularly during evenings, winter peaks, or low renewable conditions.
As scrutiny of sustainability claims intensifies, regulators and standard-setters are responding. The Scope 2 consultation highlighted concerns around:
- Temporal mismatches between generation and consumption.
- Limited geographic and technological transparency.
- Double-counting risks.
- Reputational exposure linked to greenwashing.
The proposed solution is simple in principle, but complex in practice: match electricity consumption with renewable generation when it actually occurs.
What this could mean for renewable electricity claims
If future Scope 2 guidance places greater emphasis on granular matching, the implications for corporate reporting could be significant. In practical terms:
- Annual certificate matching alone may no longer support the strongest zero-carbon electricity claims.
- Organisations will need visibility into when their renewable power is generated.
- Periods of residual grid consumption may need to be explicitly recognised.
- Reported Scope 2 emissions could increase – even where total renewable procurement remains unchanged.
Importantly, this is not about discrediting existing action. Rather, it reflects a maturing market where credibility and integrity now matter as much as volume.
Are Power Purchase Agreements the answer?
Power Purchase Agreements (PPAs) are often viewed as the natural evolution from certificate-based procurement – and with good reason.
PPAs provide:
- A direct link to specific renewable assets.
- Stronger traceability and auditability.
- Alignment with additionality and long-term decarbonisation.
However, even PPAs do not deliver round-the-clock renewable supply. Wind does not always blow, and solar does not generate at night. Under a granular accounting framework, no single solution guarantees perfect alignment.
The reality is that future‑proof strategies will likely combine PPAs, certificates, flexible demand, and emerging technologies rather than relying on any one mechanism.
The rise of granular matching platforms
To address these challenges, a new layer of energy technology is emerging. Suppliers and service providers are developing granular matching platforms that allow organisations to:
- Compare half-hourly or hourly consumption against renewable generation.
- Identify mismatches and deficits in near-real time.
- Improve transparency for auditors, investors, and stakeholders.
While approaches vary and standards are still evolving, these tools are becoming a critical enabler of higher integrity Scope 2 reporting.
The strategic risks of standing still
For organisations that delay engagement, the risks extend beyond compliance.
Key exposures include:
- Financial risk: higher costs for granular certificates, balancing mechanisms, or flexibility.
- Contractual risk: long-term “green” supply agreements that no longer align with reporting expectations.
- Reputational risk: sustainability claims that attract challenge or reassessment.
- Target risk: impacts on SBTi trajectories and net zero pathways.
In contrast, early movers will be better positioned to shape procurement strategies rather than react to them.
How leading organisations are responding
Forward-looking organisations are already taking action by:
- Stress-testing renewable strategies against more granular scenarios.
- Embedding change in law and flexibility clauses into energy contracts.
- Diversifying procurement across certificates, PPAs, and technology solutions.
- Improving internal data visibility and governance around Scope 2 claims.
Crucially, they are treating Scope 2 reform not as a reporting problem, but as a strategic energy transition issue.
What happens next?
The GHG Protocol is expected to continue technical development through 2026, with revised Scope 2 guidance anticipated in 2027.
Given the scale of change, phased implementation and transition arrangements are widely expected. This provides a narrow but valuable window for preparation.
If you would like to speak to one of Inspired’s experts on anything regarding the upcoming Scope 2 emissions reporting changes or half-hourly data matching, please reach out to [email protected]
