What the GHG Protocol Scope 2 review means for corporate renewable energy strategy

Corporate electricity accounting has entered a period of change. The Greenhouse Gas Protocol (GHG Protocol) has recently completed a public consultation on proposed updates to Scope 2 Guidance, marking the first major review of electricity accounting rules since the market-based method was introduced. Since a group of our climate experts across the business provided feedback to the consultation, we’ve seen clear signs of how this could impact businesses.  

We’re still waiting for finalized standards, however, our early analysis points to a clear direction. Future scope 2 reporting is likely to place stricter requirements on how renewable energy is matched to electricity consumption, with greater emphasis on timing, location and the unique use of renewable instruments.

This has important implications for how companies think about renewable energy procurement and long-term decarbonization strategies.

What has been proposed

Under current Scope 2 Guidance, companies report both location-based emissions, using grid-average emission factors, and market-based emissions, using contractual instruments such as Renewable Energy Certificates and other Energy Attribute Certificates.

The consultation proposes tightening both approaches. Key elements discussed include:

• Hourly matching: Renewable energy instruments would need to align with electricity consumption on an hourly basis rather than through annual volume matching.
• Deliverability: Market-based instruments would need to be physically deliverable to the location where electricity is consumed.
• Unique claims: Renewable energy instruments could only be used for a single claim, reducing the risk of double counting across reporting frameworks.

These proposals aim to improve the consistency and integrity of scope 2 inventories by aligning reported emissions more closely with electricity systems.

Why this matters for renewable energy strategies

Today, many organizations reduce reported market-based scope 2 emissions by matching annual electricity consumption with verified instruments such as Renewable Energy Certificates in North America or Guarantees of Origin in Europe. This approach remains valid under current guidance and has supported widespread corporate investment in renewable energy.

The proposed changes highlight a potential shift away from annual matching toward more granular alignment. Hourly matching could increase the importance of understanding consumption patterns, while deliverability requirements may affect which instruments qualify in certain locations.

For companies with science-based targets or multi-year decarbonization plans, this underscores the importance of transparency and flexibility in renewable energy strategies.

What remains valid today

Current Scope 2 Guidance remains in force until the GHG Protocol publishes final updates. Verified market-based instruments such as RECs, Guarantees of Origin and International Renewable Energy Certificates remain compliant for scope 2 reporting.

Energy Attribute Certificates represent the renewable attributes of one megawatt-hour of clean electricity added to the grid. When purchased and retired, they allow companies to claim those attributes in market-based scope 2 calculations under existing standards.

Companies can continue to rely on these instruments for reporting while monitoring how guidance evolves.

What to consider next

While final Scope 2 Guidance is still pending, there are a few practical steps companies can take now:

• Review how electricity emissions are currently calculated and which instruments are used for market-based reporting
• Maintain flexibility in renewable procurement approaches to adapt as guidance evolves
• Focus on transparent, well-documented actions that remain defensible under current standards

Normative will continue to track updates from the GHG Protocol and support customers as reporting expectations develop.