GHG Protocol Scope 2 revision: what it means for your next PPA

The Greenhouse Gas Protocol (GHG Protocol) is revising how companies account for emissions from purchased electricity. Its Independent Standards Board (ISB) has proposed two market-based methods, with a transition date still to be set. For an energy buyer, the practical task is to understand what your current power purchase agreements (PPAs) deliver and secure the data your next contract may need.

The original consultation proposed hourly matching and deliverability requirements. The September 2026 direction adds incrementality to a proposed Method 1, while Method 2 would keep the existing 2015 requirements until the transition date. These are accounting proposals. They do not set a new corporate procurement target.

“It's hourly accounting, not 100% matching.”
_{– Carolyn Addy, Renewabl, on the Plugged In Podcast}

The first public consultation closed on 31 January 2026 with 1,072 responses. The latest proposal, those responses and the steps you can take now are set out below.

September 2026: what the ISB proposed for the market-based method

In September 2026, the Independent Standards Board (ISB) of the Greenhouse Gas Protocol (GHG Protocol) proposed a direction for the Scope 2 market-based method. The GHG Protocol memo of 16 October 2026 describes two methods:

Before the transition date, companies reporting market-based emissions would disclose which method they apply. After that date, they would use Method 1 if data that meets the quality criteria is available. No transition date has been set. Whether market-based reporting is required at all, and the proposed “shall”, “should” and “may” wording, remain open.

The Technical Working Group (TWG) develops proposals for ISB review and approval. TWG meeting 23 minutes, dated 6 October 2026, record that 10 of 10 ISB members indicated support for the Method 1 direction in a pulse check. The Secretariat said a pulse check “gives direction and is not a decision”. Open questions include the transition pathway, load thresholds and the allocation of older resources under certain contracts.

The ISB also discussed the Actions and Market Instruments (AMI) workstream. Its proposed framework includes a Market-based GHG Inventory Statement, a GHG Impact Statement and a Non-GHG Indicators Statement beyond the physical inventory. Procurement outside future market-based inventory requirements may be reportable through an impact statement or as key indicators. The details remain under development.

The TWG workshop was scheduled for 20–22 October 2026 to develop both methods. No workshop outcomes were available in the official sources checked for this update. Proposed revisions need ISB approval before they enter the consolidated public consultation.

Under the proposal, current procurement strategies could continue through Method 2 until the transition date. Putting consumption, contract and certificate data on one hourly basis is a useful starting point while the details are worked out.

August 2026: what the Scope 2 Phase 1 consultation results show

Who responded

The first Scope 2 public consultation drew 1,072 responses from 56 countries. GHG Protocol published its summary on 29 July 2026 and updated it on 25 August. Companies accounted for 466 responses, or 43.5% of the total. Of all 1,072 respondents, trade associations represented 9.6%, consultants 9.0%, NGOs 8.6%, utilities 8.5% and academia 4.1%. These are the main groups listed here, rather than a complete breakdown.

Corporate views on hourly matching and deliverability

Opposition to the hourly matching proposal was strongest among companies. Of the 909 respondents who answered question 71, 70% opposed it, 22% supported it and 7% were neutral. Among the 429 company respondents to that question, 82% opposed, 12% supported and 7% were neutral. NGOs were split: of 71 respondents, 49% supported, 45% opposed and 6% were neutral. Rounded percentages may total slightly above or below 100%.

Deliverability also drew low support among companies. Concerns extended to the location-based emission factor hierarchy, a separate proposal about which grid factors companies use. On question 23, 28% of 310 company respondents and 20% of 65 industry-group respondents rated it 4 or 5, classed as support. The scale ran from 1 (no support) to 5 (full support). One of the main concerns was regulatory fragmentation: lean teams need to reconcile voluntary guidance with mandatory reporting frameworks. Their workload is set out in “What we hear from corporate energy and sustainability leads”.

Data readiness and feasibility

Respondents pointed to practical data gaps. An hourly accounting method needs consumption data and suitable generation or emission-factor data at the right time and place. Where those inputs are missing, companies need a clear basis for estimates and a way to explain their limits to an auditor.

GHG Protocol's executive summary described views on the proposed feasibility measures as mixed. The September direction leaves data availability as an explicit condition for using Method 1 after the transition date. The TWG still needs to work through the detail.

Support for protecting existing contracts

Respondents broadly supported protecting existing contractual commitments through a legacy clause. That feedback does not establish how signed PPAs would be treated. The ISB's September direction does not mention a legacy clause, and the October minutes list the allocation of older resources under certain contracts as an open question. Buyers should check contract and certificate terms while that work continues.

Exemption thresholds

The consultation asked respondents to choose between illustrative thresholds of 5, 10 and 50 GWh of annual consumption. These were options in a question, rather than an adopted exemption. The October minutes show that a load threshold above which hourly matching would be required remains under discussion. Buyers cannot yet assume that their company or sites would qualify for an exemption.

What the results leave open

GHG Protocol treats consultations as input exercises rather than polls. The TWG and ISB assess proposed updates against integrity, environmental impact and feasibility. The September proposal is the latest direction; its review and consultation stages appear in the timeline above.

The Science Based Targets initiative (SBTi) published its Corporate Net-Zero Standard V2.0 in June 2026. It requires Category A companies with significant electricity consumption to report hourly matching performance. Market instruments remain subject to annual matching for target progress, while higher hourly performance can receive voluntary recognition. These target-setting rules are separate from GHG Protocol's proposed accounting methods.

Advocacy body EnergyTag published its own analysis of submissions. It reported that 53.5% of responses were anonymous, with support for hourly matching at 14% among anonymous submissions and 32% among named submissions. It also reported that supporters more often cited peer-reviewed research. These are EnergyTag's findings; they do not change GHG Protocol's process for assessing consultation input.

What this means for your PPA strategy

No date has been set for the move to Method 1. In the proposed framework, Method 2 remains available until that date. Hourly data also has a commercial use: it shows how closely generation follows your demand and where a PPA leaves price exposure.

“While hourly matching is by no means a mandatory target in the near term, corporate buyers are already leveraging it as a commercial tool. Hourly alignment is a direct proxy for hedge effectiveness – in our modelling, a well-matched hourly PPA eliminated 91% of long-term price risk, compared to roughly 40% for traditional strategies. That financial value holds regardless of where regulatory guidance lands.”
_{– JP Cerda, CEO, Renewabl}

The staged tender section below brings the practical steps together.

What we hear from corporate energy and sustainability leads

We have analysed our conversations with more than 100 corporate energy buyers over the past year. The most common worry is the complexity the revision will add to a function that is already stretched.

“We are extremely worried because of the complexity, the complexity that is going to add to our daily life.”
_{– Sustainability and energy lead, global agri-business}

Most energy and sustainability teams are lean for the size of portfolio they cover. A team of one or two people running hundreds of sites is not unusual.

The proposals explained: what they ask and what they do not

The Scope 2 Quality Criteria set the rules a contractual instrument must meet for its claim to count under the market-based method. They address the emissions attribute, exclusive ownership and tracking, timing and market boundaries, with further requirements for some supply arrangements. The proposed revision focuses on tighter time matching and deliverability. The October memo also describes incrementality within Method 1.

Hourly matching

Hourly matching compares consumption with eligible generation in the same hour. Annual matching can balance a year's total while leaving gaps at night or in winter. The consultation draft did not set 100% hourly matching as the compliance threshold. The October memo does not say how partial coverage would be reported under Method 1. A buyer should keep an hourly carbon-free energy (CFE) estimate separate from any future inventory reporting calculation.

Deliverability

Deliverability connects the generation claimed to the electrical region where consumption takes place. The consultation explored boundaries such as bidding zones or balancing areas and evidence that power could reach the load. The TWG still needs to work out the detailed rules. A certificate's country of origin alone should therefore be kept separate from a claim that it would meet a future deliverability test.

Incrementality

Incrementality means generation from plants built within a set number of years. The October memo describes it as part of Method 1, alongside hourly matching and deliverability. It was absent from the original consultation's two core market-based requirements. The number of years and the allocation of older resources under certain contracts remain open. Incrementality concerns plant age; additionality and avoided-emissions measures ask different questions about a purchase's effect.

What the draft includes to ease feasibility

The consultation draft included load profiles to approximate missing hourly data, exemption thresholds for smaller consumers, a legacy clause for existing commitments and phased implementation. The September direction does not establish that each allowance carries over into Method 1. The TWG must develop the detail before ISB review.

Sam Kimmins, Director of Energy at Climate Group, set out the position in September 2025: RE100 and the 24/7 CFE Coalition treat the revision as an accounting correction rather than an immediate move to the procurement target.

Why granular matching is proposed

Supporters argue that hours with scarce clean supply can carry high grid emissions. An annual claim cannot show whether a buyer purchased clean electricity for those hours. Stakeholders who favour annual matching say it keeps barriers to market participation low and supports a large, active certificate market.

For buyers, the practical value of each approach depends on the market. In mature grids, time and location help identify gaps in clean supply. In grids where fossil generation still dominates, such as Poland, emissions-driven procurement can help assess where purchases may reduce emissions. The October memo's proposed incrementality requirement and AMI framework should each be assessed on their own terms.

Background: how current Scope 2 rules handle PPAs

Where Scope 2 emissions sit in the Greenhouse Gas Protocol

The Greenhouse Gas Protocol groups corporate greenhouse gas emissions into three scopes. Scope 1 covers direct emissions from sources a company owns or controls, such as boilers and vehicles. Scope 3 covers other indirect emissions across the value chain, from raw materials to product end-of-life.

Scope 2 covers indirect emissions from purchased electricity, steam, heat and cooling. For purchased electricity, the emissions occur at the generating plant. Electricity procurement can therefore affect the contractual basis of a company's Scope 2 account, alongside efforts to reduce demand or generate power on site.

Two methods, used in parallel

Under the 2015 Scope 2 Guidance, companies report location-based and market-based results if they operate in any market where product- or supplier-specific data is available. The location-based method applies grid-average emission factors. The market-based method uses eligible contractual instruments, including PPAs, green tariffs and energy attribute certificates (EACs).

The consultation draft retained dual reporting and proposed changes to both methods. The market-based proposal tightened contractual requirements. The location-based proposal set a more detailed emission-factor hierarchy, with spatial boundary before time granularity and factor type. The September ISB direction concerns the market-based method.

These location-based and market-based calculations are different from the two proposed market-based methods, Method 1 and Method 2. Buyers may need both views of the same consumption, while the proposed Method 1/Method 2 choice concerns the market-based account.

The annual matching gap is wider than just unbundled certificates

Annual matching can leave an hourly gap across several procurement types. A company with a solar PPA for 100,000 MWh can cover its annual consumption volume while covering well under half of its consumption hour by hour. The annual amount does not show when the solar plant generated.

A green tariff can have the same gap when a supplier pairs grid electricity with an annual volume of Guarantees of Origin (GOs) or Renewable Energy Certificates (RECs). Changing the procurement instrument alone does not resolve the timing gap. Hourly measurement shows it; procurement design can then address it where the data and market allow.

The hourly renewable energy matching guide explains how the hourly measurement works.

What to do now: a staged path for your next PPA tender

The September proposal sets no new procurement target and no date for moving to Method 1. Data preparation and tender design are useful while those details remain open. Waiting for the final standard before updating tender criteria can mean signing a 10- or 15-year contract without the data you will later need. Start with the information your team can collect and use it to improve the next buying decision.

Beginner: get your data in one place

Start by bringing consumption, contracts and certificates together. Many buyers manage procurement, certificate records, price benchmarking and carbon accounting in separate tools, with spreadsheets between them. Sustainability and procurement teams may use different versions of the same information. Supplier portals, invoice PDFs and inboxes each hold part of the record.

“You can't act on what you can't see.”
_{– Carolyn Addy, Renewabl}

Reconcile what you consume with what your contracts and certificates cover. Keep the source and time resolution of each data set visible. If some sites have hourly meter data and others have annual invoices, record that difference rather than treating the whole portfolio as equally precise.

In our work with a global manufacturing company, annual renewable coverage of 100% translated to roughly 36% on a proxy-data hourly view in its EU headquarters country. The share that could be evidenced with granular certificates was lower still because hourly data was missing. The reporting was correct under the existing method. The hourly view revealed a different question about when supply covered demand.

Renewabl's free Hourly Carbon-Free Energy score estimator offers a starting point without uploading data. It uses three real 2024 load shapes – retail/office, manufacturing and data centre – with proxy solar and wind profiles across the year's 8,760 hours. The result is directional; a reportable position requires actual records and the relevant accounting method.

Reconcile existing GOs, RECs and other EACs against consumption monthly or hourly in Renewabl Track. That work can expose missing certificates and help size the next tender. Keep consumption gaps separate from evidence gaps: a generation profile may fit your load even where certificate data cannot yet prove the match.

“First things first: get visibility of your data.”
_{– Carolyn Addy, Renewabl}

Intermediate: move from annual to monthly and ask for hourly data

For many buyers, the next procurement step is annual to monthly alignment. Monthly matching is achievable with certificate infrastructure already in place, while hourly accounting can sit underneath as the measurement architecture. This is a procurement path. The proposed Method 2 to Method 1 transition is a separate standard-setting process, and the ISB direction does not recognise monthly matching as a Method 1 route.

Ask bidders for hourly generation data and support for granular certificate tracking. Make time-stamped meter logs a contractual deliverable, so your team can assess the offered generation against its actual demand.

Technology mix matters. Eurelectric and Pexapark's 2023 research compared hourly matching outcomes for solar, wind and combined portfolios in Germany and Finland:

A combined solar and wind starting position can reach the 60 to 75% hourly coverage range before costs rise sharply, though results depend on market and load. A European independent power producer we worked with moved from below 40% to over 70% hourly CFE in one country with no meaningful budget change. It consolidated the data first and then reshaped procurement against the load profile.

The IEA's 2022 Advancing Decarbonisation through Clean Electricity Procurement found that 90 to 95% 24/7 CFE targets can carry a small premium over 100% annual matching in the cases it studied. Premiums vary by market and load shape. The last 5 to 10% can cost much more, so compare portfolio options at several coverage levels before setting a target.

Advanced: design for hourly shape and hedging value

Shape risk is the gap between when a PPA generates and when you consume. A 100 MW solar PPA may match annual volume while leaving exposure on winter evenings. Size the tender against demand by hour and compare the uncovered periods, alongside capture price and annual volume.

A 2023 Eurelectric and Pexapark analysis found that a Finnish buyer with a 10 MW baseload PPA could have avoided roughly €14 million in 2022 settlement exposure by moving from a 100% annual-matched structure to a 90% hourly-matched one. The result is specific to that case and period. It shows why annual coverage alone can miss commercial exposure.

“Hourly matching effectiveness is a great proxy for hedging effectiveness.”
_{– Carolyn Addy, Renewabl}

The same hourly view serves sustainability and procurement. Renewabl's modelling, described in the August section, compares the price-risk reduction from different PPA strategies using market data from Pexapark. A close match can improve the hedge, though the outcome still depends on contract terms and the market.

“Hourly procurement provides clearer price signals and more stable revenue across different time periods. It aligns cost with real-world system conditions, rewarding renewable generation when it is most valuable and accelerating investment where it's needed most.”
_{– JP Cerda, Renewabl}

Energy sovereignty also affects procurement decisions. Buyers in Europe and beyond assess exposure to imported energy alongside cost and supply resilience. Local generation and storage can help address those concerns where the system supports them.

“You cannot rely solely on traditional and external sources of power, such as imported gas. You must build a more resilient, localised system.”
_{– JP Cerda for S&P Global, April 2026}

BloombergNEF's 1H 2026 Corporate Energy Market Outlook puts corporate clean-power procurement in 2025 at 55.9 GW, down about 10% year on year. Four buyers accounted for roughly half of activity, and hybrid energy-plus-storage deals reached 5.8 GW. Some softening reflects buyers waiting for the rules to settle, in JP Cerda's assessment to pv magazine in June 2026: “Corporates are kind of waiting on the final decision on the protocol to see what kind of rules are going to be imposed on them.”

Ask for hybrid bids where they fit the load: combined technologies or renewables with storage may cover different hours. Compare costs and price exposure across those options. Hourly matching does not guarantee a good hedge; it helps reveal which hours a contract covers and what remains to be bought.

Write provisions into the contract for how certificates will be issued, tracked and transferred if reporting rules change, so you can evidence what it delivers under whichever method applies. Legacy treatment for signed contracts remains open. No contract clause can guarantee that a purchase will qualify under a standard whose final requirements have yet to be set.

Scale this work across markets and business units at the time resolution each market supports. Combine time matching with location matching and assess generation technologies against each portfolio's needs.

The standard's slated Q4 2028 publication leaves time for data preparation and tender design. Publication is a checkpoint in the standards process; the Method 1 transition date still needs to be set.

Renewabl is one platform to track, trade and report renewables in one place, with hourly matching built into the architecture. It brings together work often spread across separate tools, supported by Renewabl Trade and Digital Advisory. We help corporates do the data work and shape the procurement that follows.