The Paris Climate Accord of 2015 (COP21) set the renewable energy transition on its present course, with 196 countries committing to ambitious targets for 2030. Since then, the EU has led the charge, launching regulatory frameworks to push both producers and off‑takers toward cleaner energy. To measure progress against these targets, production and consumption of renewable energy must be accurately tracked — with hourly matching emerging as a key accounting method.

Brussels’ approach has created three major regulatory regimes, expanded adoption of global greenhouse gas reporting standards, and triggered a wave of voluntary sustainability disclosures. Renewable energy certificates are now the backbone of compliance, whether through unbundled certificates (Guarantees of Origin or GOs), Power Purchase Agreements (PPAs), or green supply tariffs.

As these frameworks evolve, GOs and related instruments are set to play an increasingly critical role. This article explains the key EU regulatory changes expected through 2025–2027, why they matter for renewable energy reporting, and how procurement strategies like hourly matching will be affected.

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TL;DR

  • Since COP21, EU regulators have been guiding the renewables transition with new rules, standards, definitions and reporting requirements
  • 2024 represents a point of regulatory convergence, with key EU sustainability regimes adopted by Brussels moving from enactment to implementation. Renewable energy certificates — called Guarantees of Origin (GOs) in the EU — are in the spotlight.
  • We look at the major frameworks, changes coming down the legislative pipeline, and consider how the procurement use cases for renewable energy certificates (GOs and related instruments like PPAs and green tariffs) could be impacted

Greenhouse Gas Protocol

What it's about:

Established in 1990, the Greenhouse Gas Protocol (GHCP) provides standard criteria for the measurement of greenhouse gas emissions and a common framework for greenhouse gas accounting. It established the ‘scope’ emissions categories (Scope 1, Scope 2, and Scope 3) used in EU and other regulatory definitions and sustainability reporting requirements.

Scope 1 refers to direct emissions from self generation. Scope 2 refers to the emissions a company contributes to indirectly through energy purchases from a utility company. Scope 3 emissions refer to indirect emissions from the vendors and partners in a company's supply chain.

The GHG Protocol is undergoing a major update to its corporate standards — including the 2015 Scope 2 Guidance — with new rules expected by the end of 2027. The update will reshape how companies report their electricity‑related emissions by introducing spatial and temporal (hourly) matching requirements and adding a new complementary metric, Marginal Emissions Impact (MEI).

Why it matters:

Since late 2023, Europe’s RECS Energy Certificate Association has advocated for enhanced market‑based reporting, emphasising that off‑takers can actively choose to buy renewables and report their real contribution to emissions reductions. This strengthens the case for granular GOs as a precise instrument for backing up market‑based reporting.

In June 2025, the Scope 2 Technical Working Group published a major progress update that aligns with this trend. For the first time, companies may need to report emissions based on when and where electricity is consumed — not just what was purchased annually. Claims will only be valid if clean energy was generated in the same hour and within the same grid region as consumption, an approach supported by most TWG members and the Independent Standards Board.

While firms using under roughly 5 GWh per market may keep matching at monthly or annual resolution, the trend is clear: future standards will reward energy procurement that is time‑ and location‑specific.

The proposed complimentary metric, Marginal Emissions Impact (MEI) provides a way to credit clean energy that displaces fossil generation when strict hourly matching isn’t possible. Together, the updates create a more credible, science‑based framework – driving stronger demand for contracts and certificates that meet stringent criteria.

Key takeaways:

  • Updated rules will require companies to match renewable energy procurement with consumption by time (hourly) and location (regional).
  • Clean energy not used in the same time or region won’t qualify for Scope 2 totals — but it may still count toward impact via Marginal Emissions Impact (MEI) if it displaces fossil generation.
  • Buyers under 5 GWh per market may be exempt, with limited use of profile‑based estimates.
  • The aim is to improve accuracy and comparability of emissions reporting while creating stronger demand signals for clean energy.

Renewabl's platforms help buyers get aligned with the GHG Protocol updates by effortlessly tracking hourly matched data and procuring qualified renewable energy. Read more about Renewabl's methodology for producing 24/7 CFE and emissionality reports.

The Renewable Energy Directive (RED III)

What it's about:

The EU’s Renewable Energy Directive (RED) establishes renewable energy consumption targets that must be achieved by the bloc as a whole. RED III, the latest iteration, is the regulatory regime with the widest impact on the renewable energy attribute certificate market.

RED III and its associated European standard CEN-EN 16325 prescribe the format, content, time scale and validity of GOs, legitimising them further as a key instrument behind Europe’s renewable energy transition. They also put the EU on course for direct intervention in the GO market if future ‘imbalances’ are detected.

The first version of RED was enacted in 2009, setting a 20% target for the EU's gross final energy consumption to come from renewable energy sources by 2020. A revised directive (RED II) was enacted in 2018, upping the target to 32% of final energy consumption by 2030. RED III sets an overall renewable energy target for the EU of 42.5% by 2030.

key numbers in the revised renewable energy directive
Source: European Commission

Why it matters:

RED III includes measures designed to encourage the shift from annual to hourly-matched certificates. It clarifies the unit size GOs can be split into, setting a standard proportion of 1 MWh which can be issued in smaller fractions.

Any fraction of the 1 MWh standard be a multiple of 1 Wh, a provision that could speed up the shift to certificates that have hourly, or even half-hourly timestamps. Adoption of these granular GOs will make it easier to correlate the purchase of clean energy to the actual time the energy was used by the business.

RED III also places time restrictions on GOs, limiting sale or purchase to within 12 months of ‘the production of an energy unit.’ Buyers will have 18 months to cancel (i.e. redeem) their certificates, after which they expire.

To facilitate these changes, Europe's Association of Issuing Bodies (AIB) is updating its European Energy Certificate System (EECS) framework to make it easier for national GO issuing bodies to create, transfer and redeem hourly certificates.

RED III also states the EU will monitor the GO market with the aim of ensuring its stability. The European Commission will make an assessment by June 2025, looking specifically at factors affecting the balance between supply and demand. How the Commission will conduct its analysis — or the actions it might take afterwards — have not been specified.

For hydrogen producers, RED III adds a ‘temporal correlation’ requirement. By January 2030, renewable hydrogen producers will need to match the electricity that they have purchased on an hourly basis in order for the hydrogen they produce to be considered green.

Under the current legislative schedule, EU member states are expected to enact RED III’s laws, regulations, and administrative provisions by May of 2025.  

Key takeaways:

  • RED III adds to the momentum for regulator-mandated hourly matching
  • The most recent update clarifies the quantities of power GOs can be split into
  • The AIB is updating its issuing framework to facilitate hourly GOs
  • Hydrogen producers must move to hourly matched GOs by 2030
'European and global policy frameworks are starting to reflect that increased accuracy is the only way forward. To be truly net zero in electricity, it's obvious we must match our demand with clean production every hour everywhere to ensure we are not fossil reliant.'
– Killian Daly, EnergyTag

Green Claims Directive

What it's about:

Brussels’ proposed Directive on Green Claims is designed to stop companies from misleading consumers with false or exaggerated statements about their environmental record. Sometimes called the ‘greenwashing’ directive, EU policymakers want to establish a clear set of rules to ensure that companies verify and communicate any claims they make around sustainability.

Standards will be enacted and enforced to make sustainability claims legitimate, verifiable, and comparable across the EU. While the directive is still moving the EU's process of consultations and proposed amendments, its core provisions were approved in March 2024 and the directive is expected to be enacted into law by 2028 at the latest.

The driving principle of the directive is that any green claims made to be precise, scientifically verifiable and relevant to the company or product as a whole. The directive will also levy penalties for misleading claims.

Why it matters:

Under the directive, companies reporting levels of renewable energy consumption — for example, advertising that they are powered by 100% carbon free energy — will need to provide detailed and specific evidence to back up the claim. This applies across all instruments: GOs, PPAs, and green tariffs. Auditors will review marketing and investor communications, financial reporting, and any sustainability reporting mandated by regulation.

While the final wording is still taking shape, regulators are seeking greater levels of proof for renewable energy and sustainability claims. Although annual and monthly matched GOs are still permitted as backup documentation under the current wording, it's safe to assume that the requirements for disclosures will expand. Regulators will continue to examine exactly where energy is sourced from, how much is used, and the mechanism used to match real consumption with renewable energy purchases.

Companies will need to ensure that they are reporting accurately. For whatever portion of renewable energy a company procures via GOs, hourly-matched certificates could become a standard audit requirement for green claims in the future.

Key takeaways:

  • EU regulators want to eliminate bogus claims about the sustainability of products or business practices
  • For renewable energy claims, the direction of travel is to expect greater levels of detail as backup
  • Expect regulators to mandate hourly matching when GOs are part of the clean energy procurement mix
‘The greenwashing directive promotes the environmental footprint method for making environmental claims, making GOs an integral tool of this life-cycle assessment methodology.’  – Mary Polovtseva, Renewable Policy Analyst at Veyt

Corporate Sustainability Reporting Directive

What it's about:

The Corporate Sustainability Reporting Directive (CSRD) is a set of recently-adopted EU regulations requiring all large companies to publish regular reports about their sustainability and other ESG (environmental, social and governance) activities.

The CSRD replaces the previous Non-Financial Reporting Directive (NFRD) and defines a common reporting framework for non-financial data. The aim is to help investors, consumers, and regulators evaluate the non-financial performance of companies and encourage firms to work towards more sustainable operations.

The CSRD nearly quadruples the number of companies required to report on sustainability, from 11,000 under the NFRD to almost 50,000 under the CSRD. The first deadline for CSRD-compliant reporting lands on 1st January, 2025 for the 2024 financial year.

Why it matters:

Under the revised CSRD rules, any company exceeding 1000 employees and either €50 million in turnover or €25 million in assets must report sustainability data — replacing the previous 250‑employee threshold.

CSRD also raises the bar for reporting clean energy consumption by establishing additional criteria for claiming the use of renewables to reduce emissions. The directive makes it explicit that contractual instruments – including GOs – are now mandatory for backing up any such claims.

Being located in a region with a high degree of renewable generation, for example, will no longer be enough to prove an organisation has been using clean power. The directive mandates that energy purchases will only be considered ‘renewable’ if the origin of the energy is clearly defined by a contractual arrangement.

Key takeaways:

  • By changing the company size requirement to cover smaller firms, the CSRD dramatically expands the number of organisations that must report their sustainable activities annually
  • For claims about the use of renewable energy as a way to reduce emissions, companies must provide contracts that identify the source of the energy purchased
  • When GOs are part of the procurement mix, hourly matched GOs will provide detailed and specific evidence that clean energy purchases and true consumption are in balance
'Granular certificates offer a more flexible — and potentially cheaper — alternative to decarbonise the last MWh of power.'
– Bruno Brunetti, S&P Global

Voluntary and upcoming frameworks

Climate Group’s 24/7 Carbon‑Free Energy Coalition

What it’s about:

Launched in 2024 by Climate Group alongside RE100, the 24/7 Carbon‑Free Energy (CFE) Coalition promotes granular renewable procurement as a way to accelerate grid decarbonisation. Its technical criteria outline what qualifies as truly carbon‑free electricity, including hourly‑matched renewables and storage charged exclusively with clean energy.

Why it matters:

While voluntary, the initiative is rapidly becoming a reference point for corporate buyers and auditors, especially as regulatory frameworks (like the GHG Protocol Scope 2 update and RED III) move in the same direction. Companies aligned with the Coalition’s criteria gain reputational advantages, stronger investor confidence, and early compliance readiness. It reinforces the idea that to be credible, renewable energy claims must reflect when and where consumption takes place.

Renewabl's platforms are fully aligned with the 24/7 Carbon-Free Coalition, as well as the GHG Protocol updates and other frameworks explained in this article. Read more about Renewabl's methodology for producing 24/7 CFE and emissionality reports.

Key takeaways:

  • Defines eligibility for 24/7 CFE, including renewables and qualifying storage.
  • Provides a voluntary but influential benchmark for corporates preparing for stricter rules.
  • Complements regulatory shifts toward hourly and regional matching.
  • Helps businesses reduce greenwashing risks by aligning claims with verifiable impact.

Read the joint article by Climate Group's Sam Kimmins and Renewab's CEO and Co-Founder JP Cerda.

Joint article in edie by Sam Kimmins and Juan Pablo Cerda

RED IV

What it's about:

As RED III moves toward final implementation, renewable energy stakeholders are already looking ahead to the next iteration of the directive, known colloquially as RED IV. With the 2024 European Parliamentary elections now complete, the EU is expected to publish its first proposal for RED IV in the first half of the current European political cycle, e.g. by mid-2027.

While the final timescale and focus of the updated directive will take shape in the coming months and years, RECS is already proposing a series of measures designed to strengthen the GO system.

Why it matters:

RECS’ proposals for RED IV include a requirement for all corporate energy consumers to report the origin of all the energy they purchase. In practice this would mean that every organisation would need to gather information about all the types of energy they have paid for, renewable or otherwise.

Another recommendation is to reward companies that purchase renewable energy through reductions in VAT and/or other energy-related taxes. If enacted, it can be assumed that the EU and/or member states would set criteria for proving the nature and quantity of clean energy energy purchases, strengthening the case for hourly GOs.

RECS would also like to see a move to shorter disclosure periods; reducing the validity period of GOs, for example, from 1 year to 1 month. This would mean that organisations would need to buy GOs from production in July 2024 to cover consumption in July 2024. This change could align the GO market more closely with seasonal variations in clean energy generation, and push producers to generate enough clean energy on a monthly basis to address that month’s demand.

Key takeaways:

  • RED IV is only on at concept stage but already proposals are being made to build on the measures established in RED III
  • Making a stronger link between the time of energy generation and its consumption, and rewarding / incentivising companies for making renewable energy purchases are included in industry recommendations

Demand for hourly matching will re-shape the market for GOs

The cumulative impact of these changes can be expected to intensify demand for GOs and strengthen their place in the renewable energy mix.

Killian Daly, Executive Director of EnergyTag, told Renewabl that energy markets are seeing the emergence of a new and much more accurate definition of what it means to be clean powered.

"EU and indeed global policy frameworks are starting to reflect that increased accuracy is the only way forward. To be truly net zero in electricity, it's obvious we must match our demand with clean production every hour everywhere to ensure we are not fossil reliant.”
– Killian Daly, EnergyTag

Mary Polovtseva, Renewable Policy Analyst at Veyt, believes the EU’s Green Claims Directive will have a direct impact on demand for GOs:

“The ‘greenwashing’ directive promotes the Environmental Footprint methods for making environmental claims, which steer companies towards tracked electricity use, making GOs an integral tool of this life-cycle assessment methodology, regardless of granularity. Depending on the implementation deadline, demand for GOs could rise from 2027 onwards."
– Mary Polovtseva, Veyt

Bruno Brunetti, Head of Low Carbon Electricity Analytics at S&P Global, sees evolving EU regulation and the arrival of 24/7 hourly matching dovetailing to make GOs more effective in helping firms reach net zero targets.

Corporations looking to reach 100% carbon free energy can achieve that now using annualised GOs and over-sizing clean energy purchases by tacking on storage or adding wind and solar plants. Granular certificates, however, “offer a more flexible, and potentially cheaper, alternative to decarbonise the last MWh of power”.

“In highly decarbonised power markets, it will become more important when renewables are generated. Granular certificates are another signal to reward and price flexibility of clean energy.”
– Bruno Brunetti, S&P Platts

Cost is going to become an even bigger consideration, he notes, as the price of hourly GOs “will move to a level that incentivises more flexibility in demand or adds flexibility in terms of additional generation or storage.

“Hourly GO prices are likely to be highly volatile — or at least as volatile as hourly power prices. Hourly certificates will be trading at the annual GO price during periods of surplus renewable generation, while during periods of low renewables supply, the price will be high enough to limit consumption or enable additional flexibility solutions.”
– Bruno Brunetti, S&P Platts

Who will lead the way? Brunetti expects the certificate market in Europe to fragment, with sectors like hydrogen and big tech being early adopters of hourly matching. Annual certificates will continue to play a role, however,  “helping companies in earlier stages of their decarbonisation journey.”

Daly also points to hydrogen as an indicator of where EU regulation is likely to take us.

“The EU's green hydrogen rules will require all clean hydrogen producers to adopt hourly matching by 2030 in order to be called renewable.”
– Killian Daly, EnergyTag

Conclusion: Staying on track in a changing landscape

Energy buyers today face stricter rules on when and where their clean energy is sourced. Renewabl helps you stay compliant and impactful with a combination of technology and hands‑on guidance.

With Renewabl, you get:

  • Hourly CFE scores and emissionality metrics in every report — showing both compliance readiness and real‑world impact.
  • Centralised procurement and simplified tenders across PPAs, GOs, and green tariffs, all time‑ and location‑matched.
  • Transparent insights, including market pricing and contract performance forecasting, giving your team confidence in procurement decisions.

Beyond technology, Renewabl acts as a digital consultancy, guiding procurement teams through evolving rules like CSRD, RED III, and the GHG Protocol updates. Book your discovery call now.

– With files from Renewabl contributor Mark de Wolf

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