The Greenhouse Gas Protocol underpins how most companies report electricity emissions. In October, it opened a public consultation on proposed updates to Scope 2 guidance. These changes focus on traceability, physical reality, and time. They affect how companies use Guarantees of Origin, how “100% renewable” claims work, and how closely energy procurement reflects real system decarbonisation.
In this episode of Plugged In, Montel News speaks with EnergyTag and Renewabl at RE-Source in Amsterdam about what is changing, why it matters, and how companies should respond. This is the original transcript with light clean-up for readability.
Guests: Richard Sverrisson (Montel News), Alina Trabattoni (Montel News), Carolyn Addy (Renewabl), and Killian Daly (EnergyTag).
TL;DR
What is the debate around Scope 2
Richard Sverrisson — Editor-in-Chief, Montel News:
We’re in the middle of the bustling Beurs van Berlage, the former stock exchange building in the heart of Amsterdam, where nearly 1,500 industry professionals have gathered to discuss issues affecting corporate renewable energy procurement. One of the hottest topics is GOs — Guarantees of Origin — and the Greenhouse Gas Protocol. On 20 October, the Greenhouse Gas Protocol launched a 60‑day public consultation, inviting input from professionals across the industry on proposed changes to the current guidance.
On the 20th of October, the Greenhouse Gas Protocol launched a 60-day public consultation, inviting input from professionals across the industry to share their thoughts on proposed changes to the current guidance. [Note: The consultation period has been extended until 31.01.2026]
Alina, welcome. Could you explain to our listeners what the response has been to the proposed changes in the protocol? What are you hearing from your sources?
Alina Trabattoni — Reporter, Montel News:
There’s a lot of debate, and a lot of excitement around the push for globally recognised accounting standards – a clear framework for measuring and reporting emissions across companies, governments, and organisations.
Crucially, the debate is focused on whether we need more transparent methods or not, and methods that would allow for easier comparison globally as well. And as it always does with climate-related issues, the conversation is getting quite heated. People are getting very passionate.
On the one side, you have those pushing for granular reporting — stringent, clear, transparent reporting — and that's NGOs, companies, regulators, and of course big tech, the Googles of this world. They very much advocate for it, and they see it as essential for getting to net zero, for real decarbonisation.
And of course, there's also a lot of opposition, and that mainly comes from some other industry groups, energy suppliers, power authorities as well, who are concerned not so much about the transparency per se — which they back — but about the complexity and the costs that it would all bring on board, making it also a barrier for smaller players in the market.
Some worry that these stricter rules could conversely slow down a market move towards a complete green transition — net zero decarbonisation — and make it more difficult for some firms to operate across these complex systems.
Hourly and locational matching, in context
Richard Sverrisson:
So what does this mean in concrete terms for the energy transition?
Alina Trabattoni:
From a green energy and net‑zero perspective, it would allow new mechanisms and instruments to be embedded into the frameworks.
Let’s take, for example, location and time signals. These are the so-called hourly and location matching reporting methods that would be included into emissions accounting. This basically means that companies would need to match their renewable energy use to the actual hours of green energy that they use, and the actual locations the green energy comes from — not just annual totals, which is the case right now.
Right now, companies can use offset credits in some cases, even from distant regions, which becomes very generic and unclear. And to be honest with you, it is criticised because it allows for a lot of grey areas. In some extreme cases, even greenwashing.
The idea is to strip away these vague, mismatched green claims and, in a nutshell, incentivise the use of clean energy when and where it's produced.
Richard Sverrisson:
Alina, thanks very much. So what do big businesses say about Guarantees of Origin and the Greenhouse Gas Protocol?
What the GHG Protocol is, and who it affects
Richard Sverrisson:
I’m pleased to be joined by Carolyn Addy, Head of Commercial at Renewabl, and Killian Daly, Executive Director at EnergyTag, a nonprofit think tank. A warm welcome to you both.
Killian, what is the Greenhouse Gas Protocol, and why is it significant?
Killian Daly:
So the Greenhouse Gas Protocol is basically the carbon accounting rules used by about 97% of the Fortune 500 companies to report their emissions. It's the set of rules companies use to calculate how many tonnes of CO₂ do I have.
The hot topic today and at this conference is the Scope 2 — electricity emissions accounting — and proposed changes that are coming for that standard.
By way of background: I used to buy power for a French company called Air Liquide — wholesale power procurement at very large scale — and I then also used to do the carbon accounting using the Greenhouse Gas Protocol. So I've worked with it practically in the past and saw some areas of improvement potentially.
Now, my day job largely is working on trying to improve the standard as a member of the technical working group that's updating the Greenhouse Gas Protocol.
The Greenhouse Gas Protocol is the carbon accounting rulebook used by about 97% of Fortune 500 companies.
– Killian Daly, EnergyTag
Richard Sverrisson:
Could you explain to listeners what Scope 1 and Scope 2 are, and the difference?
Killian Daly:
Scope 1 is the emissions you have directly from burning stuff in a factory. You're burning gas to make heat, or you're burning coal to make electricity. That's your Scope 1, on your operational sites.
Scope 2 is really the emissions that are output by someone else to supply you electricity.
Richard Sverrisson:
That’s why here at the renewables conference, it's so important.
Carolyn, who does the Greenhouse Gas Protocol affect? It’s not just the Fortune 500, is it?
Carolyn Addy – Head of Commercial, Renewabl:
It is the main accounting standard for carbon accounting. Most companies doing any kind of carbon accounting will be using the GHG Protocol.
Richard Sverrisson:
And why are these accounting standards so important?
Carolyn Addy:
You need a common baseline for companies to be measuring their carbon emissions so that we can accurately track where we are now and what progress we're making. If you don't have a common baseline, it calls into question the accuracy of performance measures, target setting, etc.
If [companies] don’t have a common baseline [to measure their emissions], the accuracy of performance metrics and target setting is questionable.
– Carolyn Addy, Renewabl
Richard Sverrisson:
And this is a global standard, not just European, right? And it’s voluntary rather than mandatory?
Carolyn Addy:
Yes, it’s global, and it’s voluntary – it’s a choice of accounting standard. But it also underpins initiatives like SBTi, RE100, and CDP, so most of those target‑setting frameworks use GHG Protocol rules.
[The GHG Protocol] also underpins initiatives like SBTi, RE100, and CDP.
– Carolyn Addy, Renewabl
Why updates are on the table
Killian Daly:
Even though we might see a backlash against some sustainability criteria, it depends where you are. The US is a big place, and some states are doubling down.
I was in China last week. There's definitely not a backlash against clean energy there.
In Europe, I don’t think there’s a broad backlash against sustainability. Ultimately, we don’t have a choice — we have to decarbonise for energy security and competitiveness. We don’t have cheap gas, so we need to go down this path.
You mentioned sustainability standards: the EU has the Corporate Sustainability Reporting Directive, which is being trimmed down but will still apply to large companies. The Greenhouse Gas Protocol is one of the methodologies referenced in that standard. So there are regulations that effectively require companies to report, and GHG Protocol is the main way they do that.
To put it simply, imagine we had no common standards for financial accounting and everyone could define profit however they liked. There’d be no comparability, and we couldn’t see which businesses are really performing well.
Today’s Scope 2 standard was first defined over 10 years ago, when there were far fewer renewables on the grid, mainly to help get a market started. There are now some glaring concerns and inaccuracies that mean a number of very large companies already report “no emissions”, which doesn’t reflect what’s actually needed to get to zero emissions in society or in power systems.
Today’s Scope 2 standard was first defined over 10 years ago [...]. There are now some inaccuracies that mean a number of very large companies already report “no emissions”, which doesn’t reflect what’s actually needed to get to zero emissions in society or in power systems.
– Killian Daly, EnergyTag
Richard Sverrisson:
Are any companies pushing back against the protocol itself, saying they’ll do their accounting differently, or is the commitment still strong from big tech and smaller companies?
Carolyn Addy:
I don’t see much pushback against the protocol itself. The debate is about what the changes should look like.
The updates are under public consultation now, and everyone should take the opportunity to have their views heard. So there’s discussion about how it should evolve, but not about whether it should evolve.
Richard Sverrisson:
We’re talking in particular about the impact on Guarantees of Origin — the way you verify that the power you consume is green.
What are the changes on the table?
Carolyn Addy:
Fundamentally, it’s about increasing traceability and credibility in reporting.
Currently, many corporates report on an annual basis. We are moving toward more granular spatial (locational) and temporal (hourly) matching, so you can say that every hour of consumption you report as clean is matched by actual clean production.
Killian Daly:
A good model for what’s proposed is how the power market works today. Power is settled on a 15‑minute basis in regions where power is physically deliverable or where there’s a single price.
The proposal is that, after a phase‑in period — for example after 2030 — large companies, so only a subset of all companies, would have to do hourly reporting of where their energy is coming from.
This doesn’t mean they must be 100% clean every hour, but it does mean, for instance, they can’t claim to be using solar power in the middle of the night, as they effectively can under today’s rules.
There will also be market boundaries that better reflect physical reality. If you’re in Portugal, you probably won’t be able to say you’re 100% supplied by Norwegian hydropower, because that isn’t physically real. You can’t ring a power supplier in Norway and get your power delivered directly to Portugal.
So it will tighten the types of claims that are possible today, where some have a very weak link to how the power grid and power markets actually work.
There will be flexibilities. SMEs won’t have to do hourly accounting. Companies can use load profiles if they don’t have hourly data for all sites. The idea is to phase this in appropriately while making fundamental improvements in accounting accuracy.
After a phase‑in period — for example after 2030 — large companies, so only a subset of all companies, would have to do hourly reporting of where their energy is coming from.
– Killian Daly, EnergyTag
What companies need first: visibility
Richard Sverrisson:
Does this imply that the market architecture or regulations also need to change? Is something in the framework lacking that needs to be tightened up? Carolyn, what’s your view?
Carolyn Addy:
The key is visibility — having the tools to see where a corporate’s consumption is matched by the solutions they procure, whether that’s unbundled EACs, a green tariff, or a PPA.
The data exists; it’s about accessing it and having systems that allow you to report on it and then act on it.
For most companies, the first stage will be gaining visibility. Then they can decide: What can we realistically achieve? What ambition should we set around this hourly piece? And how are we going to achieve that? They need that foundational understanding.
The key is visibility — having the tools to see where a corporate’s consumption is matched by the solutions they procure, whether that’s unbundled EACs, a green tariff, or a PPA.
– Carolyn Addy, Renewabl
Should companies aim for 100% 24/7 CFE?
Richard Sverrisson:
On hourly matching: you said that even with hourly data, companies don’t have to be 100% green. Should they be striving for that?
Killian Daly:
Ultimately, yes. But being truly 100% green is hard, unless you’re somewhere like Norway.
If you’re in Germany, being 100% renewable on the German system is very hard. We should strive toward it, but if companies claim 100% renewables while the grid is only 50% renewables, something doesn’t quite add up.
The end goal should be 100% real clean power, but that will look different in different places. The Greenhouse Gas Protocol is an accounting methodology; it tells you what your emissions are, not that you must be at zero by a specific year.
We have a lot of companies who are 100% renewable already — big tech companies — according to today's rules. That's good. It's fantastic they're in these markets buying renewable energy. But it's not accurate to say that they are 100% green, because they're still not green at nighttime, when there's no wind or sun, but they're using credits from the daytime.
We probably need a reset about some of these targets. Being 100% renewable right away next year shouldn't be the only acceptable thing. Decarbonisation is hard. In some grids, it's extremely hard. Maybe 80% green is already a great thing in Germany — but not based on fudged accounting.
A bit of a reset about some of these targets: maybe 80% genuinely green in Germany is already a great achievement — but not based on fudged accounting.
– Killian Daly, EnergyTag
Carolyn Addy:
I think that’s really important. When we talk about these changes, we often focus on the challenges and how difficult it may be for companies to adapt, and sometimes that’s overblown. I also don't think that because something's difficult, we shouldn't do it.
There’s a strong opportunity for climate leaders – front‑runner companies that have already been 100% renewable on an annual basis for years. What’s their next step? Where can they invest R&D and resources into something that shows more credible impact and delivers real benefits?
They don’t want to just sit back and say, “We’ve done our bit, now it’s up to the rest.” But to secure internal resources, they need to show a clear benefit from going further. They’re accountable to investors and stakeholders, and they want to be able to say, “We’re pushing the envelope.” As is often the case, there's an opportunity as well as a challenge.
There’s a strong opportunity for climate leaders – front‑runner companies that have already been 100% renewable on an annual basis for years.
– Carolyn Addy, Renewabl
Why storage and flexibility matter
Killian Daly:
For example, to get to zero as a company or a society, we need to build a lot more renewables, but we also need many more batteries, much more demand flexibility, and probably some clean firm capacity in certain countries.
Today, only about 1% of PPAs include storage. Hardly any European countries issue Guarantees of Origin for storage. We have a long way to go. If we’re not thinking about demand response, storage, and other solutions that firm up renewables, we’re doing only half the job.
If the accounting system says you’re “done” just by buying wind, solar, and maybe some hydro, it’s not capturing the full picture.
Today, only about 1% of PPAs include storage.
– Killian Daly, EnergyTag
Richard Sverrisson:
This is crucial when we talk about matching: there’s a debate around whether you simply say “the grid is 100% renewable, therefore I’m 100% renewable,” versus buying specific Guarantees of Origin.
Location-based vs market-based
Does this update put an end to that debate between location‑based and market‑based methods, or will it continue?
"Both location‑based and market‑based methods will continue. They’ll just have slightly different criteria."
– Carolyn Addy, Renewabl
Killian Daly:
Both will remain, but the current market‑based rules often don’t reflect reality.
Take Norway. Norway exports about 20 terawatt hours of electricity in a year, and about 120 terawatt hours of green certificates — six times more than it actually ever could in power.
You end up with situations where a company who doesn't buy any GOs in Norway, in market-based accounting, is shown as fully powered by fossil fuels — even though there's hydro all around.
Some of the disconnects between the location and market-based method will be somewhat resolved with these changes, because it draws the market-based method back more to reality, but still enables people to go out into the market and buy green energy and make a change — something you cannot do in the location-based method.
"Norway exports about 20 terawatt hours of electricity in a year, and about 120 terawatt hours of green certificates."
– Killian Daly
Greenwashing risk and heavy industry examples
Killian Daly:
I’ve spoken to aluminium smelters in Norway and Iceland who have serious concerns with the current methodology. On paper, they’re shown as powered by fossil fuels in Iceland, even though there are none, because their certificates are exported to Europe, and Iceland has no interconnection to Europe.
That will be fixed in the new approach.
It will also put more value on truly green production. Those Icelandic producers are competing with aluminium smelters in the Middle East that are 100% gas‑powered but then buy RECs from a nearby country and claim green aluminium with no physical link to the actual supply. That’s not a good incentive structure if we’re serious about decarbonising heavy industry like aluminium.
What happens to cross-border certificate flows?
Richard Sverrisson:
Could this also put a stop to, for example, green power produced in Norway, Iceland, or Sweden selling certificates to Portugal or to the Dutch railway company, allowing them to claim they’re green?
Carolyn Addy:
Once you start putting a time‑based value on EACs, you effectively create a more sophisticated market. EACs generated at times of low supply will have higher value, and whoever needs them will pay for them.
Although this is an accounting standard, it also helps derive market signals that push us toward a fully diversified energy system within each country. A lot of today’s cross‑border redistribution reflects missing or distorted market signals. Correcting that is the end goal.
Killian Daly:
EACs are Energy Attribute Certificates, by the way.
In the proposed rules, in Europe, matching will be largely “in‑country”, except where you can prove interconnection. Norway will still be able to export GOs to serve corporate customers in other parts of Europe, but only in a way that respects actual electricity flows out of Norway.
So if 20 units of power can flow, only 20 units of certificates can follow. If interconnection grows, that ceiling can grow — but it will be tied to reality. Today, there is effectively no such limit. Almost the entire Norwegian hydro fleet exports certificates across Europe, which dampens the signal to build more renewables in places like the Netherlands, because they rely on “Norwegian hydro” that doesn’t really supply them.
Norway will still be able to export GOs [...], but only in a way that respects actual electricity flows out of Norway. So if 20 units of power can flow, only 20 units of certificates can follow.
– Killian Daly, EnergyTag
Killian Daly: So yes, this could reduce some of the supply from places like Iceland. But the GO market has been oversupplied for years – prices are very low, too low to materially drive new renewable investment on their own.
Some big Norwegian and Icelandic utilities may not like losing that revenue, but from a system perspective, it could be positive.
There will also be mechanisms, similar to how cross‑border power trades work now, to ensure the amount of certificates transferred reflects physical constraints.
Market response so far
Richard Sverrisson:
So these changes could significantly affect how the market operates, particularly for Guarantees of Origin.
Carolyn, what has been the response from the market so far?
Carolyn Addy:
Certain sectors are ahead: the tech sector has led this for years. We also see strong interest from FMCG and other consumer‑facing businesses.
A lot of front‑runners — RE100‑type companies that want to be sustainability leaders — are very engaged. Many are currently focused on gaining visibility rather than immediately setting hourly matching targets. They see the changes coming and want to get ahead: understanding how their load looks hourly, what they might aim for, and what the potential cost implications are.
Certain sectors are ahead: the tech sector has led this for years. We also see strong interest from FMCG and other consumer‑facing businesses.
– Carolyn Addy, Renewabl
Killian Daly:
If you take Engie, for example — one of the biggest PPA suppliers in the world — they have a stretch goal for around 20–25% of all their PPAs to be 24/7 PPAs by 2030.
They’re thinking about how to move towards more hourly‑matched PPAs and products that better match actual consumer demand.
Ultimately, a PPA should match demand as closely as possible to hedge a customer’s electricity supply. The PPA market has been in decline in some places because there hasn’t been enough focus on adding batteries alongside solar. Today’s GO market doesn’t incentivise solving that problem, but we must solve it for a healthy PPA market in future.
Of course, some people will lose and others will gain. Those currently making money by selling large volumes of GOs into regions where the underlying power isn’t deliverable will find these rules more challenging. But developers of renewables and storage in countries where cheap certificates disappear will benefit. Like any change, there will be winners and losers.
And yes, a simple step that should happen quickly is issuing GOs for storage charged with renewable energy. That’s not happening in many markets yet, and it needs to.
Corporate concerns about proposed Scope 2 updates
Richard Sverrisson:
Carolyn, are there concerns around these changes, alongside the enthusiasm you’ve described?
Carolyn Addy:
I mostly work with corporates that will have to comply with the new rules. Their concerns are around complexity, additional resources, and cost — and what this will mean for their sustainability targets.
Even those who are positive about the direction are cautious about what implementation will look like: changing internal systems, integrating new data into existing EMS platforms, and so on.
So while there is positivity, there’s also a realistic appreciation of the work required.
Next steps and where the consultation stands
Richard Sverrisson:
To round off, Killian, what are the next steps in the process? When does the consultation close, and what happens after?
Killian Daly:
On concerns: not everyone fully understands what’s being proposed yet. Many are still reading and trying to figure it out.
I spoke yesterday with a large utility that thought the proposal required their customers to be fully 24/7 matched by 2035, which is not what it says. A lot of questions are simply about understanding the proposal and then identifying opportunities within it.
In terms of process: the Greenhouse Gas Protocol has opened a public comment period. It’s open until 19 December [Note: This has been extended until 31.01.2026], and everyone is encouraged to respond.
At EnergyTag, we’re publishing a guide to help people understand and demystify the documents, because it’s a complex topic and the materials are quite dense. It’s really important that stakeholders make their voices heard so that the updated standard that emerges has high integrity but is also workable in practice.
