Ahead of the public consultation on the Scope 2 standards revision, the GHGP’s Technical Working Group proposed mandatory hourly matching and geographical correlation.
The public consultation period for proposed updates commenced on 20 October and will conclude on 19 December 2025.
This is set to affect the Guarantees of Origin (GOs) and the Power Purchase Agreement (PPA) markets.
In July 2025, the GHG Protocol Independent Standards Board (GHGP) voted on the Scope 2 revisions proposed by the Scope 2 Technical Working Group (TWG) to be included in the newly launched public consultation period. The consultation has now opened for 60 days and provides an opportunity for feedback on the Scope 2 standards development.
The finalised revised text is expected by mid-2026, with final publication of the fully revised Scope 2 standards anticipated for the end of 2027. Any phase-in would be considered thereafter. The last major update to the GHGP Scope 2 guidance was published in 2015.
GHGP Scope 2 guidance is referred to in the European Sustainability Reporting Standards (ESRS) that companies under the Corporate Sustainability Reporting and Due Diligence Directive (CSRD and CSDDD) need to apply. Once the new standard is adopted, it will repeal and replace the 2015 Scope 2 guidance. This could, in turn, mean that the CSRD-scoped companies might be affected by this, as the ESRS currently guide reporters to “take into account” the 2015 GHGP when disclosing GHG emissions.
Changes to the location- and market-based methods are proposed.
If the discussion in the past focused on the upkeep of dual reporting and whether market- or location-based method should prevail, now dual reporting is preserved with stricter temporal and spatial requirements suggested. This could be explained in part by the composition of the technical working group and the internal split on the level of temporal precision, with some proposing annual or monthly matching and others – hourly matching.
Following the consultation period, the GHGP will work with the TWG to revise the draft standard.
An update to the location-based emission factor hierarchy is proposed that seeks to provide more guidance on spatial (bidding zone, national level) and temporal (hourly, monthly, annual) granularity. For instance, given the choice between the two emission factors, the first one being a national emission factor with hourly temporal resolution, and the second one being a local emission factor with annual temporal resolution, the second emission factor should be selected.
These emission factors need to be accessible, i.e. “publicly available, free to use, and from a credible source”. In the EU, national emission factors are published by the European Commission on an annual basis with a several years delay. In this case, the GHGP suggests that when only older emission factors are accessible, the most recent data shall be used.
To make hourly matching practical and accessible, the proposal would allow an organisation to use load profiles (e.g. facility-specific profiles, utility/customer-class profiles, etc.), which let users disaggregate their monthly or annual electricity consumption into an hourly consumption estimate. This consumption can then be matched with hourly emission factors. In the EU, transmission system operators (TSOs) and distribution system operators (DSOs) often have load profiles publicly available.
Under the current standard, annual electricity disclosure is recommended. The GHGP now proposes to require contractual instruments with hourly temporal correlation for matching the underlying electricity to the reporter’s consumption.
The rationale behind opting for hourly granularity over annual matching is to deliver Scope 2 emission reduction. The GHGP cites research publications suggesting the market-based method may be insufficiently effective in slashing GHG emissions. Furthermore, the European Network of Transmission System Operators for Electricity (ENTSO-E) supports hourly matching.
The technical working group proposes imposing different requirements based on the consumer’s consumption threshold, so that organisations under a threshold (e.g. 5-15 GWh annually across individual markets) are exempted from hourly matching, but could, for instance, be required to use monthly or annual matched EACs.
The standard requires deliverability, which means that electricity from a generator could plausibly be part of the mix serving the reporting entity through an electrically connected grid. In practice, this means that attributes sourced from generating facilities need to be located within the same deliverable market boundary as the demand to which they are applied. In this context, deliverability aligns with ENTSO-E’s zonal pricing boundaries and serves to better reflect the realities of the physical grid.
Per Veyt’s understanding, reporters would either need to procure EACs from the same bidding zone they are operating in or source them from strongly interconnected bidding zones (e.g. Central Western Europe, Nordics, Baltics, Iberia).
This introduces an element of geographical matching to the GHGP requirements.
Prior, the GHGP treated the EU as a single market and thereby permitted the use of GOs from the AIB area, recommending geographical matching but not requiring it.
The GHGP suggests treating standard supply service (SSS) agreements differently in the market-based Scope 2 calculations to prevent double counting.
Thus, where default utility suppliers serve consumers, reporters need to distinguish their share coming from the SSS and voluntary renewable electricity procurement. The corresponding SSS EACs need to be cancelled, thus making them ineligible for use in the voluntary market, and will thus not be part of the European residual mix.
Claims of renewable electricity consumption from the SSS will need to align with the updated Scope 2 quality criteria. Since most SSS agreements are long-term, spanning 10-20 years, and are cumbersome to renegotiate, the GHGP would consider legacy clauses.
The new requirements will guide the companies throughout the 2030s and are set to change how companies track, manage and report their Scope 2 emissions.
Hourly matching introduces more technical and operational complexity, driving up compliance costs. The infrastructure needed to facilitate this transition (registries, trading exchanges, etc.) is yet to fully adapt, develop and mature.
While the revised Renewable Energy Directive (III) enables the issuance of granular GOs in Watt-hours (Wh) and the keystone European standard for GOs (EN16325) ensures this is applied, most countries have yet to transpose this provision into national law and adopt the new standard. Thus, today’s registries have not yet made the transition to issuing hourly time-stamped GOs.
With the market for granular certificates still in a nascent state and the scaling back of the sustainability reporting requirements in the EU, it is unclear whether companies reporting to the voluntary Climate Disclosure Project (CDP) would want to embrace stricter requirements or accept getting a lower “climate score” by foregoing them to cut costs. Voluntary compliance is one of the drivers behind the increased RES-E GO cancellations and the deployment of renewables in Europe; the GHGP’s new guidance could undermine their adoption.
This development is expected to affect the GO market only in the long run due to the ongoing revision of the Scope 2 guidance, and if the proposed guidelines are adopted as they are. In the short to medium term, we can expect GO market participants to closely follow the consultation and adoption process related to location and temporal matching, as this is likely to affect their long-term hedging strategies.
The GHGP's new temporal requirement could split the EECS GO market into two, with some market players opting for less stringent annual matching or none at all, and those pursuing hourly matching. Greater fragmentation of demand by technology and origin could introduce greater price volatility in the market, with certificates issued during low RES-E generation times capturing higher prices. This could also carve out a role for storage certificates.
PPAs can technically provide hourly granularity in the delivery of both power and GOs. Especially in pay-as-produced contracts, electricity delivered to the consumer is linked to actual generation from the contracted asset. In addition, most PPAs in Europe are being signed within the same bidding zone, or at least market area, providing spatial correlation. However, common contracts cover electricity generation from single solar or wind power projects, which rarely coincide with the consumer’s hourly load profiles. In 2024, 50 % of PPAs were signed for solar PV, and around 30 % for wind (onshore and offshore), with the remaining contracts covering other RES or a combination of multiple technologies. Only 9 out of 268 deals in 2024 were cross-border PPAs. The proposed changes could mean that companies need to adapt their PPA strategy to more closely match their load profile. This can be achieved through a portfolio of PPAs with different delivery profiles, multi-technology PPAs or with battery storage onsite or included in a PPA (so-called hybrid PPAs).
At present, hydrogen producers are the only ones in the EU legally obligated to correlate their electricity consumption in time and space; matching practices may extend beyond renewable hydrogen makers if the GHG Protocol Scope 2 guidance adopts the current proposal.
Already, France has a monthly matching regime in place; Switzerland will introduce quarterly disclosure from 2027 onwards. Other countries, such as Germany and Austria, mandate annual matching. A granular certificates system is put up for approval in Ireland for large electricity users such as data centres, while other domains in the AIB are piloting hourly GOs.
Separately, the ISO and the GHGP announced a strategic partnership to harmonise their existing GHG standards and to co-create new standards on 9 September 2025.
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