More clarity on future requirements for location and hourly matching of Guarantees of Origin (GOs) under GHG Protocol Scope 2 standards is expected to emerge by mid-2026.

In July 2025, the GHG Protocol Independent Standards Board voted on the Scope 2 revisions proposed by the Scope 2 Technical Working Group to be included in the forthcoming public consultation period. The consultation will open this autumn for 60 days and provide an opportunity for feedback on the Scope 2 standards development, including on the topic of additionality. The finalised revised text is expected by mid-2026, with final publication of the full revised Scope 2 standards anticipated for the end of 2027.

Changes to the location- and market-based methods are proposed.

For the location-based accounting, these include a new emission factor hierarchy that prioritises more accurate accounting over time and across regions. But this level of detail is only required when the necessary activity data is available, and the emission factors are free and publicly accessible. In the EU, the Commission’s Joint Research Center freely provides GHG emission factors for electricity consumption with several years’ delay, while the IEA’s emission factors are behind a paywall.

New location and hourly matching criteria are introduced for the market-based accounting. The GHG Protocol did not provide any details as to the granularity requirements of location matching in their announcement (e.g. country level/bidding zone). However, the GHG Protocol Scope 2 guidance that is in force at the moment, treats the EU as a single market and thereby permits the use of GOs from the AIB area, per Veyt’s understanding.

In addition, the existing GHG Protocol Scope 2 guidance already recommends that:

Temporal matching is proposed to be required only when companies are making voluntary clean energy claims, while exemptions apply to smaller organisations and long-term contracts via a legacy clause. No details were given as to the level of time stamping put forward (e.g. hourly, monthly). Under the current standard, annual electricity disclosure is recommended.

Still, some flexibility is suggested: estimated hourly data can be used, so that the annual or monthly consumption data already collected can be matched with hourly generation data.

All new requirements will be phased in over time, giving several years of head start.

Separately, RE100, a voluntary initiative for renewable electricity procurement for corporates, has a 15-year age limit on commissioning/repowering of power plants, while its single market boundary for Europe excludes the UK.

This development is expected to affect the GO market only in the long run due to the ongoing revision of the Scope 2 guidance. 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.

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.

France has a monthly matching regime in place; Switzerland will introduce quarterly disclosure from 2027 onwards.

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 (see below). The revised Renewable Energy Directive (III) enables the issuance of granular GOs in Watt-hours (Wh).