Proposed changes include hourly matching of renewable supply and demand, and stricter rules on the physical deliverability of PPAs and GoOs. As the GHGP underpins most corporate reporting, these reforms could significantly influence future corporate renewable procurement strategies.
The GHGP is the world’s most widely used framework for corporate GHG reporting, has launched a 60-day public consultation on proposed updates to its Scope 2 Guidance, which sets the rules for reporting emissions from purchased electricity. The current guidance dates back to 2015 and underpins how corporates use renewable energy certificates (RECs), GoOs and PPAs to reduce market-based emissions from their purchases of electricity, steam, heat and cooling (Scope 2). The consultation runs from 20 October to 19 December 2025.
The GHGP includes two methods for calculating Scope 2 emissions: the location-based method (LBM) and the market-based method (MBM). The LBM reflects the average emissions of the geographical location where the electricity was purchased or acquired, while the MBM provides the opportunity to reflect emission savings from the energy procurement decisions and actions taken by the end consumer, such as entering into PPAs
The key proposed changes include:
In the proposed revisions, the structure of the updated Scope 2 reporting framework would remain the same but would now include more stringent requirements focused on introducing hourly-granular matching and stronger locational credibility for renewable electricity claims. These rules determine how emissions from purchased electricity are calculated and reported, and changes could potentially reshape clean energy procurement and voluntary renewable energy markets globally.
The current GHG framework recognizes contractual instruments (such as PPAs) that match consumption with renewable generation on an annual basis.
The proposed update would now require hourly matching under the market-based method. This would mean that relying solely on single-technology, pay-as-produced solar PPAs or unbundled certificates would no longer be sufficient to claim market-based Scope 2 reductions for all consumption hours, as companies would need renewable supply that matches the timing of their actual electricity use. The proposal foresees some degree of exemptions (although these have not been clearly specified).
It also proposes ways to make reporting on hourly matching easier. For example, hourly supply load profiles will be supplied to help translate monthly or daily electricity consumption data into hourly data, to enable hourly reporting.
The proposal also includes a transitory period as well as a time-limited legacy clause, which would recognize investments and contracts already closed (“grandfathering”).
Hourly matching with physical deliverability is being proposed to improve the accuracy of Scope 2 inventories, decreasing the prevalence of corporations reporting inputs that they could not have consumed.
Under the 2015 guidance, contractual instruments must be sourced from the “same market” as the reporting entity’s load. This is generally interpreted as national boundaries with recognition of some multinational markets. For example, the EU is often considered a single market, even though it consists of several countries, because it has common market rules and regional interconnection.
The proposed update now redefines this boundary based on “physical deliverability”: that is, it must be plausible that electricity from the source of purchased generation is physically able to reach the reporting consumer’s grid region. This is not confined to national borders alone, but boundaries will be informed by physical interconnection or coordinated market operations. A company may prove deliverability from an adjacent, directly connected market through two ways.
The GHG Protocol is not a target-setting body, but it provides the accounting rules used by most corporates for voluntary reporting, including RE100. The proposed updates would potentially shift companies away from annual matching using unbundled, cross-border GoO certificates toward hourly matching, locationally credible renewable energy sourcing, and potentially greater reliance on physical PPAs.
Under today’s annual approach, a buyer can use GoOs from solar plants to claim 100% renewable electricity, even for their consumption occurring during non-solar hours. Hourly matching would restrict solar attributes to the hours in which solar actually produces, requiring companies to procure additional attributes (e.g., from wind or storage-backed assets) to fill the gaps.
This would materially change reporting outcomes. RE100 data shows that 30% of members already claim 90–100% renewable consumption, and over 60% target 100% by 2030 largely through unbundled EACs, which currently represent 39% of RE100 procurement. Under the proposed rules, many companies would be able to claim significantly fewer Scope 2 reductions with their existing procurement strategies.
Tighter physical-deliverability criteria would also reshape certificate markets. GoOs currently flow freely across borders, with Germany importing more than 160 TWh in 2023 from countries such as the Nordics, far exceeding physical power flows. If attributes must be deliverable within the same grid region, GoO prices could rise sharply in net-importing countries.
For PPAs, the reforms would potentially reduce the future eligibility of VPPAs and unbundled certificates for Scope 2 reductions unless they meet strict deliverability requirements. This could depress VPPA demand, in markets like the US, while increasing the demand forf physical PPAs, which already dominate in Europe (only ~17% of 2025 YTD deals have been virtual).
Additionally, the proposed changes could help increase the attractiveness of hybrid PPAs or multi-technology PPAs and help to increase the willingness to pay a premium for hybrid PPAs, for flexibility-integrated procurement options, that would be needed to achieve hourly matching.
A key point of the proposal is that existing investments and PPAs will be protected under legacy clauses. The update suggests crediting long-term contracts signed before the new rules take effect under the current accounting framework. This would effectively mean that any PPA signed before 2028 would be grandfathered
The consultation documents also propose exempting small energy users from hourly matching requirements, and phasing in the new rules to support planning certainty and market development.
The consultation is open until 19 December, giving market participants an opportunity to provide feedback, raise concerns and highlight practical implications for corporate reporting and renewable procurement. Once the consultation closes, the GHG Protocol plans to publish draft guidance in 2026, finalize the updated standards in 2027, and bring the new rules into effect from 2028.
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