In short: The impact of the revised GHG Protocol Scope 2 Standard on your EAC management
- The revised Scope 2 Standard will bring stricter rules for which EACs qualify for renewable energy claims and how EACs must be recorded and managed, and also seeks to introduce hourly matching with deliverability.
- These changes will challenge how companies have been reporting for many years, with some stakeholders arguing that the new standard moves the system forward 20 years and faster than the market is currently prepared for.
- Industry associations have mixed feedback on the proposed standard, from EnergyTag strongly supporting granular, hourly matching to RECS supporting tighter controls but pushing back on the additional reporting it may require.
- Manual spreadsheets and disconnected registry exports will not keep up, so centralised and automated EAC management will become increasingly important.
- Different reporting frameworks may use different rules, which means EAC portfolio managers must be able to produce several reporting views from the same dataset.
Quick explanation of the revised GHGP Scope 2 Standard
The GHG Protocol’s revised Scope 2 Standard will change how companies have been reporting on their electricity use and energy attribute certificates (EACs) for over a decade, and many current systems will not be able to meet the new requirements. It is open for consultation until December 2025, after which it will be finalized and published.
The revised standard aims to tighten and standardize what counts as a renewable energy claim and how you validate your claims of using renewable energy. It also introduces proposals for hourly matching with deliverability to improve the accuracy of companies’ scope 2 inventories.
It has already sparked debate in corporate sustainability circles, because it means that, once this standard is introduced, thousands of companies will have to change how they classify, calculate and report on their scope 2 emissions.
This has a knock-on effect for companies who purchase EACs—or guarantees of origin (GoO) as they’re referred to in the EU—as they’ll need to tighten up how they manage these certificates.
Why the rules for Scope 2 emissions accounting are changing
Back when the GoO concept was first introduced, it solved the real problem of companies claiming to use renewable energy but not having any proof of doing so. It made it possible to buy renewable energy certificates at an affordable cost, for both large-scale and small-scale consumption. However, as the market grew rapidly, now averaging at 10% per year, it’s become clear that stricter controls are needed.
For example, a company in Germany can buy low-cost Norwegian hydro GoOs from power plants built decades ago and report its electricity as zero carbon. This is allowed today, but because the certificates are not linked to the place or timing of consumption, the claim does not reflect the emissions of the German grid or contribute to reducing them.
That’s essentially what Scope 2 Standard seeks to fix, making Scope 2 emissions accounting reflect actual reality and be fully auditable, rather than theoretical purchases of EACs from energy generated years ago.
Industry reactions to the proposed GHGP changes
Since the GHGP Scope 2 Standard draft was released, many industry associations and groups have publicly stated their stance, and the feedback is very mixed. Non-profit policy reform association, EnergyTag, has been pushing for hourly carbon-free energy matching for a while, so it reaffirmed its support for the GHGP’s shift toward granular, time-based (hourly) accounting.
Whereas RECS Energy Certificate Association is pushing back on the proposed standard, advocating to tighten up the existing controls but not introduce new reporting requirements as they fear this would put a disproportionate burden on companies and renewable energy developers.
The debate reflects a gap between the ideal of a unified emissions accounting and reporting standard across Europe and the reality that many companies do not yet have the data or systems needed to meet stricter rules.
The final Scope 2 Standard will likely fall somewhere in the middle, but either way, companies who buy and sell GoOs need to start improving how they manage them sooner rather than later.
How EACs are currently managed
Many companies who manage EACs today—such as utilities, renewable energy developers, and large corporations—still rely on spreadsheets and manual processes to record details of the EACs they buy or sell, reconcile the data with the relevant registries, and manage the EAC until it is delivered to the end customer.
This is not only inefficient from a time and costs perspective, but it also hugely increases the risk of data errors, missed delivery obligations, and ultimately financial costs from penalties, lost customers, or incorrect trades.
Matching of EACs purchased with consumption is usually done manually and on an annual basis, which means mistakes can go uncovered for months and reconciliation can take days of sorting through files and multiple registry datasets.
Future expectations for how EACs will be managed
As already mentioned, the Scope 2 Standard will see stricter rules for EAC matching and management, across both the market-based and location-based methods. The proposed changes for the market-based method include:
- EACs need to come from generation connected to the same synchronous electric grid where the buyer’s facility is
- More granular matching of EACs, including hourly matching for advanced users
- New generation that comes online is prioritized over EACs from old generation assets
The location-based method is not changing dramatically, but the draft rules would require companies to use more precise grid-emission factors and prioritize regional or grid-specific data when available rather than relying on broad national averages.
Even if the final Scope 2 Standard is softened, the direction towards stricter, more granular management of EACs across Europe is clear.
GHG Protocol and the CBAM
The upcoming Scope 2 changes also sit alongside other regulatory frameworks that treat EACs differently. For example, the EU’s Carbon Border Adjustment Mechanism (CBAM) does not accept GoOs or EACs for reducing the embedded emissions of exported products. CBAM only uses location-based emission factors, while the GHG Protocol still allows market-based reporting.
As a result, companies may need to follow two different methods for the same electricity use, depending on the reporting context. This incompatibility between GHGP’s market-based rules and CBAM’s strict location-based method is one of the clearest examples of why EAC management will become more complex and why organizations will need to produce parallel reporting views from the same dataset.
Take a German manufacturer as an example. It could potentially need to report Scope 2 emissions under the GHGP draft, comply with CBAM for exported products, and respond to supply-chain requests for more granular energy data. Each framework uses different rules for EAC eligibility and matching, which means the same electricity consumption may need to be categorized and reported in several ways.
While this issue will likely be clarified over time, it reinforces the need for accurate and flexible EAC management so you can comply with both approaches and maintain clear audit trails.
Centralizing EAC management in one platform
While some stakeholders feel that the Scope 2 Standard is trying to move the system twenty years forward in one revision, what they often don’t realize is that some companies are already managing their EACs in this way.
CerQlar centralizes EACs in a purpose-built, fully auditable platform that gives you a real-time view of your EAC portfolio and automatically reconciles your records with 30+ registries. It applies attribution logic and delivery-level matching so you can produce several reporting views from the same dataset.
This makes it possible to accurately capture, manage, and report on all EACs in one platform—whether you need to match and report annually (most common today), monthly, or even hourly (as proposed in new standards like the GHGP Scope 2 Standard).
Custom dashboards and filters mean you can slice and dice your EAC inventory and delivery obligations by country, region, counterparty or status so you can always ensure you’re in compliance with your contracts and can easily prepare reports or exports for different regulatory requirements like the Scope 2 Standard and CBAM.
It also frees up your team to focus on optimizing allocation of EACs to delivery obligations and helping to maximize the profitability of your portfolio, rather than spending hours locating and updating data in spreadsheets.
Want to learn how you manage your GoO portfolio efficiently while also ensuring compliance with the future Scope 2 Standard? Book a demo with one of our experts.
