Concern 322 · Working draft · editorial review in progress
Renewable energy certificate accounting gaps
Renewable-certificate accounting gaps arise when a clean-electricity claim hides differences between purchased certificates and the power available at the time of use.
Understanding the concern
A renewable energy certificate records attributes of renewable generation. Buying certificates can support a company's electricity claim under accounting rules, but annual matching may pair power used at one time with generation at another. Geography matters too: a distant project may not help supply the grid serving the facility.
Imagine balancing a yearly food budget. Spending enough over a year does not show that food was available for every meal. Similarly, a yearly renewable total is not the same as round-the-clock clean supply. Certificates are not automatically deceptive; the concern is whether the public claim explains what was actually matched.
An example
A facility uses electricity every night while its annual claim relies on daytime solar generation elsewhere.
Illustrative unless identified as a documented case.
Evidence and its limits
GHG Protocol distinguishes accounting methods and has considered tighter matching proposals. Proposed revisions are not presented as final requirements.
Greenhouse Gas Protocol · Accounting guidance
GHG Protocol Scope 2 Guidance ↗ (opens in a new tab)Accounting for purchased electricity and contractual energy instruments.
Greenhouse Gas Protocol · Standards update
Upcoming Scope 2 Public Consultation: Hourly Matching and Deliverability ↗ (opens in a new tab)Proposed changes announced in 2025; proposals must not be presented as final rules.
Broader frameworks and background
These resources provide context. They do not establish every claim in this concern.
A question to discuss
Does the claim describe annual matching, hourly supply, location and the role of certificates?
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