Executive Summary 

The Greenhouse Gas Protocol (GHGP) is undergoing a significant revision to its Scope 2 accounting guidance, introducing two major changes: mandatory hourly matching of Energy Attribute Certificates (EACs) and stricter deliverability requirements.  
 
To better understand how the market is responding to these proposed changes, GO2 Markets ran a survey across its network to capture sentiment ahead of the last public consultation planned for mid 2027. 
 
The final version is expected to be published in the second half of 2028. 

This white paper synthesizes the findings from respondents across a range of stakeholder types, including corporate electricity consumers, utilities, and renewable energy producers. 
 
The data paints a complex and cautionary picture. Despite pockets of support for specific elements of the proposal, respondents broadly questioned whether the changes would achieve their objective of strengthening the integrity of Scope 2 accounting without compromising the progress and real-world impact the guidance is meant to drive. Concerns about operational complexity, cost burdens, and systemic readiness gaps were pervasive, signalling that significant questions must be addressed before industry confidence can be secured. 

Background and Policy Context 

The GHGP Scope 2 guidance provides the global framework for how organizations account for their indirect greenhouse gas emissions from purchased electricity, steam and heat. The current revision process is driven by a desire to improve the environmental integrity of EAC-based claims, ensuring that renewable energy certificates more accurately match the period and location of the generation with those of the consumption. 

Key Proposed Changes 

Two primary changes are under consideration by the GHGP. 

Hourly Matching: EACs would need to be matched to the same hour electricity is generated and consumed, rather than on an annual basis. This would apply to entities above a threshold that is yet to be defined. Smaller participants may continue using annual data, and approved hourly profiles could be used where metered data is unavailable.  

For example, evening electricity use could no longer be covered by solar EACs generated during the daytime, even if they are from the same year. 

Deliverability Requirements: EACs could only be used if the renewable electricity could realistically reach the consumer in that hour. In practice, this means certificates would need to originate within the same bidding zone as the consumer. As these bidding zones generally mirror national boundaries (sometimes broken into smaller sub-national zones), this effectively introduces a country-level constraint on certificate use.  

Cross-border certificates from neighboring zones may only be used where “deliverability” to the consumer can be demonstrated according to the methodology outlined in the standard. 

For example, EACs from another zone could only be used when there is a price convergence between zones or when the buyer holds explicit transmission rights. 

Update Timeline 

• Initial Public Consultation: Formally closed on 19 December 2025 

• Second draft development: During 2026 

• Final Public Consultation: Will follow in mid 2027 

• Final Publication: Expected by late 2028 

• Implementation: Kicking off in 2028, beginning with a to-be-defined transition period 

Survey Methodology and Respondent Profile 

The questionnaire was distributed to GO2 Markets clients and relevant industry contacts during the initial public consultation period.  

The respondent base is representative of the core market segments GO2 Markets serves. More than 60% of respondents handle electricity volumes in excess of 200 GWh per year. More than 80% work primarily with Guarantees of Origin (GOs). Respondents span three key stakeholder groups: Corporate electricity consumers, utilities, and renewable energy producers. 

Key Findings 

1. A Market Unconvinced 

Sentiment toward the proposed Scope 2 revisions is predominantly negative. Approximately 50% of all respondents oppose the changes, around 30% remain unsure, and only 20% express support. This distribution reflects significant uncertainty and concern within the market, even among those not yet firmly opposed. 

2. Hourly Matching: Technically Feasible but Broadly Opposed 

Hourly matching is the most divisive of the two proposed changes. Around 60% of respondents oppose the requirement, with opposition primarily rooted in anticipated administrative burden and increased procurement and operational costs. 

A critical readiness gap is evident: 88% of respondents report they are not yet prepared to handle granular, hourly energy data. This points to a substantial infrastructure and systems challenge that would need to be addressed ahead of any implementation. 

However, there is a notable silver lining: 75% of respondents view hourly load profiles as a feasible interim solution. This finding suggests that approved hourly profiles, a compromise already proposed within the draft guidance, could serve as a practical bridge. This could ease the transition while full metering infrastructure is developed. 

3. Deliverability Requirements: Seen as Restrictive and Disruptive 

The proposed deliverability rules attract similarly high levels of opposition. 56% of respondents oppose the requirement, and 63% report they are currently unprepared for certificate trading on a bidding-zone basis. 

The impact on market access is a key concern: 62% of respondents expect the proposed deliverability boundaries to reduce their procurement or sales options. This suggests the rules could significantly curtail the flexibility currently available in cross-border EAC markets, with knock-on effects for liquidity and pricing. 

4. Net Zero Implications: Changes Seen as an Obstacle, Not an Enabler 

Among respondents who have established net zero or renewable energy targets, the findings are striking. 90% indicate that the proposed changes would either prevent them from progressing their targets or have no meaningful effect on advancing them. Only 10% believe the changes would actively facilitate further action toward net zero goals. 

This is a counterintuitive outcome given that the stated rationale for the revisions is to improve environmental integrity. It suggests the proposed framework, in its current form, risks creating compliance complexity without proportionate environmental benefit for many participants. 
 

Stakeholder-Specific Perspectives 

1. Corporate Electricity Consumers 

Corporate electricity consumers anticipate higher clean energy procurement costs as hourly matching requirements make flexible, cost-efficient sourcing more difficult. They expect a structural shift toward long-term Power Purchase Agreements (PPAs) or more tightly structured supply arrangements. They also require practical support mechanisms, including access to hourly load profiles and standardized hourly tracking infrastructure, to navigate the transition. 

2. Utilities 

Utilities face significant operational challenges from both hourly matching and deliverability requirements, citing increased complexity and potential supply-demand mismatches. They anticipate reduced market liquidity for hourly certificates, which could undermine the commercial viability of certain product offerings. Utilities represent the segment with the broadest and most consistent opposition to the proposed changes. 

3. Renewable Energy Producers 

Renewable energy producers expect mixed impacts on monetization, with cross-border sales restrictions under deliverability rules creating revenue risk, offset partially by potential value upside from hourly pricing signals. They view the deliverability requirements as a barrier to market access, particularly given limited options for cross-border certificate sales and the increased transactional complexity involved. Regions where renewable energy supply significantly exceeds local demand, such as Norway, stand to be disproportionately affected as restricting certificate sales to domestic buyers alone would substantially limit their market access and cut a critical revenue stream. 

Conclusion 

The proposed revisions to the GHGP Scope 2 guidance represent the most significant overhaul of renewable energy accounting standards in recent years. The market's response, as captured through this questionnaire, is one of uncertainty, concern, and in many cases, active opposition. Readiness gaps are widespread, cost implications are front of mind, and the potential for the changes to hinder rather than help net zero progress is a recurring theme.  

At the same time, the findings highlight some areas of pragmatic consensus: Hourly load profiles are seen as workable, and many stakeholders acknowledge the underlying intent of the reforms. The challenge for the GHGP and market participants like GO2 Markets is to channel that pragmatism into constructive engagement with the consultation process and into practical preparation for eventual implementation. 

GO2 Markets is well positioned to lead that conversation, bringing together deep market expertise and the direct industry insights gathered through this questionnaire. We remain committed to keeping our clients informed as this landscape evolves, and to serving as the reliable, proactive partner they need to navigate the road ahead with confidence.