Following the release of the Greenhouse Gas Protocol’s 1,072 responses to its consultation on Scope 2 electricity emissions, EnergyTag ran a webinar looking at the results. We outlined key trends, explored what organizations did and didn’t say and outlined the future timeline. 

We also received a lot of questions. We’ve grouped and selected the ones most relevant to the Scope 2 update process and given some high-level answers below. You can watch the full webinar here. 

1. The Case for Hourly Matching

Does market-based matching make sense long term? Yes. Location-based reporting is a useful snapshot into the carbon intensity of the grids organizations operate on (but have limited macro-level control over), but the dual reporting of market-based as well gives them an actual avenue to pursue credible interventions. Proposed GHGP updates strengthen the integrity and impact of both methods’ reporting and actions taken. Hourly matching ties claims to real generation and consumption patterns, not annual averages. This is the only method that reflects grid reality, especially as more renewables and storage come online.

Are there any good, sound arguments in the opposition to hourly matching? Some feasibility concerns are legitimate and the GHGP has stepped processes in place to address these. On hourly matching specifically, it’s worth stressing that load & production profile fallbacks ensure an immediately-feasible backstop option for converting monthly/annual data into hourly where hourly data is not already available. 

Is the shift to hourly matching likely to slow down? We don’t expect a slowdown – quite the opposite. There are many reasons beyond GHGP for companies to transition to hourly accounting and matching: it can help hedge against price spikes and optimizes energy use, as well as adding transparency to their claims – increasingly necessary for stakeholders subject to new regulations like CBAM. Even before GHGP has definitively moved to hourly accounting, hourly products like supplier tariffs and registry upgrades are rapidly accelerating YoY. As for the response to the GHGP survey, the GHGP will incorporate feedback – crucially, evaluated based on evidence quality, not raw response count – and we would expect hourly accounting to be phased in over multiple years, as directionally indicated in the proposal.

How will 24/7 matching be taken up by customers? Will certain segments go first?  A diverse and credible coalition of organizations across various sectors and sizes is already implementing hourly accounting and matching. While the general rollout has famously been spearheaded by major leaders such as Google and Unilever— members of the 24/7 Carbon-Free Energy Coalition—there are thousands of entities already plugged into hourly matching, especially in regions where supplier products make this trivial. Regulated first movers are also quickly following. This includes heavy industries and green hydrogen sectors that require hourly matching to secure EU subsidies and avoid CBAM penalties. Nevertheless, organizational size is not a primary barrier, as early adopters already range from a local US bagel shop to a Scottish whisky distillery. Further examples of where it is happening already can be found here.

Do hourly matching and grid decarbonization go hand in hand? Trade-offs vs. cost. Yes. Annual matching lets clean power generated at noon offset dirty power used at night, so it is a crude and outdated measurement for decarbonization. The International Energy Agency and others find 80%+ hourly matching is already cost-competitive with annual matching, with only the final push toward 100% carrying a real premium. Since GHGP is a standards body, no level of procurement is mandated on anyone, so entities can scale their spend to their ambition level. As for pure operational cost impacts of higher-fidelity accounting, Watershed has estimated these to be marginal. Hourly-matched contracts also act as a better hedge: they lock in clean supply against the specific hours buyers actually consume power, reducing exposure to wholesale price volatility.

2. Corporate Opposition — Substance and Credibility

What’s the biggest, most credible corporate pushback on hourly matching, and how do we help address it?

 Some feasibility concerns are legitimate and the GHGP has stepped processes in place to address these. On hourly matching specifically, it’s worth stressing that load & production profile fallbacks ensure an immediately-feasible backstop option for converting monthly/annual data into hourly where hourly data is not already available.The GHGP has also proposed including a load-based exemption so companies below that threshold can keep using annual accounting. A primary method to address pushback is widespread stakeholder education on these feasibility measures, the rapidly expanding availability of hourly products, and how to enact whatever reforms GHGP ultimately lands on – correctly framing the update as a necessary upgrade, not some impossible revamp. Hourly accounting is already being done today by companies ranging from bagel shops to Google’s global operations. 

Was there geographic or company-size bias among opponents of hourly matching? There was a high geographic concentration of responses overall, with ~70% of responses from Europe and North America, 17% from East Asia, and the remaining ~13% from everywhere else. For hourly matching support level – going purely on numbers, which, as we stress, this is not a voting exercise – European and South Asian respondents were twice as likely to support hourly matching, while the highest opposition came from North America and East Asia. You can find the breakdown from GHGP here. Company size bias analysis would take a deeper dive into the raw data since GHGP did not explicitly ask an organization size question in the demographics info. 

There’s more corporate support for deliverability than hourly matching. Should that be the first focus? GHGP is evaluating a holistic update to its criteria, and research has consistently shown that higher-integrity criteria for time- and location-matching (in addition to incrementality) drives appreciable impact, namely all together (“three pillars”), whereas lax accounting does not (annual, continent-scale, no incrementality considerations). The GHGP will take into consideration the different perspectives provided on each criteria, but it is worth noting that the decision-making hierarchy of integrity > impact > feasibility is the metric here, an evaluation of the evidence and not raw respondent count. EnergyTag and others support a transition to 3-pillars accounting criteria. Candidly, the profile feasibility measures arguably make the hourly accounting pillar much less stringent than the more directly restrictive deliverability definitions, but all in all we view the evidence as clear that we must progress on both. 

Besides hourly matching, what are the biggest limitations to effective GHG accounting? Rigor and adoption are the two primary factors for the effectiveness of reporting. Rigor: Hourly matching, especially when coupled with deliverability and newness criteria (SSS or full incrementality pillar), have been repeatedly shown in the research to improve impact and decision-usefulness. Adoption: assuming sufficiently rigorous quality criteria, the other lever is adoption and ambition levels. These can be driven by both voluntary uptake as well as increasingly regulatory-bound adoption, such as via CBAM requirements and various reporting regimes worldwide. Standardization also can help adoption, which of course is the GHGP’s intention with its broad refresh of its standards alongside harmonization with ISO for a unified framework. Finally, adoption can also be influenced by stakeholder education around reporting and the solutions available to them. 

3. Roadmap, Next Steps, and Timeline

What are the next steps / GHGP’s expected position / EnergyTag’s plan? The Technical Working Group and Secretariat will reconvene to revise the standard, guided by the principles established through this consultation process. The revised standard then goes to the Independent Standards Board for a vote. The publication timeline has been extended to 2028, from the previously targeted 2027, in part to allow harmonization with ISO standards. The new timeline from GHGP can be found here.

EnergyTag will continue to analyse the responses to the consultation in the short term, but moving forward we will continue to advocate for our position on hourly matching and other critical reforms and work closely with the TWG to advise on this take. 

We won’t speculate on GHGP’s final position, though we’ll note that both the TWG and the ISB have previously shown support for hourly matching based on the evidentiary need for reform. The consultation was a call for input, not a voting exercise, and we would contend that the evidence presented points towards higher-integrity reforms going through with sensible transition/phase-in mechanisms (and targeted flexibility measures) to address feasibility concerns while still preserving needed updates. 

Where are we in the journey to hourly matching? Further along than most realize. EnergyTag’s About Time dashboard tracks real-world case studies globally that show hourly tracking is already feasible and scaling quickly, alongside more than 60 active suppliers worldwide offering hourly-matched clean energy products. On the infrastructure side, five registries — CleanCounts, Evident, Grexel Systems, Unicorn Systems, and Xpansiv — are already modernizing to hourly issuance, and ERCOT recently joined PJM and CleanCounts in issuing hourly certificates in the US. The tracker also shows growing momentum on the demand side, with corporate buyers increasingly combining wind, solar, and battery storage in single hybrid power purchase agreements to hit hourly targets. The market has already started proving this out; GHGP’s standard is catching up to it. 

What’s the trend of temporal accounting after the first Scope 2 consultation? 

The consultation results show a clear directional trend: civil society, technical experts, and named corporates supported hourly matching at roughly 4 times the rate of corporate opposition. Worth noting: over half of all responses were anonymous, and the anonymous slice skewed more opposed than named respondents, which is itself part of the pattern worth watching as GHGP weighs the feedback.

Beyond the consultation itself, the trend is already visible in the market. EnergyTag’s About Time tracker shows five registries actively upgrading to hourly issuance, over 60 suppliers now offering hourly-matched products, and growing momentum in hybrid power purchase agreements combining wind, solar, and storage. Regulatory momentum is moving the same direction: the US 45V Clean Hydrogen Standard, the EU Hydrogen Standard, and CBAM-related rules have all incorporated hourly matching principles already. 

What’s most likely to be dropped or reduced to appease stakeholders? We won’t speculate on GHGP’s final position, though we’ll note that both the TWG and the ISB have previously shown support for hourly matching based on the evidentiary need for reform. The consultation was a call for input, not a voting exercise, and we would contend that the evidence presented points towards higher-integrity reforms going through with sensible transition/phase-in mechanisms (and targeted flexibility measures) to address feasibility concerns while still preserving needed updates. 

4. Implementation and Feasibility for Companies

How should companies prepare to implement hourly matching? To start, consider getting a simple estimate of your hourly clean energy score via free online calculators such as this one or this one. Take stock of how you keep track of your electricity demand (utility bills, meter data) and any supply arrangements you have (green tariffs, PPAs), note what level of data granularity you have for each, and consider what hourly supply options may already be available to you. Additional explainers on getting started and hourly matching’s feasibility can be useful resources. Companies who start early with granular accounting and matching gain deeper operational insight and energy security, adapt fastest as hourly matching becomes standard in voluntary programs and regulations, and demonstrate leadership in sustainability.

How well do temporal and spatial matching requirements line up with existing technology? Electricity grids already operate on sub-hourly intervals today and hourly meter data underpins electricity billing for most large consumers, with advanced metering widely deployed across the US, Japan, the UK, and Europe. Where hourly data isn’t available, GHGP’s load profile hierarchy lets companies convert existing monthly or annual data into hourly estimates, down to a simple flat average as a last resort, which still beats today’s annual matching on accuracy. The GHGP proposal offers similar feasibility options for generation — use whatever generation data is available and apply that to a standard generation profile for that type of resource and a far more accurate accounting is possible. Spatial matching is eminently feasible with existing technology because it only requires the power generator and the consumer to disclose their rough location.

How does this affect BESS business cases for 8-12 hour durations needing 11-17 hours to charge? 

In general, these changes will provide greater value for BESS. Without evolving to more temporally accurate emissions accounting, the value of time-shifting clean energy from when it is produced to when power is still needed and renewables are no longer producing is not clear. Hourly accounting creates a system in which stored clean energy that can be discharged at times of low renewable generation (like overnight) becomes valued for its real contribution to the system. Longer duration energy storage can be even more valuable by offering solutions to fill in potential longer gaps of low renewable output (like a Dunkelflaute). As the LDES Council said in their public comments: “The hourly matching proposals in this consultation would drive increased deployment of LDES. Buyers with voluntary or mandated emissions targets – large corporates and energy suppliers – would have greater incentive to procure clean power from LDES during periods when there is no output from solar or wind.”

5. Certificates, PPAs, and Market Instruments

Use of market instruments, what’s new?

The use of market instruments in and of itself is not new. What is proposed as new is that when using a market instrument, like an Energy Attribute Certificate (EAC), to make a Scope 2 emissions claim, companies over a certain size would have to ensure that EAC represents generation in the same hour located in the same grid zone as the consumption to which they are matching.

Are GECs and PPAs recognized for zero-carbon claims? Progress on hourly PPA requirements? 

Yes, bundled energy and attribute contracts will be recognized for zero-carbon claims. However, under the GHGP proposal, only energy attributes that align hourly with the consumption of the buyer can be used for zero-carbon claims. This is likely to accelerate the ongoing shift towards more hourly-aligned PPAs, in which a buyer may pursue a hybridized generation portfolio of wind, solar, battery storage, or other clean technologies.

Will there be an open marketplace for Energy Attribute Certificates in the US? How will it be deployed? 

There is already an open marketplace for existing EACs in the US, and efforts are underway to create an open marketplace for hourly EACs. LevelTen, alongside AES, Constellation, Google, Microsoft, and the Intercontinental Exchange (ICE), has created the Granular Certificate Trading Alliance where they are piloting hourly certificate transactions in PJM today. Additionally, ERCOT in Texas recently announced that they would be launching an hourly certificate program to support innovative transactions, more retail products, and greater market transparency. As existing wholesale markets and registries adopt hourly certificate issuance, it should be expected that the open marketplace for non-granular EACs today will evolve into one in which hourly EACs are also transacted.

6. Sector, Technology, and Policy Interactions

How will this affect green energy alternatives like VPPAs? 

VPPAs can and likely will continue to play a role in corporate clean energy procurement. While not all VPPAs will be well aligned with proposed hourly and locational matching rules, many will. For companies not required to do hourly accounting, VPPAs may continue to play a large role in their procurement strategies. For companies that are required to do hourly accounting, VPPAs may be one part of their strategy. The geographic matching requirements are likely to have a larger impact on whether a company continues to pursue VPPAs, but under the GHGP’s proposed consequential emissions framework these contracts will still be able to make certain claims about their impacts on the grid system wherever they operate.

Any movement on “Avoided Emissions”? Energy-saving devices like high-efficiency CHP are often penalized.

Avoided emissions estimates and their use in reporting are being addressed by the Actions and Market Instruments working group under the GHGP update process. These are parallel processes and are now on track to finish on the same timeline. More information on the public consultation feedback can be found here and the updated standard development plan here.

Net impact of new Scope 2, the EU Carbon Border Adjustment Mechanism, and the UK-Belgium London Protocol agreement, all at once? 

The multiple policy, regulatory, and voluntary standard updates that have already adopted or are considering adoption of hourly and locational clean electricity accounting indicate a clear direction for the future of clean electricity procurement and requirements. When multiple, independent processes all land on the same answer — that hourly and locational accounting are a more accurate and impactful way to do electricity accounting — it is an indication that the status quo is not acceptable and evolution is needed. 

How will this shape the US voluntary and compliance Renewable Energy Certificate market for 2026/2027? 

This is unlikely to shape the US voluntary and compliance REC markets this year and next year. The updated Standard Development Plan from GHGP now predicts the final standard will not be issued until late in 2028. The market may continue to adjust based on voluntary demand for hourly clean electricity matching, state policies regarding data center electricity usage, or other policy and market influences. 

7. Global Equity and Regional Fairness

How is GHGP thinking about fairness between data-rich and emerging markets?

Proposed exemptions for smaller energy users and the ability to use profiled and flat average data for generation and electricity consumption should make compliance more feasible for companies of all types in all markets. The flexibility and feasibility measures proposed, combined with time for markets to develop to adapt to new rules (the standard won’t be finalized until late 2028 and then there may be a phase in after that point) should support global implementability.

8. General Q’s / Getting Involved

Does GHGP know who submitted anonymously? Is that kept anonymous from working groups too? Yes, the GHGP Secretariat knows who submitted anonymously as they compiled and summarized the survey responses; however, this won’t be shared with working groups.

How do we get more diverse corporates interested in GHGP granularity language? Lead with named, credible voices already on record — Google, Iron Mountain, Engie, Fervo, Constellation Energy, and others. That gives other corporates social proof to engage without feeling like first movers.