Your "100% Renewable" Claim Is About to Get Audited by the Clock
Most corporate renewable energy claims rest on a yearly calculation that the GHG Protocol's Scope 2 Guidance has allowed since 2015. A company totals annual electricity use, buys an equal number of megawatt-hours of renewable energy certificates, and reports zero emissions from purchased power. Certificates from a high-solar June afternoon can therefore cancel out fossil fuel heavy power drawn at 9pm in January.
A 2022 Nature Climate Change study led by Anders Bjørn projected that if REC-driven trends continued, 42% of the Scope 2 reductions companies had committed to would not represent real-world mitigation.
The GHG Protocol is now weighing its largest revision to Scope 2. Its market-based method draft would require every certificate to be issued and redeemed "for the same hour" as the electricity it covers. It would also require that the renewable certificate generator is on a grid that can physically deliver power to the buyer. The draft adds two exceptions. A company consuming less than a threshold volume in a market could keep matching monthly or annually, with proposed thresholds of 5, 10, and 50 GWh per year. A company without hourly meter data could estimate consumption from a load profile. The Independent Standards Board voted 10-1 in July 2025 to publish the draft, and the consultation drew nearly 1,100 responses from 56 countries.
Large buyers disagree on whether the hour is the right unit. Google committed in 2020 to run on carbon-free energy "everywhere, at all times" by 2030, a target announced by Sundar Pichai. Microsoft set a comparable 2030 goal of matching 100% of its consumption 100% of the time with zero-carbon purchases. Meta took the opposing position and helped found the Emissions First Partnership in 2022, which argues that what a clean megawatt-hour displaces matters more than when it arrives, because displacing coal cuts more emissions than displacing hydro. Its July 2025 letter warns that hourly matching can raise real-world emissions while still letting a company report a reduction.
That objection does not rescue the current rule, because the partnership is not defending annual matching either. It wants measured grid impact to replace the yearly calculation, while the hourly camp wants time and location. Both sides treat today's claim as too easy. In response, the GHG Protocol said it is exploring multiple reporting approaches, and targets the end of 2027 for the revised standard.
In anticipation of this change, corporations should be capturing hourly consumption data, mapping each contract to the grid region that serves the load being covered, and test whether a "100%" claim survives a matching window of an hour rather than a year.
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