By James F. Boyle, Founder & CEO, Sustainability Roundtable Inc.
Fifteen years ago, corporate sustainability leaders faced a similar moment of uncertainty. The first major revision of the Greenhouse Gas Protocol’s (GHGP) Scope 2 guidance ignited heated debate over what could credibly be claimed as “renewable electricity.” The process was long—several years of consultation, testing, and implementation—but it ended with a pragmatic compromise: dual accounting. The world adopted both location-based and market-based approaches, and that balance unlocked an extraordinary decade of corporate climate leadership.
Since then, voluntary corporate procurement has caused more than 200 GW of new clean-energy capacity worldwide—enough to power hundreds of millions of homes. That success did not come from perfect modeling. It came from enterprises choosing the hard right over the easy wrong: entering long-term, forward contracts that made new projects possible.
Today the GHGP and the Science Based Targets initiative (SBTi) are again revisiting these foundations. Their current consultations on Scope 2 accounting and the Corporate Net-Zero Standard Version 2 (CNZS v2) will influence how every enterprise reports progress toward net zero. As before, the work will take years—and as before, those who keep focusing on what truly makes a difference will again lead both practice and policy.
The GHGP Scope 2 consultation, open through December 2025, explores new quality criteria for market-based instruments:
introducing hourly and locational matching of procured energy,
tightening definitions of market boundaries, and
considering legacy provisions and small-buyer exemptions.
At the same time, GHGP has opened a second track—Electricity-Sector Consequential Accounting—to develop methods for measuring the actual system-level impact of electricity procurement: what additional generation and avoided emissions a project causes.
The SBTi, preparing its second CNZS v2 consultation, proposes two statements that appear harmonious but conflict in practice:
Recommendation R15.2: companies should “procure contractual instruments that result in additional renewable-energy production.”
Criterion C15.5: companies may count contributions to zero-carbon electricity in other grids only when in-grid sourcing is “not possible,” and even then only as an “interim” measure.
For most enterprises, those conditions are mutually exclusive. Few have enough load within a single grid to finance new generation locally; most must aggregate demand across markets. If cross-grid procurement were limited to an exception, the very mechanism that built 200 GW of new capacity would be sidelined.
Hourly and locational matching are valuable analytical refinements for companies that can manage them. Hyperscale data-center operators, for instance, have concentrated loads and digital resources that make 24/7 “carbon-free energy” feasible. But for the remaining 95 % of enterprises, such a requirement would be an administrative impossibility and a climate distraction.
That is why Directors of Sustainability should focus their engagement on one simple point: in-grid 24/7 matching must remain a “may,” not a “shall.”
Optionality protects diversity of action. It lets large buyers pursue granular matching where possible, while allowing smaller and mid-sized companies to continue causing new clean-energy generation through aggregated, cross-grid procurement. Turning that “may” into “shall” would not raise ambition—it would remove it from reach.
Crucially, 24/7 in-grid matching is not the more rigorous standard—it is the easier one. It measures where and when electrons are counted, not whether they would have existed without you. The genuinely demanding act—the hard right—is to serve as the proximate cause of new, additional generation capacity. That is what changes the physics of the grid and chemistry of our atmosphere. Hourly matching, by contrast, risks rewarding precision without progress: an easy wrong disguised as rigor.
Much of today’s debate assumes that tighter temporal and locational matching is the “gold standard.” It is not. Rigorous accounting must reflect causation, not co-location. A company that perfectly matches its hourly consumption with renewable output from projects built years ago contributes little new capacity. A company that finances a new project—anywhere—advances decarbonization far more. The true measure of difficulty and virtue is not temporal coincidence but creative causation.
Electricity is a shared medium. Once generated, electrons merge on the grid; none can be traced to a specific consumer. The phrase “we use renewable electricity” therefore describes an accounting convention, not a physical truth. The honest question is different: did your company’s procurement proximately cause the new clean generation capacity that that attribute certificate represents?
A company uses renewable power when it buys and retires certificates from existing projects. That’s a conceit of accepted accounting.
A company causes renewable power when its purchase finances the construction of new capacity. That’s physics meeting accounting to benefit our atmospheric chemistry.
At SR Inc for more than ten years we’ve defined the latter contracts as Purchaser-Caused EACs (PC-EACs)—agreements. They meet three requirements:
Bundled pre-financing: the contract covers the cost of both project development and the resulting energy attributes;
Sufficient term: typically ≥ 10 years, providing bankable revenue certainty;
Sufficient scale: roughly 40 MW or more, achieved individually or through aggregation.
These transactions have driven the voluntary market’s growth. They are transparent, auditable, and replicable. They reconcile accounting with physics and with purpose.
Every major accounting reform must honor the past to sustain the future.
When GHGP introduced market-based accounting in 2015, it recognized existing long-term contracts through a grandfathering clause so companies would not be punished for having led early. A similar Legacy Clause is now under design.
Its intent is straightforward: ensure that current long-term contracts—those signed under existing guidance and still financing operating projects—remain valid for market-based reporting once new criteria arrive. Without such protection, companies that did exactly what standards once encouraged could see their achievements invalidated.
What to do:
Compile a concise Legacy Dossier for each PPA or VPPA: counterparty, commercial-operation date, term, structure, additionality narrative, and grid context.
Share these data points in GHGP’s consultation feedback.
Advocate explicitly that the new standard preserve the integrity of existing contracts for their full term
Doing so protects credibility, maintains market stability, and signals that leadership will always be honored—not retroactively penalized.
Alongside the attributional Scope 2 framework, GHGP is developing a Consequential Accounting methodology to quantify the real-world impact of electricity-sector actions. This track, now forming an Actions & Market Instruments (AMI) Technical Working Group, will define how companies report the emissions they cause to be avoided through new generation.
Consequential accounting asks: What difference did this action make to total system emissions?
It examines additionality (would the project have been built anyway?), emissionality (how much dirtier was the displaced generation?), and induced effects (does the action alter demand or supply elsewhere?).
For Directors of Sustainability, this is where the future lies.
It recognizes purchaser causation explicitly; it bridges corporate reporting with the analytic work of firms such as ReSurety, whose emissionality models trace marginal grid impact hour by hour; and it complements advocacy from CEBA and ACORE, which emphasize market scalability and real decarbonization outcomes.
How to engage:
Contribute to GHGP’s consultation on consequential accounting (open through 2025).
Join sectoral working groups via CEBA or ACORE, organizations that actually understand how accounting and physics interact.
Testify to the fact that as a corporate decision-maker you will be encouraged to choose the “easy wrong over the hard right” of just buying coincidentally 24/7 in-grid matched unbundled EACs from long existing projects instead of causing the new projects we need, if the former is celebrated and the latter, needed path, ignored.
The needed path is the bridge between accounting and truth.
Across two decades, voluntary corporate procurement has built a market once thought impossible. Companies of varying size have aggregated demand, signed virtual power-purchase agreements, and financed projects far beyond their own grids. Together they have caused more than 200 GW of new renewable capacity, with another 275 GW in active pipelines.
Those results are not hypothetical; they are grid-connected. They prove that prioritizing what makes a difference makes a difference.
The next chapter depends on protecting this proven pathway while improving transparency. Standards should clarify—not constrain—the means by which enterprises help build the future. Shrewd sustainability leaders will continue to focus on what is right, transparent, and marketable: contracts that plainly cause new generation and verifiably reduce emissions. Doing so provides the evidence GHGP and SBTi analysts most need.
The record of the past decade proves that voluntary corporate procurement was never charity or compliance theater—it was strategic industrial leadership.
Forward-looking companies deliberately invested in utility-scale clean energy not because it was easy or immediately profitable, but because they saw that catalyzing a new technology set was essential to their long-term competitiveness and to our global ecology’s sustainability.
Those early commitments did three things of global consequence:
They collapsed the cost curve. Corporate offtake provided the bankable demand that enabled wind, solar, and storage technologies to scale. In 2010, utility-scale solar averaged roughly 25 ¢ per kWh; by 2024 it averaged 3 ¢ per kWh or less in major markets. That cost decline was driven not only by policy but by private demand signaling.
They inspired regulatory transformation. The credibility and scale of corporate participation helped unlock political consensus for landmark public programs—the U.S. Inflation Reduction Act, the European Green Deal, and China’s 13th Five-Year Plan emphasis on renewable deployment. Voluntary procurement demonstrated that clean energy was commercially viable; governments then amplified it through policy.
They established a proven model for public-private alignment. Enterprises financed risk, utilities integrated supply, and regulators followed with enabling frameworks. The result is the most rapid energy-technology transition in history.
This achievement is living proof that accounting clarity enables action. Standards that clearly reward causing new generation will multiply this dynamic; standards that confuse use with cause could suffocate it just as the world needs it most.
The companies that took the first risk have already delivered an extraordinary public good. What they—and the planet—need now is standards certainty: a GHGP and SBTi framework that validates and amplifies the practices that worked. With that clarity, voluntary corporate leadership can expand from hundreds of gigawatts to the terawatt-scale deployment the UAE Consensus calls for by 2030.
The UAE Consensus at COP 28 set a singular global target: triple renewable-energy capacity by 2030. From October 2025, that leaves about 62 months.
In the United States, corporate buyers operate across balancing authorities; their cross-grid deals in ERCOT and MISO have delivered the largest carbon-abatement impact per dollar invested.
In the European Union, the Association of Issuing Bodies already enables cross-border Guarantees of Origin; restrictive “in-grid only” logic would contradict EU market design.
In Asia and Latin America, emerging I-REC and TIGR frameworks depend on multinational participation to finance first-wave clean-energy infrastructure.
A credible global standard must therefore remain principle-based, not geography-bound. What counts is the capacity you cause, not the postal code of the substation.
As statistician George E. P. Box observed, “All models are wrong, but some are useful.”
Accounting standards are models: simplifications of wickedly complex energy and carbon systems. Their usefulness depends on whether they direct human intelligence toward what actually helps life flourish.
A model that elevates hourly precision above physical causation may be mathematically elegant but practically harmful. A model that recognizes and rewards causation—while encouraging ever-better temporal and locational data—serves both truth and progress.
The test for GHGP and SBTi is therefore not perfection but usefulness: will these models help humanity triple renewable capacity in time?
Keep causing new capacity. Continue contracting for bundled, long-term renewable projects.
Support “may,” not “shall.” Advocate that in-grid 24/7 matching remain optional and acknowledge that it is less demanding than causing new generation.
Protect your legacy contracts. Prepare documentation and comment publicly for a strong Legacy Clause.
Engage in consequential accounting. Join working groups or provide data linking your projects to measurable system-level impact.
Align your claims with reality. Say “Through long-term contracts, we financed ___ MW of new renewable capacity now delivering ___ MWh annually.”
Educate peers and executives. Explain internally why causation outranks consumption.
The purpose of accounting is not to measure virtue but to enable effective cooperation.
When it aligns with physics and moral clarity, it channels human effort toward the preservation of life. When it mistakes precision for purpose, it risks paralysis.
The GHG Protocol and SBTi revisions are not ends in themselves; they are instruments. Their worth will be judged by whether they accelerate the building of new, zero-carbon generation—the tangible work that sustains economies and communities alike.
Those who continue to do that work now will again shape the standards later, just as they did fifteen years ago. Standards follow leadership. Leadership, today, means causing what the world most needs built—for that is the truly rigorous, truly demanding, and truly human measure of success.
For Directors seeking deeper understanding and collaboration:
Clean Energy Buyers Association (CEBA) – under Miranda Ballentine’s leadership, CEBA has championed pragmatic Scope 2 guidance that keeps voluntary procurement scaling.
American Council on Renewable Energy (ACORE) – convenes investors, utilities, and corporates to align market mechanisms with grid decarbonization.
ReSurety – led by Lee Taylor, provides pioneering emissionality analytics linking projects to avoided emissions.
Michael Leggett – a leading voice for transparency in additionality metrics and buyer education.
Sustainability Roundtable Inc. (SR Inc) – through our Net Zero Consortium for Buyers, we help Member-Clients aggregate demand, structure Purchaser-Caused contracts, and engage constructively with standard setters.
Together, these organizations form a global community of practice proving that voluntary corporate action can scale to the terawatt level the UAE Consensus demands.
The path ahead will be neither short nor simple. Consultations will take years; implementation will take longer. But the physics of climate change will not wait for consensus.
The measure of leadership now is not compliance but causation.
Each Director of Sustainability who helps finance new clean-energy capacity—who aligns accounting with action—adds a tangible light to a world that is, in many ways, already on.
The work is to keep that light growing until it becomes the grid itself.