You can be '100% renewable' and cause zero new renewable capacity

When discussing PPA projects with clients, and green electricity procurement more broadly, one thing kept bothering me: how is it possible that additionality requirements are defined differently from client to client? In my view, additionality is only achieved when your actions add something that would not have happened without them.

Here's a version of that problem almost every corporate buyer using EACs should sit with for a second: under the current global standard, a company can genuinely claim to be 100% solar-powered, including during the hours when the sun isn't up. As long as the certificates add up to the right amount over a year, or even a month, nobody checks whether the actual electricity in your building at 2am came from solar or from the grid running on gas.

This is built into how market-based Scope 2 accounting currently works. The GHG Protocol's Scope 2 Guidance, the standard that governs this, lets companies report emissions based on the contractual instruments they've purchased, Energy Attribute Certificates, rather than the physical electricity flowing into their building at any given moment. One EAC represents one megawatt-hour of renewable generation, somewhere, at some point. It doesn't have to match your consumption hour for hour or even come from anywhere near you. Researchers reviewing the standard have summarized the resulting concerns as threefold: no physical connection between where the buyer sits and where the renewable power was generated, no guarantee the purchase caused any new generation to be built, and a real risk of double-counting the same renewable claim across multiple companies. That's three separate concerns from people who study this closely.

To be precise here, hourly matching and additionality aren't the same problem, even though they get lumped together. A certificate can match your consumption perfectly, hour for hour, and still come from a plant that would have existed with or without your money. Fixing the timing mismatch doesn't answer the harder question: did your purchase cause anything to exist at all?

Regulators have started to notice, and in one case, they've already acted. From 2028, the EU will require the electricity used to produce green hydrogen to come from new, unsubsidized renewable generation, physically deliverable to where it's used, and, from 2030, matched to actual production hour by hour. No annual averaging, no certificate shuffling. It's the strictest additionality requirement enforced anywhere. Currently, this only applies to companies producing green hydrogen. Everyone else buying PPAs or EACs is still operating under the looser rules described above.

But the mainstream Scope 2 guidance that governs everyone else's EACs is already being revised in the same direction: a proposed ‘Deliverability Requirement’ would stop companies claiming renewable power from certificates with no real connection to their own grid, and a proposed ‘Hourly Matching Requirement’ would end the exact night-time solar claim above, since a certificate would have to match the hour renewable power was actually generated, not just the calendar year. Neither is in force yet, but this is the direction of travel.

That development of the green energy procurement is what we work through in our white paper on additionality: what would additionality mean, what the standards require today, where the real grey areas sit for PPA and EAC buyers, and what we think needs to change before ‘renewable’ claims catch up with what regulators are already demanding in at least one corner of the market.