Making Renewable Electricity Claims with Confidence: Understanding REGOs/EACs

Stricter Rules for Renewable Claims

Companies worldwide increasingly rely on Energy Attribute Certificates (EACs)—known as REGOs in the UK and Guarantees of Origin (GOs) in Europe—to claim renewable electricity usage under Scope 2 emissions accounting, even when their actual grid power mixes fossil fuels. These certificates track the environmental attributes of one megawatt-hour of renewable generation, allowing organizations to subtract emissions via market-based methods in frameworks like the GHG Protocol.

Recent developments have challenged this approach. In March 2025, RE100 updated its technical guidance with stricter EAC sourcing rules, requiring credible retirement on registries and cancellation in markets where EACs are common. By October 2025, the GHG Protocol formalized mandatory hourly matching and narrower deliverability boundaries for EACs to count toward reductions, moving away from annual averaging that has long dominated corporate reporting. Proposed revisions could reduce the emissions impact of unbundled EACs by half in some cases.

In Europe, the Green Claims Directive, set for enforcement in September 2026, targets greenwashing by requiring verifiable and comparable environmental statements, while the Corporate Sustainability Reporting Directive demands detailed disclosures. The UK's REGO market has seen dramatic price drops in 2025 from oversupply, reduced demand amid preferences for direct power purchase agreements, and improved renewable capacity growth, yet this volatility underscores risks if future rules favor granular, time-matched certificates over traditional annual ones.

Tensions arise between cost-effective annual matching and emerging demands for hourly or shaped matching, which better reflect actual grid decarbonization but raise expenses and complexity, especially for firms with global operations. Stakeholders debate whether these shifts drive genuine renewable investment or merely complicate compliance without proportional environmental gains.