As the Greenhouse Gas Protocol reviews feedback on proposed amendments to its flagship Scope 2 emissions guidance, the Business Renewables Centre-Canada is warning that abrupt implementation in Canada, where corporate procurement of renewable energy already struggles against infrastructure and regulatory gaps, could stall the very momentum the amendments are meant to accelerate.

The GHG Protocol, a set of comprehensive global standards for measuring and managing greenhouse gases (GHGs), was first released in 2001 and has been updated regularly since. A joint project of the World Resources Institute and the World Business Council for Sustainable Development, its standards are by far the most widely used globally.

The Business Renewables Centre (BRC-Canada) is particularly concerned about new amendments that would tighten the rules around how companies can claim renewable energy purchases to achieve their reduction goals for Scope 2 emissions, those generated by electricity they purchase from the grid.

The GHG Protocol opened these and other proposed amendments to public consultation in the last two months of 2025. BRC-Canada, a non-profit initiative of the Pembina Institute that supports corporate renewable energy procurement of renewable energy, was one of more than 800 stakeholders to submit an opinion. It lays out its concerns in a recent report titled Momentum at Risk.

“Unfortunately, the potential changes and importance of the GHG Protocol aren’t widely understood, and we wanted to bring the message to a wider audience,” BRC-Canada Director Jorden Dye told The Energy Mix. “We do hope that the message is received by governments and corporations.”

Under current guidance, companies can purchase Renewable Energy Certificates (RECs), each of which represents one megawatt-hour (MWh) of renewable energy generated anywhere within typically vast geographic regions (for example, a company operating in northern B.C. can currently procure RECs from a solar producer in New Mexico). Then the buyer can apply that MWh to any part of its electricity use, renewable or not, at any time during the year.

In theory, and in practice, such flexibility allows companies to match one MWh of clean electricity procured from far away with one MWh of dirtier electricity actually consumed via the local grid, a calculation which can then lead to an overestimate of the Scope 2 emissions the company avoids.

Under the proposed revisions to the GHG Protocol’s Scope 2 guidance, companies seeking to procure renewable electricity will be required to match the incoming megawatt-hours with their actual electricity consumption hour by hour and source their RECs from the specific electricity market within which they operate.

The Grid-Greening Power of a PPA

While companies can purchase so-called “unbundled” RECs which “allow companies to claim renewable electricity attributes without directly supporting the addition of new renewable generation or driving long-term investment in clean energy,” explains BRC-Canada, corporations around the world—courtesy of the GHG Protocol’s standardized guidelines for Scope 2 emissions—are  increasingly buying their RECs via Power Purchase Agreements (PPA), thereby linking their emissions reduction goals to the actual greening of the grid.

BRC-Canada provides an overview of the growing synergy between new renewable energy capacity and corporate PPAs.

• In 2024, Europe added roughly 70 GW of new renewable capacity, alongside 12.9 GW of PPAs.

• In 2022, corporate PPAs accounted for roughly 70% of new renewable capacity, with cumulative contracted capacity reaching a record 100 GW two years later.

• In Canada, 63% of the deals in BRC-Canada’s Deal Tracker have come from corporate demand.

PPAs in Canada Could Double in Price

In mature markets like Europe and the United States, the greater accuracy of hourly (also known as 24/7) and geographic matching “could affirm progress towards deep decarbonization,” BRC-Canada writes. But in jurisdictions like Canada, where corporate procurement of renewables remains low, such stringency could cause companies located here to beat a retreat back into unbundled RECs.

Looming large as an impetus behind that retrenchment is that full compliance with the protocol’s Scope 2 amendments could double the price of a PPA, BRC-Canada’s analysis concludes.

To arrive at that calculation, BRC-Canada began with a representative (theoretical) facility that meets its annual—as opposed to hourly—electricity demand with a 100-MW solar PPA. It then added a 50-MW wind PPA to address nighttime demand, 5 MW of demand response, and the additional energy storage necessary to reach 100% hourly matching. Then it calculated the cost of the hybrid PPA.

Then the non-profit repeated its  analysis across 19 industries in Alberta, the province whose (deregulated market hosts the lion’s share of corporate PPAs in Canada, explicitly excluding mid- and downstream oil and gas.

Using current data, BRC-Canada found that “moving from annual matching to 100% hourly matching raises PPA costs by a range of 98% to 139% across the 19 industrial sectors in Alberta.”

The analysis also showed the cost increases in cost that go along with incremental efforts to secure hourly matching: adding wind raised the cost of a PPA by 40%, while storage and demand management options, which improved hourly coverage up to 90%, boosted PPA costs by over 73%.

Dye explained that excluding oil and gas from the calculation was a matter of response time. “Given the tight timeline on the submission to the GHG Protocol, we were unable to procure industry load profiles for oil and gas,” he told The Mix.

But “we wanted to prominently highlight this exclusion as it is a key gap in the Alberta context,” he added. “As BRC continues to explore 24/7 matching and the further integration of renewables and energy storage, we plan to build stronger industry profiles.”

Data Gaps, Regulatory Barriers

The GHG Protocol’s revised guidance on Scope 2 emissions is expected to be published in late 2027, following a second round of public consultation scheduled for later this year. Alongside requirements for hourly and geographic matching will come another for much more rigorous data collection and verification.

In places like Canada, where digital and physical infrastructure are not yet in place to enable and underwrite it, that added layer of precision “could undermine the integrity of the GHG accounting system itself,” BRC-Canada warns.

The Momentum at Risk report includes the results of BRC’s engagement with the renewable energy buyers and developers it currently works it. They said access to hourly energy consumption data “remains a major challenge” for public and private entities alike, regardless of size.

Access to such data is often limited “because utilities or third-party providers control it,” the report explains. “Of Canada’s 12 regional electricity system operators (10 provinces and two territories), only six have hourly generation data available for wind and solar products.”

The absence of a consistent data standard—because oversight is regional—compounds the problem.

Meanwhile, on the demand side of the equation, not all corporate buyers possess the smart meters necessary to log hourly electricity consumption. For multinational organizations, that means the challenges are “amplified by uneven data availability across regions, forcing reliance on proxy data,” says BRC-Canada.

“Both limitations reduce the credibility of hourly matching,” the organization adds. “Without accessible and auditable data, corporate reporting would become a weaker reflection of realities on the ground.”

Market Structures and Regulatory Frameworks

Finally, market structures and regulatory frameworks may not yet support corporate procurement. In Canada, renewable energy buyers currently rely almost exclusively on PPAs in Alberta to address Scope 2 emissions.

As of last year, “the top 100 Canadian corporations would require 7.7 GW of renewable energy capacity to meet their Scope 2 targets, out of which only 19% of that demand comes from corporations with operations in Alberta,” says BRC-Canada.

That means the geographic matching requirement, which will tighten the deliverable boundary for contracted virtual PPAs from national boundaries to provincial or territorial ones, “could suppress PPA activity in Canada and, in turn, renewable development,” BRC-Canada writes.

“Reduced corporate procurement activity could further weaken incentives for governments in other jurisdictions that may have been considering opening their electricity markets to corporate procurement,” it adds.

BRC-Canada’s Recommendations

While BRC-Canada “supports the ambition” of the GHG Protocol’s amendments to its Scope 2 guidance, recognizing that “in an ideal scenario, the proposed changes could deliver both impact and increased accuracy,” it is concerned that too-rapid implementation “risks producing the opposite outcome.” To mitigate the risk, the report says the GHG Protocol must preserve legacy contracts, phase in hourly matching, and apply its geographic matching criterion with care.

While the GHG Protocol has indicated that legacy contracts will be honoured, BRC-Canada is concerned that the details “are not fully fleshed out,” Dye told the Mix. “On legacy contracts, BRC-Canada’s position is that all existing PPAs need to be grandfathered into any updates to the protocol, regardless of buyer type.” That’s because PPAs “are multi-decade agreements that require significant upfront investment, and retroactively changing the terms on which these deals were built for any category of buyer sends a signal to the market that long-term contracts aren’t reliable.

“That has ramifications well beyond the companies directly affected.”

On hourly-matching, BRC-Canada supports the Science-Based Target Initiative’s recommended phase-in schedule that would see such matching “reaching 50, 75 and 90% by 2030, 2035 and 2040, respectively.”

The non-profit is asking that the geographic matching amendment be applied with attention to what a particular country can actually deliver on. For Canada, that would mean continuing to define the deliverable market boundary at the national level.

Dye said a 2025 report by BRC-C, Powering Corporate Choice, lays out policy changes that Canada could introduce to accelerate corporate PPAs for renewables. “By increasing jurisdictional access, the potential impacts of geographic matching would be minimized,” he told the Mix.