Compliance

Scope 2 and Solar PPAs

Scope 2 is electricity emissions. Buying through a PPA with REGO transfer lets you claim renewable electricity under the market-based method — provided your accounting is rigorous.

What this means

Scope 2 emissions are those from purchased electricity. Buying through a PPA with REGO transfer lets you claim renewable electricity under the market-based method — provided your accounting is rigorous and the REGO is genuinely retired against your consumption.

Actions to take

• Decide between location-based and market-based accounting (most use both).
• For market-based, ensure REGO certificates are explicitly assigned to your PPA contract.
• Audit REGO retirement annually via Ofgem registry.
• Disclose dual-reporting in environmental disclosures.

The two ways to count Scope 2

Scope 2 covers the emissions created when someone else generates the electricity you consume. Under the GHG Protocol it is reported two ways, and the gap between them is the whole game. The location-based method applies the average carbon intensity of the grid you sit on, whatever you actually buy — it is effectively fixed by geography. The market-based method reflects the electricity you have specifically contracted, and that is where a renewable PPA changes the number. Most rigorous reporters now publish both figures alongside each other, because each answers a different question.

How a PPA earns the market-based claim

Renewable power is only genuinely renewable on paper when the certificate proving it is tied to you. In Great Britain that certificate is the REGO — Renewable Energy Guarantees of Origin — issued per megawatt-hour of renewable output. A solar PPA lets you report a zero-carbon market-based figure for the electricity it supplies, but only where the REGOs are explicitly assigned to your contract and genuinely retired against your consumption rather than sold on elsewhere. Metered generation plus retired REGOs is what turns a supply arrangement into a defensible reduction.

Keeping the accounting honest

Auditors and regulators have grown wary of double-counted certificates, so the discipline around the claim matters as much as the contract itself.

• Report both location-based and market-based Scope 2 — don't quietly drop the higher one.
• Confirm the REGOs are named against your PPA, not pooled or resold.
• Verify retirement each year through the Ofgem REGO registry.
• Disclose the dual reporting transparently in your environmental statements.

Getting the contract right at the source

Whether the REGO transfer is included, and on what terms, varies between funders — so it belongs in the conversation before you sign, not after. See how a PPA delivers both power and certificates, weigh it against other routes to renewable supply across the comparison pages, and shortlist providers willing to put the REGO assignment in writing. An on-site array keeps the chain short: generation, meter and claim all sit on the same site.

FAQs

Scope 2 and Solar PPAs FAQs

Can a solar PPA on its own deliver compliance?

Not on its own — but it's typically the highest-impact single lever, especially for MEES and Scope 2. Combine PPA with LED + insulation + heat-pump for full compliance pathways.

How long before compliance deadline should I sign a PPA?

12-18 months minimum. PPA contracts take 6-12 months to sign and build. Add 3-6 months for measurement and verification before the deadline assessment.

Do PPAs always include REGO transfer?

Most do — but it must be explicit in the contract. Some standardised retail-PPA structures don't transfer REGOs by default; specifically negotiate this if you need the green claim.