Compliance

TCFD and Solar PPAs

TCFD-aligned disclosure has been mandatory for LSE-listed and large private UK companies since 2022. A solar PPA is a Scope 2 emissions reduction lever with audited delivery.

Last reviewed 13 May 2026 7 min read By Compliance

What this means

TCFD-aligned disclosure has been mandatory for LSE-listed and large private UK companies since 2022. A solar PPA is a Scope 2 emissions reduction lever with audited delivery — providing the kind of concrete, measurable evidence TCFD reporting requires.

Actions to take

  • Baseline current Scope 2 emissions using market-based and location-based methods.
  • Calculate Scope 2 reduction from a planned PPA with REGO transfer.
  • Disclose contracted PPA capacity in next TCFD report.
  • Track actual delivery against modelled in subsequent reports.

How PPA delivery fits

A solar PPA delivers measurable, audited renewable kWh from a known commissioning date — exactly the kind of evidence compliance frameworks want. The contract underpins the claim; the M&V annex provides the measurement.

What to negotiate into the PPA

  • REGO certificate transfer (essential for market-based claims).
  • Reporting cadence and format aligned with your compliance cycle.
  • Audit trail support from provider (data feeds, certifications).
  • Performance ratio guarantee with make-good if generation falls short.
Donovan Fawcett · Director, SEO Dons Ltd Twelve years in UK commercial solar SEO and PPA advisory. Editorial policy & independence.
FAQs

TCFD 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.

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