TL;DR
The GHG Protocol is consulting on whether to make hourly matching mandatory for Scope 2 reporting — a proposal that 66 major corporations have publicly opposed, citing operational barriers and supply constraints. At the same time, SBTi's Corporate Net-Zero Standard V2 draft is moving toward embedding hourly matching as a structural requirement for new targets from 2028. The debate is live and unresolved; no final standard has been set. This article explains both sides, where the regulatory process stands, and what corporate buyers should do with their procurement planning in the meantime.
Key takeaways:
- The GHG Protocol's hourly matching proposal is not yet adopted — a second consultation is expected in 2026, with a final standard due in 2027
- 66 major corporations oppose mandatory hourly matching, citing supply constraints, grid infrastructure gaps, and the risk of slowing renewable investment
- Proponents argue hourly matching closes a credibility gap in current annual Scope 2 reporting by aligning certificates with actual consumption, hour by hour
- SBTi V2 is moving toward hourly matching for new net-zero targets from 2028, independently of GHG Protocol's timeline and outcome
- Annual matching via GOs and I-RECs under the current market-based method remains fully valid — buyers should proceed with 2026 procurement under existing rules
[Table of Contents]
- What hourly matching actually requires — the operational reality
- Why 66 companies are pushing back — the coalition's case
- The case for hourly matching — what proponents argue
- Where the regulatory process stands — GHG Protocol and SBTi V2
- What to do now — a practical framework for corporate buyers
On 23 April 2026, 66 companies and organisations formally opposed the GHG Protocol's proposal to make hourly clean energy matching mandatory for Scope 2 reporting. The signatories include Apple, Amazon, General Motors, FedEx, Salesforce, Honda, Hewlett Packard Enterprise, and Patagonia — companies with combined annual revenues exceeding $4.6 trillion, collectively responsible for procuring, facilitating, or producing more than 300 gigawatts of carbon-free electricity worldwide.
This is not a protest from companies on the margins of the renewable energy transition. In 2024, Big Tech companies alone accounted for 43 per cent of all corporate clean energy power purchase agreements signed globally. Google consumed 32 TWh of electricity that year — more than many mid-sized countries. These are the companies that built demand for renewable energy certificates, and their collective pushback is the most significant industry challenge to Scope 2 methodology in years.
For corporate sustainability leads, the immediate question is not who is right. It is what this debate means for procurement planning, and how to position a certificate strategy that holds up regardless of which way the standard lands.
1. What hourly matching actually requires: the operational reality
Under the GHG Protocol's current Scope 2 market-based method, companies match their annual electricity consumption with an equivalent volume of Energy Attribute Certificates — Guarantees of Origin (GOs) in Europe, I-RECs across international markets. The matching is done on an annual basis: a company consuming 10,000 MWh per year purchases 10,000 MWh of certificates covering the same reporting period. When and where the underlying renewable electricity was generated during that year does not affect the claim.
Hourly matching changes that fundamentally. Under a mandatory hourly matching requirement, each MWh consumed in a given hour would need to be matched with a certificate from a generator producing in that same hour, in the same market. The temporal and geographic connection — currently optional under programmes such as RE100's advanced procurement criteria — would become a reporting requirement.
The operational implications are significant. Hourly matching requires granular consumption data at hourly intervals across all metered sites; a supply of time-stamped certificates linked to specific generation hours rather than annual production totals; and procurement and tracking systems capable of matching the two at scale. For most corporate buyers today, none of these three conditions are fully in place.
2. Why 66 companies are pushing back: the coalition's case
To understand the weight of this pushback, start with who signed it. Apple has matched 100 per cent of its global electricity use with renewable energy since 2018. Amazon is one of the world's largest corporate purchasers of renewable energy. General Motors, FedEx, Honda, Salesforce, Hewlett Packard Enterprise, and Patagonia are among the other signatories — alongside research and advocacy bodies including Ceres, WattTime, and the American Clean Power Association.
Collectively, the coalition represents more than $4.6 trillion in combined annual revenues, employs 48 million people, and operates across 220 countries and territories. Its members have procured, facilitated, or produced more than 300 gigawatts of carbon-free electricity to date. In 2024, Big Tech companies alone accounted for 43 per cent of all corporate clean energy power purchase agreements signed globally.
These are not companies opposed to renewable energy. They are, in many cases, the companies that created institutional demand for it. Their opposition is not to the principle of accurate Scope 2 reporting — it is specifically about what mandatory hourly matching would produce in practice, given where the market stands today.
The implications extend well beyond the 66 signatories themselves. These companies sit at the top of global supply chains, and their clean energy requirements cascade downward. Apple's Supplier Clean Energy Programme has enrolled more than 320 suppliers across 30 countries, covering 95 per cent of its direct manufacturing spend — with expansion to Tier 2 suppliers already under way through 2026 and 2027. Amazon, which reached 100 per cent renewable electricity across its own operations in 2023, expects its suppliers to demonstrate progress on the same trajectory. Under CSRD and Scope 3 reporting frameworks, large corporates are increasingly required to account for and engage their supply chains on renewable energy use. If hourly matching becomes mandatory at the top of these chains, the operational requirement does not stop there — it propagates to hundreds of thousands of businesses downstream. The coalition's statement refers to representing 33,500 or more organisations in total; the supply chain reach extends considerably further still.
Supply does not yet exist at the scale required. In most markets, the infrastructure for issuing time-stamped, hourly certificates does not exist at the volume corporate buyers would need. Mandating hourly matching before that supply develops would force buyers into a constrained market — or leave them unable to meet their reporting obligations at all.
Grid infrastructure is not ready across most operating geographies. Hourly matching requires metering and grid data infrastructure that is not uniformly available across the 40-plus countries where large multinationals operate. The requirement would fall unevenly — viable in some Nordic and Central European markets, but practically unworkable across many I-REC markets in Asia, Latin America, and Africa.
It risks penalising early movers. Companies that have already invested heavily in annual matching programmes and long-term renewable supply agreements could find those commitments devalued overnight. The coalition's position is that this sends precisely the wrong signal at a moment when corporate renewable energy investment needs to accelerate, not stall.
3. The case for hourly matching: what proponents argue
The argument for hourly matching rests on a genuine limitation of current annual reporting.
Annual matching allows a company to claim 100% renewable electricity for a reporting year even if, in practice, it drew on fossil-generated grid power during peak demand hours when renewable generation was low. The certificates purchased may represent wind or solar generation that occurred in off-peak hours or in a different season — with no required connection to actual consumption patterns.
Proponents argue this creates a credibility gap. Under annual matching, a company's Scope 2 disclosure reflects the total volume of renewable energy it procured across a year, not when or whether that renewable generation coincided with its actual consumption. Hourly matching would close this gap, producing a claim that is accurate at the level of each hour rather than the year as a whole.
For CSRD auditors, CDP reviewers, and supply chain partners applying increasing scrutiny to Scope 2 disclosures, this distinction is becoming more material. As reporting frameworks evolve, the question of whether a company's market-based claim reflects genuine temporal alignment with renewable generation is moving from a best-practice consideration toward a credibility standard.
The infrastructure question is also evolving. A number of technology companies are actively developing the data and tracking layer that hourly matching would require at scale. Companies such as Granular Energy and FlexiDAO, among others, are building platforms designed to issue, match, and retire time-stamped energy attribute certificates at hourly — or sub-hourly — granularity. Their work suggests the operational barriers the coalition cites are not permanent constraints, but a question of market readiness and timing. For corporate buyers exploring what an hourly matching strategy would look like in practice, these developments are worth monitoring as the standard-setting process advances.
4. Where the process stands: GHG Protocol and SBTi V2
Two parallel processes are moving on separate timelines, and it is important not to conflate them.
GHG Protocol Scope 2 revision: The first public consultation on Scope 2 closed in January 2026. A second public consultation — specifically addressing hourly matching and deliverability, the most contested elements of the revision — is expected later in 2026. No launch date has been confirmed. The final updated Standard is expected in 2027. The coalition's statement is a contribution to a live consultation process. Nothing has been decided.
SBTi Corporate Net-Zero Standard V2: Separately, the SBTi's second consultation draft of its Corporate Net-Zero Standard V2 mandates 100% low-carbon electricity by 2040, with targets required to be sourced from the same market as consumption and matched on an hourly basis, implemented gradually. V2 is expected to be finalised in 2026 and becomes mandatory for companies setting new net-zero targets from 1 January 2028. Companies may continue setting targets under the current standard (v1.3.1) until 31 December 2027.
These two processes are independent of each other. The outcome of the GHG Protocol consultation will not determine SBTi V2's requirements. Corporate buyers with SBTi net-zero commitments may face hourly matching requirements through the V2 standard regardless of where the GHG Protocol revision lands.
If your organisation is part of the supply chain of a major RE100-committed buyer, understanding this debate is not optional — it is preparation. GreenPowerHub helps corporate buyers source, track, and report Energy Attribute Certificates across more than 40 countries. Whether you are managing annual GO procurement today or planning for what a future hourly matching requirement would mean for your certificate strategy, the platform gives you the market access and data to stay ahead of the standard — not behind it.
About GreenPowerHub
GreenPowerHub is a leading digital marketplace for trading renewable energy certificates, serving stakeholders across Europe and global markets. By facilitating transparent, efficient trading and providing actionable market intelligence, GreenPowerHub empowers energy producers, suppliers, and consumers to participate in the energy transition and achieve their sustainability goals.
Reference: