My discom supplies green energy beyond my own obligation. Does it count those units for its own obligation too, and can I still claim them in Scope 2?
Rule 4 of the Green Energy Open Access Rules says green energy bought beyond your own obligation, from the distribution company (discom) or other renewable sources, counts towards the discom's obligation compliance. The text is silent on who holds the claim, so get a written statement before reporting zero.
What Rule 4 says
- Rule 4(2)(C)(f) says green energy purchased from the distribution licensee, or from renewable sources other than the distribution licensee, in excess of the renewable purchase obligation of the obligated entity shall be counted towards the renewable purchase obligation compliance of the distribution licensee.
- Rule 2(1)(e) defines an obligated entity as one mandated to meet the obligation, and lists the distribution licensee, the captive user and the open access consumer.
- Rule 10 says the distribution licensee shall give a green certificate on a yearly basis to consumers for green energy it supplies on request beyond the consumer's obligation.
- Our reading, not a line from the Rules: the same excess units can sit in your Scope 2 claim and in the discom's compliance count. The Rules do not say which party holds the claim.
What the Scope 2 Guidance asks you to do
The Greenhouse Gas (GHG) Protocol Scope 2 Guidance, in its chapter on voluntary consumer programmes, says companies should check with their electricity supplier or relevant policy-making bodies to ensure voluntary certificates are claimed, paired or retired in compliance with jurisdictional requirements.
Its section 9.4.1, on achieving 100 percent renewable energy when supplier quotas apply, says a utility under a quota can combine voluntary and compliance instruments up to the level of the quota, provided the compliance instruments convey energy use claims. Our reading: your zero factor is safe only for units that a document shows were set aside for you and were not also used to meet the discom's own quota.
A second text reaches the same units. The Renewable Energy Certificate regulations make an open access consumer that buys renewable power beyond its obligation eligible for certificates for that excess, but only against the quantity set by the state commission's obligation (Regulations 4(4) and 10(3)), and the application needs the state commission's certification within three months of year end. We found nothing in either text that says which route comes first, so treat it as open and ask.
Ask the discom in writing
- Whether the units you buy beyond your obligation are counted in the discom's own compliance.
- Whether the yearly green certificate under Rule 10 states that the attributes of those units belong to you.
- Whether any Renewable Energy Certificate has been or will be issued for the same units.
- Keep the reply with your bills and the certificate. If you get no clear answer, report the units in your market-based figure only with a note saying the claim is unconfirmed, or use the grid factor.
A factory buying green energy beyond its obligation, in megawatt hours (MWh)
- Annual use: 6,000 MWh. Green units supplied by the discom: 3,000 MWh. Your own obligation in this example: 600 MWh
- Beyond the obligation: 3,000 minus 600 = 2,400 MWh. Rule 4(2)(C)(f) counts this excess towards the discom's compliance
- Confirmed in writing as yours: 2,400 MWh at zero. Uncovered: 6,000 minus 2,400 = 3,600 MWh = 3,600,000 kilowatt hours (kWh) x 0.675 kilograms (kg) of carbon dioxide (CO2) per kWh = 2,430,000 kg = 2,430 tonnes
- If the discom confirms nothing: 6,000,000 kWh x 0.675 = 4,050,000 kg = 4,050 tonnes, with the green units shown in a note
- Gap between the two cases: 4,050 minus 2,430 = 1,620 tonnes
The figures are an example. The 600 MWh obligation is assumed, and the factor 0.675 kg CO2 per kWh is for financial year 2025-26. Our reading: the 600 MWh meets your own obligation and is not a voluntary claim, so it stays in the uncovered part. Our reading: the obligation split is where this page differs from the green tariff page linked above, which counts all green tariff units with a certificate at zero. Rule 10 covers energy supplied beyond the obligation.
What Senseible does here
Senseible keeps electricity bills and renewable purchase records side by side, so location-based and market-based Scope 2 figures can be reported from the same data. Certificate retirement proof stays with the buyer.
- If I buy a discom green tariff, can I report zero Scope 2?
- Can an open access consumer earn certificates?
- What to put in a power purchase agreement for a carbon claim
- Emissions calculators
Sources: Ministry of Power, Electricity (Promoting Renewable Energy Through Green Energy Open Access) Rules, 2022, Gazette notification of 6 June 2022, Ministry of Power, Green Energy Open Access Amendment Rules, 2023, Gazette notification of 27 January 2023, Central Electricity Regulatory Commission (CERC), Terms and Conditions for Renewable Energy Certificates for Renewable Energy Generation Regulations, 2022, Greenhouse Gas (GHG) Protocol, Scope 2 Guidance (2015), Table 7.1 Scope 2 Quality Criteria, Section 9.4.1 and Chapter 10
Last reviewed 2026-11-05. Whether the units are also counted for the discom, and which party holds the claim, is not answered in the national texts. Check your state commission's order and the discom's reply.