How do I report Scope 2 when my factory buys solar power through a group captive or open access arrangement?
Report both ways. Location-based Scope 2 applies the grid factor to all the electricity you consume, including the wheeled solar. Market-based Scope 2 can treat the solar units adjusted on your bill as zero, if your contract gives you their renewable attributes and nobody sold RECs for them.
Why location-based Scope 2 does not fall
Wheeled solar travels over the same grid as everyone else's power. The GHG Protocol Scope 2 Guidance defines location-based Scope 2 as the average intensity of the grid where you consume, so it is total consumption times the grid factor, whatever you contracted. Only a direct private line from a plant to your factory, with no grid in between, changes that.
When the solar can count as zero in market-based
The guidance sets quality criteria for contractual instruments. For a group captive or open access deal, check each one:
- The contract conveys the renewable attributes of the generation to you.
- Only you claim them: no RECs issued and sold for the same MWh, and the generator does not claim them elsewhere.
- The units are from the reporting period, or close to it.
- The plant is in the same market as your load. Plants on India's national grid are generally treated as one market.
Which units to claim
- Claim the units adjusted at your meter on the discom bill, after transmission and wheeling losses, not the units the plant injected.
- Banked units are claimed when they are adjusted against your consumption; note their generation months, since the guidance asks for instruments as close as possible to the period of use.
- Lapsed banked units that were never adjusted against your load cannot be claimed.
What to use for the remaining grid power
India does not publish a residual mix factor. Use the CEA grid average for the units still drawn from the grid, and say in your report that it is a proxy for the residual mix. This slightly understates market-based Scope 2, because the grid average still contains renewables that others have claimed.
Evidence to keep
- The power purchase or shareholder agreement clause on renewable attributes.
- Monthly discom bills showing units adjusted.
- The energy account from the state load despatch centre or the generator.
- A declaration from the generator that no RECs were issued or sold for your units.
Worked example: one year with group captive solar
- Total consumption: 1,000 MWh, of which 600 MWh adjusted as group captive solar
- Location-based: 1,000 MWh x 0.710 t CO2 per MWh = 710 t CO2
- Market-based: solar 600 MWh at zero; grid 400 MWh x 0.710 = 284 t CO2
- Report both: 710 t CO2 location-based and 284 t CO2 market-based, with the residual mix proxy disclosed
The 284 t figure holds only if the solar attributes are contractually yours and not sold as RECs.
What Senseible does here
Senseible reports location-based Scope 2 from the kWh on your electricity bills at 0.710 kg CO2 per kWh, and market-based Scope 2 when you supply the contract or certificate data. It does not verify that the attribute claim is valid.
Sources: GHG Protocol Scope 2 Guidance, Electricity Rules, 2005, Rule 3, and Electricity (Promoting Renewable Energy Through Green Energy Open Access) Rules, 2022, Ministry of Power, CEA CO2 Baseline Database
Last reviewed 2026-10-16. The GHG Protocol is revising its Scope 2 guidance and Rule 3 of the Electricity Rules was amended in 2026; check both before the next report.