When banked open access units lapse at the end of the banking cycle, who gets the certificates, and can I claim those units in Scope 2?

Under the Green Energy Open Access Rules, 2022 as amended in January 2023, surplus banked energy not used within the banking cycle lapses, and the renewable generating station is entitled to Renewable Energy Certificates (RECs) for it. Count only units the distribution company (discom) adjusted against your load.

What the Rules say about unused banked energy

• Rule 8 of the Green Energy Open Access Rules, 2022, as substituted on 27 January 2023, says the credit for banked energy shall not be permitted to be carried forward to subsequent banking cycles and shall be adjusted during the same banking cycle.
• It adds that the un-utilised surplus banked energy shall be considered as lapsed at the end of each banking cycle, and that the renewable energy generating station shall be entitled to get Renewable Energy Certificates to the extent of the lapsed banked energy.
• Before the 2023 amendment the proviso spoke of months, not banking cycles. Rule 8(1) still says banking shall be permitted at least on a monthly basis, and the appropriate commission fixes the charges. The Rules do not reconcile the monthly basis in Rule 8(1) with the banking cycle in the proviso, so that is your state's call.
• The Rules do not say how long a banking cycle is. Your state commission's regulation and your agreement with the discom decide that.

What this means for your market-based Scope 2

The Greenhouse Gas (GHG) Protocol Scope 2 Guidance says every contractual instrument used in the market-based method shall be the only instrument that carries the emission rate claim for that quantity of electricity, and shall be tracked and redeemed, retired or cancelled by or on behalf of the reporting entity.

Our reading, not a line from either text: lapsed units were never set off against your consumption, and the Rules point the certificates for them to the generator. So they do not belong in your market-based figure. Only the units your discom adjusts against your load in the cycle can carry a zero factor, and only if no certificate is issued for those same units.

The Rules say the generator is entitled to certificates for the lapsed amount. They do not say the generator will apply for them. Either way you hold no claim to lapsed units.

What to ask for and keep

• From the discom or the load despatch centre, a statement for each banking cycle showing units banked, units adjusted against your consumption, and units lapsed.
• A clause in the power purchase agreement (PPA) that certificates are sought only for lapsed units, never for units adjusted to you.
• Your electricity bills for the same months, so adjusted units can be matched with consumption.
• The month each unit was generated, in case a buyer asks for it.

One banking cycle for a factory using 1,200 megawatt hours (MWh)

• Units credited to your account from the solar plant in the cycle: 1,000 MWh
• Used in the same time blocks as generated: 900 MWh. Surplus banked: 1,000 minus 900 = 100 MWh
• Drawn back inside the cycle: 60 MWh. Lapsed at the end of the cycle: 100 minus 60 = 40 MWh
• Units adjusted against your load: 900 + 60 = 960 MWh, at a zero factor
• Uncovered: 1,200 minus 960 = 240 MWh x 0.675 kilograms (kg) of carbon dioxide (CO2) per kilowatt hour (kWh), the grid factor for financial year 2025-26 = 162,000 kg = 162.0 tonnes
• Location-based for the same cycle: 1,200,000 kWh x 0.675 = 810.0 tonnes
• The 40 MWh that lapsed are in neither the zero-factor part nor your claim.

The figures are an example. India publishes no residual mix, so the example uses the grid factor for uncovered units; the residual mix page explains this.

What Senseible does here

Senseible keeps electricity bills and renewable purchase records side by side. Add banked, adjusted and lapsed units from your discom statement. Certificate retirement proof stays with the buyer.

• How much solar power can I bank with the discom?
• Banked units: which month in Scope 2
• What to put in a PPA for a carbon claim
• Residual mix factor for India
• 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, Greenhouse Gas (GHG) Protocol, Scope 2 Guidance (2015), Table 7.1 Scope 2 Quality Criteria and Chapter 10

Last reviewed 2026-11-05. Check your state commission's banking regulation for the length of the banking cycle and for what it does with lapsed units, and confirm with the generator whether it applies for certificates on them.