Can an India Renewable Energy Certificate I already retired be cancelled later, and what happens to my Scope 2 claim?
Under Regulation 14 of the 2022 certificate rules of the Central Electricity Regulatory Commission (CERC), if an eligible entity (usually the generating plant) got accreditation or registration on false or suppressed information and it is revoked, unredeemed certificates stand extinguished from issue. For redeemed ones, that entity must deposit the sale proceeds with the Central Agency.
What Regulation 14 says
- Certificates issued remain valid until they are redeemed.
- If an eligible entity obtained accreditation or registration on the basis of false information or by suppressing material information, and it is revoked at a later date, certificates already issued but not redeemed stand extinguished from the date of issue.
- For certificates already redeemed, that entity shall deposit with the Central Agency the amount realised from selling them, with interest, as the Regulation sets.
- Regulation 7 (accreditation by the Regional Load Despatch Centre) and Regulation 9 (registration) separately allow revocation after an enquiry and notice, for a breach the accreditation or registration itself declares grounds for revocation.
What it means for you
Our reading, not a line from the Regulations: the clawback lands on the eligible entity, usually the generating plant, though distribution licensees and open access consumers can be eligible entities too. For redeemed certificates the Regulations say that entity must deposit the sale proceeds with the Central Agency. They do not say it is repaid to the buyer or that the redemption is undone. We found nothing in the text that reverses a buyer's redemption.
Unredeemed certificates are the exposed ones. A certificate bought in March and held unredeemed into the next year can be extinguished from its issue date. The Greenhouse Gas Protocol Scope 2 Guidance asks that an instrument be tracked and redeemed, retired or cancelled by or on behalf of the reporting entity, and issued and redeemed as close as possible to the period of consumption. Retiring promptly meets both, and it takes the certificate out of the unredeemed group in Regulation 14. The Regulations define redemption as use for renewable purchase obligation compliance. How a voluntary buyer retires a certificate is in the Central Agency's detailed procedure, which we did not read.
What to do before you buy
- Ask the trader which plant the certificates come from and for its accreditation and registration details.
- Retire in your name for the year you are reporting, not later, by the Central Agency's procedure.
- Keep the registry's retirement or redemption statement, not only the trade confirmation.
- If you hold unredeemed certificates at year end, do not count them in that year's market-based figure.
A year-end shortfall, in megawatt hours (MWh)
- Consumption: 500 MWh. One certificate = 1 MWh. Certificates bought: 500
- Redeemed in the year: 400. Held unredeemed at year end: 100
- Covered by redeemed certificates: 400 MWh at zero. Uncovered: 500 minus 400 = 100 MWh
- Uncovered carbon dioxide (CO2): 100,000 kilowatt hours (kWh) x 0.675 kilograms (kg) per kWh = 67,500 kg = 67.5 tonnes
- The 100 unredeemed certificates are left out whether or not they are later extinguished.
The figures are an example. The grid factor 0.675 kg CO2 per kWh is for financial year 2025-26.
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.
- What proof of certificate retirement a buyer accepts
- How to buy RECs in India
- How does India's REC mechanism work?
- Emissions calculators
Sources: 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 and Chapter 10
Last reviewed 2026-11-05. The Regulations of 9 May 2022 are the text read here. Check whether the Commission has amended Regulation 14 and what the current registry procedure says about revoked registrations.