Under the proposed GHG Protocol Scope 2 revision, would RECs from a generator in another Indian state still count for my market-based Scope 2?

Today, yes: the 2015 Scope 2 Guidance treats a country's grid as one market, so a REC from another Indian state counts if it is retired in your name for the year. Under the draft revision, the answer for India is not settled. The bigger risk is the proposed hourly match. Nothing in the draft is final.

The rule today: same market, and India counts as one

The 2015 Scope 2 Guidance asks that a certificate come from the same market as the electricity it covers, and in practice that market is the national grid. India's grid has also run as one synchronous system since the southern region joined on 31 December 2013. So a certificate from any Indian state passes this test for an Indian factory today.

India RECs under the CERC REC Regulations, 2022, and I-RECs issued for Indian generation both qualify on this point, provided they are retired in your company's name for the reporting year.

What the draft's deliverability test proposes

The consultation draft, open from 20 October 2025 to 31 January 2026, proposes that certificates come from inside a market boundary where the power could plausibly be delivered to your load. It would draw boundaries differently by region, using price zones, physical grid links and other factors, and it does not settle a boundary for India.

Two Indian facts point different ways. One synchronous grid supports a national boundary. But India's power exchanges price by bid area and split prices when a transmission corridor is congested, which could support smaller zones. Treat the outcome for India as uncertain until the final text is out.

The bigger risk is the time match

• The draft proposes that market-based claims match clean generation to consumption by the hour, with an exemption threshold for smaller users, public load profiles for those without hourly data, and a legacy clause for existing contracts.
• A company exempt from hourly matching would still face the deliverability test.
• Check whether your certificates record when the MWh was generated. A certificate that shows only a month or a year cannot prove an hourly match.
• A factory running night shifts could find that solar RECs cover only its daytime use under hourly rules, wherever the plant sits.

What to do while the rule is open

1. Keep buying and retiring Indian certificates for the same year; they meet the current guidance.
2. Record the generator, its state, technology and generation months for every certificate you retire.
3. For new supply contracts, ask for generation data by hour or 15 minutes.
4. Report against the 2015 Guidance and say so, until a final standard and its start date are published.

Worked example: Coimbatore factory, Rajasthan wind RECs

• Consumption: 1,000 MWh (10,00,000 kWh) in the year
• Location-based: 10,00,000 x 0.710 = 7,10,000 kg, 710 t CO2
• Today: 1,000 India RECs from a Rajasthan wind farm, retired for the same year, so market-based = 0 t
• If hourly matching applied and REC generation hours could cover only 600 MWh of use: 4,00,000 x 0.710 = 2,84,000 kg, 284 t CO2 market-based

The last line is illustrative. It shows how a time test, not the state boundary, would change the figure.

What Senseible does here

Senseible reports location-based Scope 2 at 0.710 kg CO2 per kWh (CEA CO2 Baseline Database version 21.0) and market-based Scope 2 once you add your certificate details, with each bill's billing period kept against its kWh.

• GHG Protocol revision: what is changing
• I-REC or India REC?
• Hourly grid emission factors in India
• Proving REC retirement to a buyer

Sources: GHG Protocol Scope 2 Guidance (2015), Scope 2 Quality Criteria, GHG Protocol, Scope 2 revision public consultation draft (20 October 2025 to 31 January 2026)

Last reviewed 2026-10-18. Draft proposal only, as of October 2026 (consultation closed 31 January 2026). Recheck the market boundary for India, the hourly matching threshold and the legacy clause against the next consultation draft or final Scope 2 standard on ghgprotocol.org.