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I’ve sat in boardrooms and pitched the importance of buying “100% renewable energy” to countless Executives and Board members.
They’ve been long term deals prioritising pricing stability, and short-term deals looking to ride the market. Deals that make us leaders amongst peers, and deals done alongside peers in corporate buyers clubs with no reputational risk. Deals with complicated hedging instruments and deals that pay a premium for simplicity. Deals for solar, deals for wind, and deals for the certificates we can put on energy calling it “renewable”.
Deals that have always secured “100% renewable energy”.
But once the Greenhouse Gas Protocol wrap their mammoth 5-year review into their standards – widely seen as the global carbon accounting standards – that will change.
Renewable energy procurement will evolve beyond simple “100% renewable” claims because the physical reality matters: the wind isn’t always blowing, and the sun isn’t always shining (and the coal isn’t always burning).
And we’ll all have to walk back into those boardrooms and explain why buying “100% renewable” energy isn’t leadership anymore (or potentially, even possible anymore) and what corporates can do instead to have genuine impact on the energy transition.
When Leadership Becomes Commonplace, Standards Must Evolve
The Greenhouse Gas Protocol’s proposed updates to its Scope 2 Guidance are the biggest change to corporate renewable energy accounting since the dual reporting framework was arrived in 2015.
Much has shifted since then. The Paris Climate Agreement ushered in global climate action, the TCFD introduced mandatory climate disclosure, technology has offered us new solutions as the price of solar and wind energy has collapsed as the proportion of renewable energy in our grid has roughly quadrupled.
The accounting rules need to catch up.
The two biggest proposed reforms relate to where and when renewable energy is used.
New requirements for hourly matching of renewable energy purchases with consumption mean you can no longer say you used solar power at night. And stricter geographic boundaries for what counts as “deliverable” clean energy means can’t use wind power generated in Madrid to say you’re 100% renewable in Melbourne.
For Australian companies that have proudly announced 100% renewable energy procurement through Large-scale Generation Certificates (LGCs), this feels like shifting sands.
And it is.
Beyond the GHG Protocol’s review, Australia is preparing to change the certificate scheme used to establish what is (or isn’t) renewable energy. Large Generation Certificates, or LGCs, which have been in circulation since 2001’s Renewable Energy Target, are being replaced by more modern Renewable Energy Guarantees of Origin – or REGO certificates – in 2030. A new certificate for a new system designed precisely to enable the kind of granular, timestamped tracking that the new GHG Protocol Scope 2 guidance contemplates.
And it brings with it challenges as we contemplate doing things differently for the first time in over a decade.
But this rule change isn’t arbitrary. It reflects something important: progress.
Why Now?
This reform responds to four fundamental changes.
- Societal expectations and corporate ambition have evolved.
When the 2015 Scope 2 Guidance was published, corporate 100% renewable energy commitments were still relatively rare. Today, hundreds of companies have made these pledges. Many have already been 100% renewable for years. What was once leadership has become standard practice. The bar needed to rise. Google and Microsoft are raising it.
- Technology has caught up.
A decade ago, hourly tracking of renewable energy generation and consumption simply wasn’t feasible at scale. The systems didn’t exist. The data wasn’t available. Now, as EnergyTag’s recent accreditation of the first Granular Certificate schemes demonstrates, we have the infrastructure to match clean energy claims with far greater precision. Emerging start-ups across Australia, the UK, Asia, Europe and the US are enabling ambition that was previously impossible.
- Governance demands have intensified.
Greenwashing concerns have moved from activist talking points to mainstream investor scrutiny and regulatory action. Transparency isn’t optional anymore. It’s survival. The European Union’s CBAM will require time-matched renewable energy claims for hydrogen imports from 2030. California’s climate disclosure laws demand verifiable emissions data. How much longer before “100% renewable energy” claims predicated on certificates sourced from different times and geographies are subjected to similar transparency and authenticity concerns?
- The energy transition is stalling – and granular data helps unstick it.
Research consistently shows that hourly matching sends far stronger price signals for the firm, dispatchable clean energy and storage we desperately need. This can correct a broken incentive structure which does nothing to deter corporates from using energy when it is its most carbon intensive, or invest in firming technologies we need to complement cheap solar and wind.
The Australian Context: LGCs to REGOs
For Australian businesses, this evolution arrives at a decisive moment. The mandatory Renewable Energy Target – and the LGC framework that underpins it – expires in 2030.
Enter the Renewable Electricity Guarantee of Origin (REGO) scheme, which launched in mid-2025 and will operate alongside LGCs until the RET ends. Unlike LGCs, which are distinguished only by the calendar year they’re created, REGOs are timestamped to the hour, creating the granular data infrastructure that aligns perfectly with where global carbon accounting is headed.
This is Australia positioning itself for the next phase of renewable energy markets, particularly as our hydrogen ambitions (which suffer from challenges beyond the granularity of their renewable energy use) depend on credibly demonstrating time-matched clean energy use for international buyers.
Empathy for the Exhausted, Enthusiasm for Progress
I have genuine empathy for sustainability professionals who will need to re-enter boardrooms and explain that the leadership standard moved. Getting executive buy-in for renewable energy procurement is hard enough the first time. Convincing finance teams to invest in hourly tracking systems, upgrading procurement strategies, and potentially paying premiums for time-matched certificates feels like running up a hill that keeps getting steeper.
But here’s what we owe them more than empathy: context and honesty.
The goalposts moved because we succeeded. 100% renewable energy procurement became so widespread that it stopped being differentiating. The market matured. The science improved. The stakes got clearer.
When Google announced it was pursuing 24/7 carbon-free energy matching for all its data centres, it wasn’t grandstanding – it was acknowledging that annual matching doesn’t actually decarbonise grids hour-by-hour. Google engineers are nothing if not stubborn geniuses who refused to swallow a broken accounting standard.
Now, through the Scope 2 update, that understanding is being woven into the global carbon accounting infrastructure that shapes how thousands of companies measure and report their climate impact.
What This Means for Australian Companies
Three things matter now.
Recognise that moving goalposts indicate market maturity, not regulatory caprice.
This is about where renewable energy markets and carbon accounting frameworks are going, not where they’ve been. Some corporates will lead in the face of reform; others will shy away and wait for others to move. Some will do nothing at all. You choose where you sit.
The 2030 transition from LGCs to REGOs offers a natural inflection point. That gives us four years (and counting) to get their act together. Leaders will not wait until then.
Early movers will be able to shape the regulatory and technical infrastructure for granular renewable energy tracking.
Leaders can work with energy retailers to develop pricing models and technology providers to develop dashboards and management strategies, developing internal capabilities while competitors are still debating whether hourly matching is really necessary.
The same ESG professional who convinced Boards that 100% renewable energy mattered was right then, and they’ll be right again about time matching renewable energy.
Listen to them. Resource them.
The goalposts are moving. They moved because the market did.
We’d love to hear your thoughts – email ian.lieblich@bwdstrategic.com or message him on LinkedIn if you’d like to continue the conversation.
About the Author
Ian Lieblich is a Senior Strategy Manager at sustainability strategy consultancy BWD Strategic, with over a decade in climate and energy policy experience.