SBTi scope 2 rules put plant power contracts under review
The Science Based Targets initiative (SBTi) has opened a short comment period on its SBTi scope 2 rules: how the Corporate Net-Zero Standard Version 2.0 treats purchased electricity. The proposals cover where clean power must come from, how buyers can pool load across sites, and which existing contracts stay valid. SBTi’s announcement stresses that nothing has changed yet.
For a US manufacturer with a validated target, or one in progress, this is a Scope 2 question with a procurement deadline attached. Contracts signed before the standard takes effect on 1 February 2027 would be grandfathered.
Picture a typical plant group buying clean power
Take an illustrative case. A US-headquartered food and beverage group runs four plants in the Midwest and Southeast and one site in Ireland. It reports market-based Scope 2 emissions using renewable energy certificates and one virtual power purchase agreement (PPA) in a different grid region. Its sustainability team is now negotiating a second deal to cover the remaining load.
Under the new standard, that second deal matters more than the first. SBTi says the amendments require that “the clean power match the grid companies actually use” and describes a managed transition to tighter geographic matching. A contract that pairs a plant in one market with a wind farm several grids away may carry less weight than it once did.
Where your power comes from is now part of the claim
The standard introduced deliverability regions, the geographic limits on where purchased clean power can come from, but never defined them. SBTi has now proposed a preliminary list for comment, so companies stop inventing their own interpretations before the Greenhouse Gas Protocol finishes its Scope 2 revision.
Load aggregation is the second issue. As ESG Dive reports, the current text limits aggregation to wide area synchronous grids and recognizes only PPAs. SBTi says this does not match current practice, particularly in the US, where tax credit transfer agreements play a similar role in project finance. The interim wording would relax that limit, which could widen the range of eligible deals.
Contracts signed before February keep their value
Grandfathering is the practical point for procurement teams. Lower-carbon electricity contracts signed before the effective date would be recognized, even where the power is not yet being delivered. Exemptions from the standard’s generator age limit also move into the main text.
That creates a window, not a rush. A badly matched contract signed in January is still a badly matched contract once the Greenhouse Gas Protocol finishes its Scope 2 revision. Treat the deadline as a reason to finish the analysis, not to skip it.
What to settle before the comment window closes
Start with the inventory. Map each plant’s electricity use against its grid region and against the certificates and contracts that cover it today. That shows which claims already sit in the same region and which rely on distant supply. Our advisory and reporting team builds this kind of market-based Scope 2 baseline as part of carbon footprinting.
Then decide whether to comment. Comments close on 5 December 2026, and SBTi plans to publish any changes in January. Operators that finance projects through tax credit transfers have a direct interest in the load aggregation wording. For multi-site manufacturers, the outcome will shape the next decade of power purchasing, so it belongs in the climate action plan, not only the procurement file.
SBTi is moving toward clean power that matches the grid a site actually draws from. Contracts signed before the standard takes effect keep their value, so the next few months are the time to check the fit.
