A mandatory reporting threshold, not a voluntary aspiration

The headline change for large energy users is clear: large companies (’Category A’) consuming 10 GWh or more of electricity annually in any area of its business is now required to report the share of that electricity matched with renewable sources on an hourly basis. This is a mandatory disclosure requirement under the new standard.

Beyond the reporting, SBTi has introduced a voluntary recognition programme for companies that want to go further. To earn recognition under the Scope 2 Hourly Matching programme, companies must match at least 50% of their consumption on an hourly basis today, rising to 75% by 2030 and 90% by 2035.

The direction of travel is unambiguous: annual matching is preserved as a baseline, but hourly granularity is now the credibility benchmark.

Geographic deliverability closes a long-standing loophole

Alongside the temporal requirements, CNZS v2 introduces a geographic constraint that materially tightens what counts as a credible Scope 2 claim. Scope 2 claims must come from assets located in the region where the electricity is actually consumed.

This effectively closes the door on EACs sourced from distant markets with no physical or causal connection to the buyer's consumption. Combined with the hourly matching requirement, this means that the combination of spatial and temporal matching is now the standard by which high-integrity claims will be judged.

The debate is not settled, and that matters

Some want to go further. A coalition of NGOs including the Natural Resources Defense Council, Sierra Club, and Union of Concerned Scientists has called on SBTi and the GHG Protocol to go further and fully mandate hourly matching, arguing that annual matching allows companies to claim credit for renewable energy that does not credibly displace fossil generation at the moment it is needed.

This debate mirrors a conversation that has been live in European certificate markets for several years. The EnergyTag standard, which Granular Energy helped to develop and implement, was built precisely on the argument that temporal granularity is what makes clean energy claims meaningful. The SBTi's own framing (that hourly matching reflects genuine alignment between when renewable electricity is generated and when it is consumed) validates that logic, even if the implementation timeline is more gradual than some in the sector had hoped.

It is worth noting that hourly matching score is not the ultimate metric. What matters most is the ability to calculate carbon emissions with hourly granularity, understanding not just whether renewable energy was consumed in the same hour it was generated, but what the actual emissions impact of that consumption was. This is a gap the GHG Protocol's ongoing Scope 2 guidance update is well positioned to address, and the sector will be watching closely for the framework to catch up with the ambition.

One further note on what remains open: alongside the published standard, SBTi has issued a call for evidence specifically on hourly matching methodology. Complementary technical guidance is expected to follow, which may refine how the reporting requirement and recognition thresholds are implemented in practice. Companies and their suppliers should treat the current requirements as the confirmed framework while remaining alert to that supplementary guidance as it emerges.

Why this is the moment for utilities and suppliers to act

For energy retailers, utilities, and suppliers, CNZS v2 is not only a signal about where regulation is heading; it is a commercial opportunity that is opening now.

Corporates with significant electricity consumption have a new compliance obligation: they must measure, track, and report hourly matching performance. Many do not yet have the products, contracts, or data infrastructure to do so. The companies that can serve this need, with tariffs, PPAs, and supply arrangements structured around hourly matching, will have a material advantage as the market moves.

This is precisely where Granular Energy's platform is designed to help. We work with energy suppliers and utilities to build and commercialise hourly matching products: from portfolio structuring and EAC registry connectivity, to the customer-facing data and reporting layers that allow end buyers to evidence their SBTi compliance. The platform handles the complexity of granular certificate issuance, matching logic, and audit-ready reporting, so that suppliers can focus on the commercial relationship with their customers.

Suppliers that can offer their customers a credible hourly matching solution, backed by verified data and robust methodology, are well placed to benefit from this change.