SBTi Opens 30-Day Comment Window on Net-Zero Electricity Rules

The Science Based Targets initiative opened a 30-day public comment window on Nov. 5 seeking feedback on the electricity criteria in its Corporate Net-Zero Standard 2.0, which takes effect on Feb. 1, 2027.

The consultation targets the most contested piece of the revised standard: how companies must account for decarbonized electricity and energy supply under Scope 2 of the Greenhouse Gas Protocol's carbon accounting rules. SBTi has circulated a 20-page electricity criteria proposals document covering new text on grid deliverability regions and clarified language on how older power purchase agreements will be recognized.

The feedback could reshape the final text, though nothing is decided. SBTi's technical council retains ultimate oversight over the standard.

Why the electricity rules drew the second-most comments

Queries related to Scope 2 generated the second-highest number of comments during the formal consultation process for the new corporate net-zero standard, SBTi said. The proposals document addresses three pressure points:

• Deliverability regions. The standard currently offers only a high-level definition, in deference to the GHG Protocol's ongoing revision process. SBTi proposes an interim list so that companies do not adopt differing approaches before the protocol's changes are finalized.
• Electricity load aggregation. The current text requires that electricity covered under aggregated low-carbon electricity projects come from interconnected grids, a constraint that could limit potential deals. The interim language would ease that restriction.
• Legacy contracts. The proposed text change would recognize lower-carbon electricity contracts signed before next February even if the power is not yet being delivered.

SBTi framed the potential changes as interim clarity. They are intended to guide companies as they begin setting targets under the revised standard in 2027, ahead of ongoing work by the GHG Protocol on revisions to the accounting rules that govern purchased electricity.

What does this change for companies setting targets?

For now, procedure. SBTi will analyze the comments it receives in December. Any changes the organization opts to make will be implemented and published in January, along with a summary of the actions taken.

The wider accounting picture is still moving. In mid-October, GHG Protocol acknowledged it will consider an adjusted approach to Scope 2 based on comments received over the summer, input from the Scope 2 technical working group, and an Oct. 6 meeting of the Scope 2 independent standards board. More guidance is anticipated soon.

A new, faster feedback machinery

The electricity comment window runs under a new feedback system created by updates to SBTi's procedural guidelines in late October. The organization signaled that more such windows will follow.

"The new standard operating procedure places a greater emphasis on public comment periods to gather feedback," SBTi said. "These can be shorter than public consultations because they are limited in scope."

SBTi also hinted it anticipates "further interpretations, clarifications and additions" as the new edition of the net-zero standard is implemented.

The near-term milestones are fixed: comments close in early December, analysis follows that month, and any revisions to the electricity criteria publish in January — ahead of the standard's Feb. 1, 2027 effective date, and before the GHG Protocol's own Scope 2 revisions settle the underlying accounting rules.