GRI 103 Renewable Energy Claims

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Renewable energy is often communicated through one percentage: '100% renewable electricity'. That single number can combine several different questions. How much electricity did the organisation consume? What did the physical grid supply? Which contractual attributes did the organisation own and retire? What Scope 2 emission factor was used? Did the procurement contract finance new generation or merely transfer existing attributes? Did the organisation sell certificates linked to its own solar output?

GRI 103: Energy 2025 makes the energy-source breakdown and the role of contractual instruments explicit. The reporting team therefore needs a reconciliation between meters, supplier information, certificates or contracts, residual or grid information and the separate Scope 2 calculation. Without that reconciliation, a credible procurement transaction can still become a misleading public claim.

Disclosure 103-2 covers energy consumption and self-generation within the organisation. It requires total fuel consumption and a renewable/non-renewable breakdown; total purchased electricity, heating, cooling and steam and their renewable/non-renewable breakdown; self-generated renewable energy consumed; self-generated energy sold; the use and quality of contractual instruments; and the standards, methods, assumptions, tools and conversion-factor sources.

GRI 103 guidance recommends explaining whether renewable purchased electricity was calculated using grid-average (location-based) data or contractual instruments (market-based data), how electricity was purchased, the grid mix, the types of contractual instruments and the amount and percentage covered by each instrument. This guidance adds context to the required renewable/non-renewable breakdown and helps users understand the basis of the claim.

Figure 1. Renewable-energy claim decision tree. First decide whether the statement concerns physical energy consumption, contractual matching, Scope 2 emissions or an energy/emissions reduction, then apply the evidence test for that claim lane.

Identify the energy quantity. Reconcile metered or invoiced consumption by site, period, product and energy type before considering attributes.

Identify the proposed source classification. Determine whether the renewable/non-renewable split is based on grid mix, supplier product data, a PPA, green tariff, certificate or self-generation.

Confirm attribute ownership. Establish who owns the relevant renewable/GHG-emission-rate attributes and whether they have been sold, transferred, retained, redeemed, retired or cancelled.

Test quality criteria. Confirm exclusive claim, tracking and retirement/cancellation, time-period alignment and same-market treatment; document how temporal and physical connection is pursued.

Reconcile coverage. Claimed renewable MWh plus unclaimed or residual MWh should equal the total purchased-energy population, subject to transparent treatment of data gaps.

Calculate Scope 2 separately. Use the appropriate location-based and market-based emission-factor hierarchy, keeping energy-source and emissions outputs connected but distinct.

Draft the claim. State quantity or percentage, period, geography, instruments, uncovered portion, method and material limitations; avoid unsupported statements about physical delivery or additionality.

The strongest evidence chain begins with the consumption population and follows the renewable attribute through procurement, ownership and retirement. A supplier label or marketing page is not enough. The organisation should obtain contract and product information that identifies the quantity, source or technology, vintage, market, instrument and ownership status. Where supplier-specific information is incomplete, the unclaimed portion should remain visible and be treated using an appropriate residual or grid basis rather than silently inheriting the supplier's headline renewable percentage.

Figure 2. Evidence lanes for renewable-energy reporting. Physical energy records, contractual attribute records and emissions-factor/Scope 2 records answer different questions and should be reconciled rather than collapsed into one claim.

GRI 103 incorporates quality criteria built on the GHG Protocol Scope 2 Guidance. The reporting organisation should be able to demonstrate that the instrument conveys the relevant emission-rate attribute, is the only source of the claim for that quantity, has been tracked and redeemed, retired or cancelled on the organisation's behalf, is aligned as closely as possible to the consumption period, and comes from the same market in which it is applied. GRI 103 also recommends describing efforts to improve temporal and physical connection, such as same-grid or same-country sourcing and hourly matching.

Supplier data can improve specificity, but it should not be accepted simply because it comes from the supplier. The reporting team should request enough information to distinguish the supplier's operational generation mix, the product sold to the organisation and the attributes allocated to that product. Where a utility reports a corporate renewable portfolio but the customer's tariff is not backed by exclusive attributes, the portfolio percentage may not support the customer's market-based claim.

GRI 103 distinguishes fuel consumed to generate electricity, self-generated renewable electricity consumed and energy sold. Electricity generated from fuel and consumed by the organisation is counted once under fuel consumption. Self-generated renewable electricity consumed does not include electricity whose associated contractual instruments have been sold. When self-generated renewable electricity is sold, GRI 103 guidance recommends reporting whether linked instruments were sold and separating energy sold with instruments from energy for which attributes were retained.

An organisation may operate across markets with different certificate systems, supplier products and residual-mix availability. The aim is not to force identical evidence where market infrastructure differs. The aim is to apply a consistent decision policy, disclose the basis used and prevent double claiming. The energy table should reconcile the renewable and non-renewable quantities to total consumption, while the Scope 2 note separately applies the relevant factor hierarchy.

The group first reconciles all invoices and meters to the 120,000 MWh population. It confirms certificate retirement by market and vintage, reviews the PPA to establish transfer of attributes, and removes the sold onsite attributes from the renewable-consumption claim. It reports the covered quantity and percentage by instrument type. The 30,000 MWh uncovered portion uses the relevant market residual mix where available and a disclosed grid-average proxy in one market without a published residual mix.

The energy disclosure separately reports renewable and non-renewable consumption. The Scope 2 note reports location-based emissions for the full population and market-based emissions using the eligible instruments and residual/fallback factors. The group states that its contractual instruments support an attribute-based renewable electricity claim; it does not say that the same electricity physically came from the PPA generator or that all procurement caused new capacity. A separate transition-plan narrative describes the long-term contract and evidence relevant to its expected system impact.

Why this works: the wording identifies the consumed quantity, basis, instruments, coverage, quality treatment, uncovered portion, fallback limitation, sold onsite attributes and separate Scope 2 reporting. It does not overstate physical delivery, additionality or energy reduction.

GRI 103 does not make both grid-average and contractual-instrument amounts an unconditional two-basis metric. Its energy-source breakdown is the reporting focus, while its guidance asks the organisation to state whether renewable purchased electricity was calculated using grid-average data or contractual instruments and to explain the method and evidence used.