SBTi opens 30-day comment period on net-zero electricity rules

By Tom Whitfield

SBTi opened a 30-day public comment period on Nov. 5 on proposed changes to the electricity criteria in its Corporate Net-Zero Standard 2.0, which takes effect on Feb. 1, 2027. The consultation is confirmed; the revisions are not.

The standard overhauls how companies address decarbonization of electricity and energy supply under Scope 2 of the Greenhouse Gas Protocol’s carbon-accounting rules. SBTi’s circulated text would define grid deliverability regions more clearly and specify how older power purchase agreements receive recognition.

Scope 2 questions produced the second-highest number of comments in the formal consultation, according to SBTi, making electricity accounting one of the most contested implementation areas. Its 20-page electricity criteria proposal concentrates on three mechanics.

Which electricity rules remain unsettled?

• Grid deliverability regions. The current standard provides only a high-level definition, deferring to the GHG Protocol’s ongoing revisions. SBTi proposes an interim list to prevent companies from adopting divergent approaches before the underlying protocol changes become final.
• Electricity load aggregation. Current text requires power covered by aggregated low-carbon electricity projects to come from interconnected grids, a condition that could limit potential deals. Interim language would ease that restriction and give complex contracts more room.
• Legacy power contracts. The proposed text would grandfather lower-carbon electricity contracts signed before February 2027 even if the power is not yet being delivered. For existing power purchase agreements, the issue is whether a contract can retain recognition before delivery begins.

How will comments change the standard?

Comments could change the final language, but they do not settle it. SBTi’s technical council retains ultimate oversight. The proposed revisions are intended to provide interim clarity while companies set targets under the new standard in 2027, ahead of continuing GHG Protocol work on carbon accounting for purchased electricity.

Any decision to treat the proposal as final would be premature.

In mid-October, the GHG Protocol acknowledged that it will consider an adjusted approach to Scope 2. Its review draws 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.

That sequencing matters. SBTi can clarify its own criteria before the standard starts, but the GHG Protocol may still alter the accounting basis beneath those criteria. Brands and suppliers working to the standard therefore face two linked rule tracks, not one.

What is the timetable for final wording?

The comment period runs for 30 days from Nov. 5. SBTi plans to analyze submissions in December, then publish any changes in January alongside a summary of actions taken. It also expects “further interpretations, clarifications and additions” as the new edition rolls out.

These steps sit within a feedback system created by updates to SBTi’s procedural guidelines in late October. SBTi said: “The new standard operating procedure places a greater emphasis on public comment periods to gather feedback. These can be shorter than public consultations because they are limited in scope.”

What does this change for brands, factories and sourcing teams?

The immediate change is to planning assumptions, not to a settled compliance endpoint. The standard takes effect on Feb. 1, 2027, its technical council can alter the consultation outcomes, and the GHG Protocol has not issued its final Scope 2 revisions.

Electricity sourcing teams should identify projects that rely on aggregation across grids, review lower-carbon contracts signed before February 2027, and record how they classify deliverability regions. Those checks can expose a contract or project that may not work under the final text.

Compliance teams should track the December review and January publication rather than lock systems to the current draft. SBTi expects further guidance, so organizations should build a review point into their 2027 target process instead of treating the November proposals as a final accounting code.

For procurement and compliance leaders, January’s text and subsequent protocol guidance matter more than the current draft. A live framework, not a finished one.