Can Energy Attribute Certificates Be Used for Scope 3 Under SBTi CNZS V2.0?

Under SBTi's Corporate Net-Zero Standard V2.0 (CNZS V2.0), Energy Attribute Certificates (EACs) are recognised instruments for implementing electricity-related targets across a company's value chain. They do not reduce a company's physical Scope 3 greenhouse-gas inventory. They count as a target-implementation action and support system-contribution claims. Geographic eligibility is based on deliverability regions where value-chain location data is available; where it is not, national or other appropriate regional boundaries may be used as a documented fallback. Coordination with value chain partners is required to avoid overlapping claims regardless of who cancels the certificate.

This article covers the topic in two halves: a practical guide to how CNZS V2.0 treats EACs for Scope 3 electricity, including eligibility, inventory effects, cancellation roles, and evidence; and a market and price impact discussion that is mostly speculative but included as market intelligence.

The historical context of SBTi and Scope 3

Energy Attribute Certificates (EACs) do have a legitimate history of being used to reduce Scope 3 emissions numbers, but only ever indirectly. We wrote a whole guide on it, which is worth reviewing before we proceed into SBTi specifics, as some knowledge is assumed within. But the overall idea is pretty simple: The valid indirect method is when your value chain partners (upstream or downstream) utilise EACs to bring down their Scope 2 emissions numbers, and as a result, your Scope 3 figures are positively impacted.

None of this is really a new commercial idea. Supplier-facing renewable-electricity programs, using supplier-specific carbon data and actioned as supplier- or buyer-funded EAC procurement, have existed for years - including in our own earlier take on EACs and Scope 3 linked above. That earlier guide covers the general indirect mechanism: no SBTi-specific framework governed how EACs could be used, and the GHG Protocol Scope 3 Standard never established a general market-based accounting method for Scope 3. Under those conditions, EAC usage for Scope 3 reduced a supplier's market-based Scope 2 figure, which in turn reduced the buyer's Scope 3 indirectly, where supplier-specific Scope 2 data was used in the calculation.

SBTi now applies a more hands-on stance that more clearly defines a role for EACs within their broader reporting framework. The previous standard, CNZS V1.3.1, did not give corporates a comparable Scope 3 EAC implementation framework. This changes under CNZS V2.0, and this is where the rest of the guide picks up.

What does SBTi CNZS V2.0 decide for Scope 3 EACs?

EACs finally have an explicit home within Scope 3: SBTi's Corporate Net-Zero Standard V2.0 Criteria (released 11 June 2026, effective 1 February 2027) expressly grants recognition of Energy Attribute Certificates as eligible instruments for implementing electricity-related targets across a company's operations and, excitingly, their value chain. There's no new market-based Scope 3 inventory, but there is a standards-aligned Scope 3 electricity program where the attributes (certificate characteristics) and attribution (naming a specific customer to make an EAC claim exclusive, not shared) are controlled in a predictable manner - with EACs used for Scope 3 subject to the same EAC eligibility and usage criteria as apply within Scope 2 pathways (with one deliverability exception that we'll unpack later).

The new version also imposes a strict sequence of actions that a company should follow when looking to address their Scope 3 emissions: the implementation hierarchy. Companies should try activity-level action first, which means reducing the emissions source itself. For value chain electricity this means working with their suppliers or customers on energy efficiency, switching to a low-carbon tariff or to on-site generation. Only where these solutions are not applicable due to, for example, timeframe, feasibility or volume constraints, should companies take action within the shared system where their electricity consumption sits in - the grid. This is where EAC procurement becomes relevant. The third, sector-level action, is reserved for cases with structural constraints, such as regulatory barriers, the lack of a registry, or supply constraints.

Scope 3 inventory means the accounted total emissions arising from an organisation's Scope 3 activities. As for the "Scope 2 of Scope 3", this is just the emissions associated with purchased electricity within Scope 3. This can occur anywhere in your value chain, besides category 15 (investments). For context, there are 15 categories for Scope 3 as detailed by the GHG Protocol. CNZS V2.0 hands category 15, investments, off to a different SBTi standard entirely, known as the Financial Institutions Net-Zero Standard (FINZ). That's a separate topic entirely, but readers should know that the emissions associated with purchased electricity of category 15 are not covered here.

Does using EACs reduce a company's Scope 3 inventory?

Under SBTi CNZS V2.0, using EACs for electricity-related target implementation does not reduce the company's physical Scope 3 inventory. This is distinct from the supplier-specific market-based accounting approach described in our general guide. Our primary SBTi V2.0 overview explores the inventory anchor in more detail. The organisation cancelling EACs for their Scope 3 consumption receives the following benefits, both non-inventory:

A recognised target-implementation action. In previous CNZS versions, buying EACs for Scope 3 electricity had no SBTi-sanctioned impact. Now it counts as a credible action under your validated target for Scope 3.

The right to make a specific public claim. These claims would be considered system-contribution claims, not emissions-reduction claims, which are no longer possible via EAC usage under SBTi V2.0 - EACs do not impact the physical inventory.

Note that as a private standard, the legality of marketing claims is not SBTi's territory, but where EAC usage credibly permits, an example of a valid systems-contribution claim under SBTi could be:

"Through procuring EACs matched to 100% of our value chain's electricity consumption, we've contributed to decarbonising the grid systems our suppliers depend on."

Using these claims for public marketing purposes should be assessed against relevant legal frameworks. But how do buyers even know which EACs are acceptable? This comes down to the standard SBTi criteria for using EACs at an activity pool level.

What EAC eligibility and usage criteria apply?

To support specific Scope 3 electricity activities, the buyer's job is essentially to prove that the certificate-backed action corresponds to specific value-chain electricity consumption, which is an integral part of choosing and using the correct EACs. That is where CNZS V2.0 becomes much stricter than the looser Scope 3 behaviours previously adopted in the EAC market.

New Boundary Rulings: Buyers should understand that CNZS V2.0 asks companies to define activity pools for value-chain electricity consumption. For a guide to defining activity pools, see our write-up on deliverability regions and activity pools (note that it covers the topic generally and is Scope 2-focused). For Scope 3, there is one additional clarifying point: where the geographic location of value-chain electricity consumption is known in sufficient detail, activity pool boundaries shall be defined based on deliverability regions. Where that information is not available, national or other appropriate regional boundaries may be used, with the company reporting the basis for their application (CNZS V2.0 C30.2).

Applicable Market Instruments: SBTi CNZS V2.0 lists the market instruments that can be used for electricity-related target implementation (C31.1). Those instruments include unbundled EAC purchases, physical and virtual PPAs (themselves containing EAC cancellation), contracts with electricity suppliers for low-carbon electricity (LCE) attributes, and some default-delivered low-carbon electricity arrangements. Default LCE delivery must be either supported by EACs, or, a carveout is made for grids where, so long as the following points are true, bypassing EACs as a traceability mechanism entirely is deemed acceptable:

• there is no applicable EAC registry for that activity pool
• LCE accounts for at least 95% of the activity pool’s generation mix

So, assuming your activity pools have an applicable registry and you're looking to procure EACs, unbundled or within a contract; the basics for viable EAC procurement are covered. Let's look at the evidence that SBTi will expect you to provide.

Do my value chain partners need to be involved?

It depends on which cancellation route is taken.

Buyer-led cancellation with coordination. The buyer procures the certificate and cancels it against the value chain partner's consumption data, without transferring it to a registry account owned by the partner. The buyer matches it to the partner's activity pool from a deliverability perspective. This approach requires coordination with the value chain partner to avoid overlapping certificate coverage and duplicate claims for the same electricity consumption. The buyer holds and retires the certificate but must demonstrate that the partner has not separately claimed the same electricity.

Supplier-led cancellation. The value chain partner buys or receives the certificate and cancels it against their own Scope 2 emissions. If registry notes can be added to the certificate, attribution to the reporting company's share of the partner's electricity consumption should be recorded. Where the partner cancels the certificate, the buyer should not separately claim the same attribute. Whichever role the registry's beneficiary field is designed to capture will depend on that registry's specific data model; companies should confirm attribution with the relevant registry operator rather than assume a universal field function.

Whichever method you choose, you should make it clear when reporting. Our original Scope 3 guide on how EACs can reduce Scope 3 emissions goes into more detail on the practicalities of partner involvement and engagement.

What evidence is required for Scope 3 EAC usage?

When reporting Scope 3 EAC usage in the form of system-contribution claims, kept separate from inventory reductions, there is some minimum evidence a buyer should prepare.

• Clear Activity: Report clearly and explicitly on the relationship to a particular upstream or downstream entity's purchased electricity that is being matched (categories 1 to 14).
• No Double Counting: Demonstrate clearly how double counting of value chain LCE has not taken place. On the registry level, named cancellation certificates attributable to the reporting company prove exclusive claim, preventing shared double counting. At the allocation level, the same supplier MWh cannot be matched to more than one customer.
• Deliverability Region Aligned: Match certificates to the relevant deliverability region and reporting period. This is typically a bidding zone, but not always. Full guide here.
• Other SBTi V2.0 Criteria Aligned: Market instruments must be limited to LCE generators commissioned or re-powered within fifteen years preceding the period of electricity consumption (C31.3). Full EAC criteria can be viewed here.
• Comprehensive Audit Trail: Certificate issuance, transfer, cancellation, and retirement must be recorded in a secure registry or equivalent system of records (C28), with any attribution clearly noted, including the registry of origin and the registry of cancellation.

What can CNZS V2.0 mean for EAC demand and prices?

SBTi's recognition of EACs for value-chain electricity expands the use case beyond a company's own Scope 2 consumption. Although that creates a larger addressable market for EACs, it does not necessarily initiate larger certificate demand.

Three factors will determine how much incremental demand appears.

First, companies need usable electricity data from their value chains. Many still estimate Scope 3 emissions using spend or industry averages, which is not enough to procure a precisely matched EAC volume. Demand is more likely to emerge first from value chain partner programmes where companies already know the facilities, electricity consumption and allocation basis involved. Second, the implementation hierarchy determines actions companies should take first. In places where it is feasible, activity-level action, such as energy efficiency programmes, comes first. EAC procurement should be considered after that. However, more often than not, EACs are the most practical option. Third, companies may ask value chain partners to procure renewable electricity themselves, fund procurement on their behalf, or buy and cancel eligible EACs against allocated value chain partners' consumption. Some of that activity will create genuinely new demand. Some will formalise procurement that value chain partners were already undertaking.

SBTi CNZS V2.0 creates a recognised pathway for addressing Scope 3 emissions, but companies will move at different speeds as targets are updated, value chain partner data improves and procurement processes are built. Therefore, expect a gradual increase in demand, rather than a single market-wide jump in February 2027.

Where will price pressure most likely appear?

You can expect to see the impacts most prominently in the sub-markets where buyers compete for a more limited supply of certificates, rather than an immediate rise in prices across the entire EAC market. Under the updated standard, Scope 3 (and 2) procurement is tied to deliverability region. This means buyers cannot just cover a global footprint with the cheapest available certificates in a connected registry system. They will need to procure an eligible supply of certificates.

This could fragment demand across local markets - large and liquid activity pools (the Nordics) may absorb additional buying with limited price movement, but smaller pools, markets with less eligible issuance, and regions where corporate supply chains cluster, could tighten more quickly. A buyer could therefore find very different prices for certificates that were previously priced similarly across its partner footprint. Certificates that also satisfy the required geography, reporting period and evidence standards may trade differently from older or less precisely matched supply.

The overall price will depend on the overlap between new buyer demand and eligible local supply. Technology, project age, vintage, activity pool, cancellation route and evidence requirements will all influence the final cost.

The certificate price is only part of the cost

Organisations will quickly discover that the manual work required to satisfy all of these requirements will be the main cost. Addressing a company's Scope 3 emissions often involves many value-chain partners, markets and small allocations. There is significant operational work involved and that will grow with each additional activity pool: coordinating partners, collecting electricity consumption data, calculating buyer's share, selecting the suitable certificates, arranging cancellations and retaining evidence. The work can grow exponentially.

As a result, the cost of managing this can grow even when the underlying price of the certificate remains the same. Registry access, local cancellation, partner coordination and documentation can matter as much - if not more - than the commodity price. Rather than placing dozens of disconnected orders on each market, aggregating the procurement under a single programme and combining that with automated operations can simplify the process and reduce costs substantially.

Our market view

CNZS V2.0 is more likely to reshape EAC demand than to lift every certificate price equally. The strongest effects should appear where three conditions overlap:

• companies can measure and allocate value-chain electricity;
• SBTi-aligned procurement creates demand that did not already exist; and
• the relevant activity pool has limited eligible supply.

In those markets, buyers may face tighter availability and a higher all-in procurement cost. Elsewhere, existing supply may absorb the new demand with little visible effect. The practical implication is that companies should map their value-chain partner's electricity exposure early. In addition to the amount of certificates needed, more emphasis will be placed on where they must come from and what evidence must travel with them.

Let Soldera help

Soldera is the unified infrastructure for global energy compliance. For Scope 3 value chain programmes, the platform brings EAC procurement, value-chain partner coordination, registry execution, local cancellation where available, and audit-ready evidence into one automated workflow. Corporate teams can source eligible certificates from 4,000+ renewable energy devices, connect each purchase to the relevant value-chain partner consumption, and preserve a clear record from allocation through cancellation without managing separate registry accounts country by country. Soldera supports teams on Scope 3 reporting that is aligned with SBTi CNZS V2.0. Corporate accounts can request access to Soldera's Scope 3 procurement features by emailing support@soldera.org or booking a demo.