EAC buyers guide to geographic matching, activity pools and deliverability regions under SBTi CNZS V2.0

SBTi’s new Corporate Net Zero Standard (CNZS) V2.0 , if you haven’t heard already, is set to rework how geographic matching will occur. This article is a comprehensive guide to new pieces of core jargon that sustainability teams and corporate renewable buyers should understand in full: activity pools and deliverability regions .

This article introduces the concept of an activity pool, and subsequently, how deliverability regions are the new primary geographical concept that determines eligible Energy Attribute Certificate (EAC) sourcing . Meaning, from where an EAC can be sourced relative to energy consumption. We break down the exact building blocks of what makes an EAC deliverable, as under SBTi, deliverability is now one of a few deciding factors as to what counts as legitimate EAC usage for a company’s Scope 2 target implementation. Whilst this article will focus specifically on deliverability, for wider context around the latest CNZS iteration, you can see our full write up here .

First, the bundled vs unbundled groundwork

Note that SBTi’s CNZS V2.0 does not prohibit unbundled EAC procurement at all. However, because many points of this article are inexorably linked to physical energy deliverability across regions, bundled procurement via a physical PPA is the de-facto standard in these instances, with unbundled EACs in-practice constrained to use within their activity pools of origin only (due to a lack of physical energy transfer). Booking physical transfer capacity between activity pools does not, by itself, make an unbundled EAC issued in the first activity pool valid for use.

What does SBTi actually mean by an activity pool?

EAC buyers following the LCE alignment targets pathway (increasing the percentage of low-carbon-electricity used) need to understand activity pools . The V2 Criteria sets the requirement - companies are asked to set an activity pool boundary at the smallest reasonable geographic or operational level, explaining why that boundary is reasonable. Activity pools should therefore be understood before qualifying EAC cancellations can take place.

Activity Pool :

A shared system of activities that serves the reporting entity, defined at the smallest system boundary within which the specific activity or activities serving the company cannot feasibly be identified. Examples include gas grids (scope 1), electricity grids (scope 2), supply sheds (scope 3), and logistics networks (scope 3) (adapted from Brander & Bjørn, 2023 and the VCI, 2025 ).

The easiest way to understand this specifically for Scope 2 is simply that, based on their consumption locations, organisations can have multiple activity pools and that these activity pools map individually to boundaries of various deliverability regions, explained below.

So, what is a deliverability region?

The SBTi Glossary defines both deliverability, and deliverability region. Note that these definitions are not absolutely final, as deliverability regions may experience targeted revisions upon conclusion of the GHG Protocol revision process.

Deliverable (Electricity):

A source of electricity generation that can serve a specific source of electricity consumption (adapted from GHG Protocol, 2025 ).

Deliverability (Electricity):

The ability of a source of electricity generation to serve a source of electricity consumption ( adapted from GHG Protocol, 2025 ).

Deliverability Region (Electricity):

A geographical area throughout which all sources of electricity generation connected to a synchronous grid can reasonably be expected to serve sources of electricity consumption connected to that grid.

A deliverability region balances the following aspects of an area in the electricity system: (i) synchronous grid boundaries; (ii) transmission congestion; and (iii) regional connectivity ( adapted from GHG Protocol, 2025 ).

Broadly, for Scope 2 an activity pool means a deliverability region, and in Europe the best available proxy for a deliverability region is the individual bidding zone. SBTi didn’t end up making this an explicit link, but nothing more granular exists in market structure.

Treating each European bidding zone as a separate deliverability region, and therefore a separate activity pool, is the default assumption that validators are most likely to accept, though it remains your assumption (and your burden) to justify rather than a clear-cut, SBTi-designated boundary you can defer to.

The final CNZS V2.0 does not itself publish a definitive map of global deliverability regions, so when working out their activity pools, buyers will need to conduct their own operational mapping and include any assumptions and the evidence used. The following breakdown is designed to make this process easier by breaking down the definition of deliverability region, one aspect at a time.

Deliverability Region Aspect 1: What is grid synchronicity?

Grid Frequency: Crucial context to the definition above, electrons don’t flow in wires in a linear path from generator to consumption point. They’re constantly moving back and forth, which is known as an alternating current. When more energy is injected into the grid, the goal is to maintain the target frequency - this is the rate at which the electrons alternate back and forth, measured in hertz. Electricity grids have a target frequency, and when two or more grids share the same electrical frequency (e.g. 60 Hz) and are phase locked, this is known as synchronicity. The market that exists solely to keep the grid stable is known as the balancing market .

European Context: In Europe, whilst all grids operate at 50 Hz, they are not all phase locked together. To see a map of synchronous zones, see here . In mainland Europe, the Continental Europe Synchronous Area , would be considered by SBTi to be a wide-area synchronous grid , but it’s not enough by itself to justify deliverability, as it can only suitably meet Aspect 1 of the definition of a deliverability region. It itself contains deliverability regions - valid EAC sourcing must occur in a manner that respects the full definition, contingent on respecting aspects 2 and 3 respectively - keep reading.

Deliverability Region Aspect 2) What is transmission congestion?

Congestion & Bidding Zones: You can think of transmission congestion as when the physical power lines have their transmission capacity come under stress. SBTi considers this relevant because it reflects a physical constraint affecting the physical deliverability of energy within a wide-area synchronous grid . After all, the physical limits that govern wide-area synchronous grid infrastructure are the reason that bidding zones (a type of commercial subdivision) exist, each showing different wholesale power prices whenever congested capacity conditions arise. Wholesale power markets include forward contracts, day-ahead & intraday.

Bidding Zones as a Proxy for Deliverability Regions: SBTi makes it quite simple for energy and EAC buyers: bidding zones are already built to segment synchronous grids by structural congestion. As a result, same-bidding-zone purchases are a sensible starting proxy for avoiding it altogether, so long as the company can explain why this boundary is the smallest reasonable deliverability-based system. You can see European electricity bidding zones here . The actual SBTi boundary still remains the deliverability region , which may not always map one-for-one in either direction, and internal congestion within a bidding zone can still exist, so it is still a proxy rather than a formally designated boundary. It's your call - individual zones can be highly congested (making the true region smaller than the zone), and high levels of regional connectivity within the same synchronous grid can see neighbouring zones effectively be unconstrained (making it larger). SBTi has left this up to you to justify.

Impact on Unbundled EAC Validity: Assuming widespread, valid use of the bidding zone proxy moving forward: If you’d like to match EACs across bidding zones , unbundled EAC procurement becomes practically impossible, and a physical PPA becomes the practical default, because you’re expected to prove the transmission/interconnector rights between those bidding zones.

Proving Transmission: When proving, both EAC issuance and physical energy transmission must occur within ±12 months of the underlying electricity consumption, unless longer timeframes are justified, e.g. by established vintage rules. This is also not considering any independent requirements and options for hourly reporting and hourly matching respectively, detailed fully within CNZS. As for transmission evidence, SBTi has not yet published a closed or exhaustive list of acceptable documentation, but this proof is likely to take the following industry-standard formats:

• Physical Transmission Rights (PTRs): Valid PTRs demonstrate that physical cross-border transmission has taken or will take place. Any documentation used will most credibly show that they are formally nominated for delivery or physically settled/delivered, rather than merely allocated, left unexercised, or settled financially. PPAs that explicitly secure transmission capacity are also likely to be accepted.
• TSO Settlement Proofs: If after-the-fact, official grid records can be used as proof, provided they verify that energy schedules were physically allocated across the interconnector during the specific consumption period.

Deliverability Region Aspect 3) What is regional connectivity?

This aspect is split in two equally important considerations.

1. Physical Connectivity: On top of the wide-area synchronous grids defined in Aspect 1, and the bidding zones arising from transmission congestion defined in Aspect 2, entire wide-area synchronous grids can themselves be interconnected, an example being Northern and Mainland Europe. Unlike the AC connection described in Aspect 1, regional connectivity typically uses High-Voltage Direct Current (HVDC) cables to bridge distinct market zones. For buyers, physical linkage can be checked to confirm that two zones are linked. Similarly to as described in Aspect 2, physical connectivity must be proven. For avoidance of doubt; specific proof of transmission rights across HVDC links and independent systems will be required.
2. Market Instrument Alignment: EAC usage across multiple pools is permissible so long as they stay within their regulatory boundaries - it must be legally permissible to transfer them across the regions that energy is flowing as per the physically linked grid regions detailed above. An EAC must be validly issued, transferred and retired through a secure tracking system that prevents double counting. In Europe, AIB-Hub connected registries following the European Energy Certificate System are the standard here*. Soldera offers a hosted account that works with all AIB-Hub connected registries, so you don’t need to open or operate individual accounts in each registry.

*Note that Iceland and Cyprus have no HVDC links to Europe, so despite AIB-Hub connection , exported Icelandic and Cypriot EACs are not considered AIB-Grid connected , and are therefore not permissible for use under Aspect 3 of SBTi’s deliverability region requirements. The reverse (EAC imports to both islands) is also incompatible with CNZS V2.0, due to their ‘islanded’ market status.

So now that you understand how deliverability regions are formulated, what is the impact of CNZS V2.0?

Because electricity consumption can only be matched with EACs originating from within the same deliverability region as the point of consumption, SBTi CNZS V2.0 effectively mandates explicit local matching (defined by deliverability-based activity pools) bar a few exceptions.

What exceptions apply?

There are a few carve-outs for strict deliverability region matching in the criteria depending on the situation. These exceptions loosely map to the aspects of the definition explored before, alongside commercial exceptions designed to make life easier for consumers. If EACs are affected by any of the following conditions, then strict deliverability region matching isn’t a hard requirement.

• Contract Grandfathering : If you signed a long-term contract (most commonly a PPA ) and had applied its EACs to your activity pools before the effective date of 1 February 2027 , you can continue to use the EACs from that contract in those same activity pools, allocated on a load-weighted basis, until the contract ends. The deliverability validity of these contracts is considered to be "grandfathered" for the contract duration , meaning they do not need to adhere to new deliverability region rules. You won't be able to renew those contracts under old rules, however, and you can't add new activity pools to a grandfathered contract.
• New Capacity = Single-PPA Allowed : For companies with load that spans two or more interconnected activity pools within the same wide-area synchronous grid (Return to aspect 1 of the definition of deliverability region for a recap), you’re allowed to use one LCE PPA from any of the activity pools where your operations are located and you’re also not required to prove transmission rights for each transfer. But this rests on a few things being true.
  • 1) Offtake under the PPA must begin within 36 months of the project commissioning.
  • 2) Associated EAC usage across multiple pools is permissible so long as they stay within their regulatory boundaries.
  • 3) The PPA itself must cover the combined consumption across those activity pools, rather than a fraction of the load.
• Sector Level Procurement: SBTi know that sometimes it’s impossible to procure verifiable low-carbon energy within a specific grid region. Whilst cost alone is not a valid structural constraint, if you’re able to evidence that sufficient LCE cannot be contracted within the activity pool or interconnected regions during the target timeframe, along with demonstration of your steps towards remedying the shortfalls in your area, you are exempt from deliverability constraints. As a result, you may use sector level procurement (meaning, outside of your activity pool, but within a systemically relevant electricity system) only for as long as the structural constraint persists. The Basis for Conclusions provides background as to why SBTi landed here; as it became increasingly apparent from the feedback of various consultations that strict local matching requirements could be unworkable in supply-constrained systems.

What should SBTi-aligned EAC buyers do now?

1. Don’t be in denial: Firstly, recognise that these requirements are real and binding if you want to meet V2.0 targets. Just because EACs can be transferred to your target registry, doesn’t mean they are viable under SBTi. Cheap remote certificates may still be importable and alluring, but they will fail the SBTi deliverability tests for a particular activity pool without a legitimate exception. Don’t expect to get away with making no changes to your current procurement strategy and not get caught out.
2. Possible ≠ permissible: Registries won’t change how they function just because SBTi sets stringent rules. This is especially important for Guarantees of Origin in Europe, where registry interoperability can make cross-border transfers feel simple, even if private standards like SBTi won’t accept EAC cancellations that fall below their eligibility criteria.
3. Realise that deliverability is just one requirement that EACs must meet: V2.0 introduced changes to generator age requirements, LCE eligible technologies, and hourly reporting. Our full guide explores these here .
4. Start preparing your systems now: Whilst validations start in 2027 with a hard stop for V1.3.1 target submissions on 31st January 2028, don’t wait that long to prepare. Sustainability teams need to start defining their activity pools - which means understanding if their organisational consumption is spread across deliverability regions using the definitions outlined in this article, and preparing their EAC procurement channels appropriately.

Let Soldera help.

Let Soldera automate your SBTi procurement requirements. We can help with defining your activity pool and automatically mapping your cross-border consumption against viable EACs. Our software-native approach provides market access to the unbundled EACs of 4000+ production devices currently using our platform to make sales, so no matter which deliverability regions your consumption spans, we can certainly help. And if you're procuring through PPAs, Soldera manages the EAC operations within your PPA too, with our Registry Bridge infrastructure automatically cancelling incoming certificates in the correct local registry per activity pool. From one platform, you can export audit-ready primary documentation sourced from any number of local registries.

Book a demo if you want to stress-test your Scope 2 procurement against V2.0 criteria without spending hours on manually filtering for the certificates you need.