RECS sets Full Consumption Disclosure and GHG Protocol Scope 2 harmonisation as core EAC market advocacy for 2026

RECS International's 2025 Annual Report sets out the association's certificate-market advocacy programme and signals its continuation into 2026. In 2025 RECS advocated that EU law should require all Member States to implement Full Consumption Disclosure (FCD) — cancellation of an Energy Attribute Certificate for every unit of energy consumed — going beyond the current Renewable Energy Directive provision that allows Member States to introduce FCD at their discretion. RECS responded directly to the GHG Protocol's late-2025 public consultation on revised Scope 2 Guidance, published a skeleton response and a consultation guide, and states its early complaint about the consultation length contributed to securing an extension for all stakeholders. RECS raised concerns that the draft Scope 2 proposals ignored the structure of the European Single Market and maligned the transparency and accuracy of current EAC systems. It published 'Matching Matters' setting out its position on annual matching and the differences between power and attribute markets, plus a Position on Corporate Disclosure Standards and Regulations with an assessment by the Hamburg Institute. RECS led a Standards Harmonisation Circle following the announced ISO/GHGP partnership to align revised Scope 2 Guidance with ISO 14064-1, with revised texts expected in 2027. Three member working groups ran in 2025: Corporate Disclosure Regulations and Standards; UK REGO Users Group; and EAC User Insights & Registry Improvements. Preliminary results of a registry user insights survey (for a benchmarking table) were presented at the AIB/RECS Open Markets Committee in Dessau on 21 May 2025, with final results to be published in 2026; the UK REGO working group's policy recommendation paper will also be published in 2026. RECS reports monitoring the stalled Green Claims Directive, the reduced-scope CSRD and EFRAG's ESRS E1/VSME work, and the Battery Regulation carbon footprint methodology, whose draft uses a location-based electricity approach without recognising contractual instruments and whose delegated act was expected in 2025 but is not yet finalised. Membership reached 130 (100 standard, 17 small, 13 non-profit) with ten joiners in 2025 and four confirmed for 2026 (Climera, S&P Global, BKW Energy, EEX).

Guarantees of Origin and other EACs are the contractual instruments through which corporate renewable demand is expressed, and their commercial value depends almost entirely on whether disclosure and carbon-accounting rules recognise them. The GHG Protocol Scope 2 revision and its alignment with ISO 14064-1 will determine whether market-based (contractual) claims with annual matching remain valid or are displaced by location-based or tighter temporal/deliverability matching requirements — a design question with direct price-formation consequences for the European GO market, where the report notes historical surplus and low prices but also evidence of price elasticity (GOs averaging 4-5 EUR/MWh over an 18-month period in 2022-2024, higher REGO prices in the tighter UK market, and I-REC solar around 25 USD/MWh in Singapore). Full Consumption Disclosure is the demand-side design lever: mandatory cancellation of a certificate for every unit consumed would convert a voluntary market into a near-universal one, absorbing surplus and materially tightening supply-demand balance. That RECS is pushing for FCD to be mandatory under the next Renewable Energy Directive within the 2040 climate and energy package places the issue squarely in the EU legislative pipeline. Simultaneously, the Battery Regulation carbon footprint methodology is a live example of EU secondary law defaulting to location-based accounting and excluding contractual instruments — a precedent that, if replicated, would erode EAC demand from product-level regulation.

This is an industry-association advocacy record rather than a regulatory decision, and should be tracked as an input to two distinct design processes rather than as a design change itself. Read carefully, the report exposes the central unresolved tension in certificate market design: the supply-side instrument (the GO, harmonised through the Renewable Energy Directive and CEN EN 16325) is being judged by a demand-side accounting standard (GHGP Scope 2 / ISO 14064-1) written outside the EU legislative process and without an obligation to respect single-market structures. RECS's explicit complaint — that the draft Scope 2 proposals 'ignored the structure of the European Single Market' — is the crux: annual, bidding-zone-agnostic matching is coherent with a market where GOs are freely tradable across the EU, but incoherent with an accounting philosophy that wants claims to approximate physical delivery. Whichever way the 2027 revised texts land, the effect on European GO price formation will be larger than most electricity market reforms tracked in this domain, because it changes who is permitted to buy and for what purpose. Second, the FCD demand deserves attention as a genuine market-design proposal, not just lobbying. Moving from the current RED discretionary provision to a mandatory obligation would eliminate the residual-mix escape route for suppliers and force cancellation volume to converge on total consumption, structurally clearing the surplus that has depressed prices. That has an obvious commercial logic for RECS members, but it also has a real efficiency argument: an untracked residual mix weakens the investment signal the certificate is meant to carry. The counter-argument — that mandatory cancellation is effectively a consumption levy with regressive incidence and questionable additionality — is not addressed in this source, and any serious assessment should treat FCD as contested. Third, the registry user insights survey and benchmarking table, plus the UK REGO working group's engagement with the UK Government and regulators on registry functionality, point at a less glamorous but practically important layer: registry interoperability, issuance latency and cancellation processes are the operational plumbing that determines transaction costs. Benchmarking issuing bodies against each other is a mild but effective accountability mechanism, and the 2026 publication of final results is worth watching. Fourth, the Battery Regulation delegated act is the sleeper item. If the EU itself adopts a location-based-only methodology for battery carbon footprints, it creates internal inconsistency with the RED's GO framework and hands the GHG Protocol a precedent. RECS notes it is unfinalised after slipping from 2025. Caveats: this is a self-reported annual report from an advocacy body, so claims about influence (for example securing the consultation extension) are the association's own characterisation; no regulatory outcome is decided here; and most underlying publications are member-only, limiting independent verification.

Renewable Energy Directive (Guarantees of Origin provisions, including the discretionary Full Consumption Disclosure provision); prospective next Renewable Energy Directive under the EU 2040 climate and energy package; Corporate Sustainability Reporting Directive and EFRAG ESRS E1 / VSME; Green Claims Directive (stalled); EU Battery Regulation carbon footprint delegated act; GHG Protocol Scope 2 Guidance and ISO 14064-1; CEN EN 16325; ISO 13659, ISO 13662, ISO 22095, ISO 14060-2, ISO 14077; SBTi Corporate Net Zero Standard

RECS Annual General Meeting 2026 · 20 Apr 2026

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