While demand for clean energy remains high among voluntary corporate buyers, they face an increasingly difficult market landscape in which to make transactions. This challenge is exacerbated by uncertainty around future greenhouse gas accounting rules. Regardless of what shape these rules will ultimately take, CEBA respectfully calls on the Greenhouse Gas (GHG) Protocol to issue immediate and unambiguous guidance protecting contracts that are executed before the final revised Scope 2 Guidance takes effect.
Troubling signs of market contraction. The number of voluntary corporate buyers in the U.S. shrank by 40%, from 51 in 2024 to 31 in 2025, according to CEBA’s Deal Tracker. The number of new market entrants last year was also at its lowest level since 2016. This is troubling because a healthy procurement market needs broad participation from diverse buyers, from risk-taking innovators to fast followers, to collectively scale the market and meet the world’s decarbonization goals.
Proposed revisions to the Scope 2 Guidance are causing uncertainty. Voluntary buyers — from manufacturers to retailers to datacenter operators — are hesitant to sign long-term contracts in this already challenging market without assurance that today’s contracts will be honored for their full duration under the existing guidance. The GHG Protocol has indicated it is considering a legacy clause to exempt existing contracts from proposed new requirements, but the devil is in the details. And the details are slim. As a result, many buyers are already pausing new commitments.
GHG Protocol should provide urgently needed clarity. The accounting standard can provide certainty by declaring that it will recognize, and apply the current guidance to, all contracts that are executed before the new GHG Protocol’s Scope 2 Guidance takes effect, no matter what form the new guidance will ultimately take. Buyers are anxiously awaiting an assurance of continued recognition for the full life of executed contracts. The GHG Protocol should promptly offer this assurance.
