For more than two decades, corporate renewable electricity procurement has largely operated on an annual basis. A company could calculate its electricity consumption over a year, purchase an equivalent volume of Renewable Energy Certificates, or RECs, and use those certificates within market-based Scope 2 reporting where the applicable accounting rules were met.

That model is now being tested.

Across tax policy, corporate target setting and greenhouse gas accounting, electricity claims are increasingly being examined not only by how much renewable electricity was generated, but also by when and where it was generated. The shift is creating demand for hourly energy data, more geographically relevant procurement and certificates carrying more detailed information about the underlying generation.

Hourly matching has not become a universal corporate requirement. In the United States, however, it has already moved beyond a voluntary concept in one major federal policy. At the same time, the Science Based Targets initiative has introduced mandatory hourly performance reporting for certain large users, while the GHG Protocol continues to consider hourly matching as part of its Scope 2 revision.

The direction is clear. The final accounting model is not.

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45V makes hourly matching a regulatory requirement

The strongest evidence that granular electricity accounting is moving into regulation comes from the Section 45V Clean Hydrogen Production Tax Credit.

Treasury and the IRS finalized the 45V regulations in January 2025. For hydrogen producers using Energy Attribute Certificates, the rules require qualifying certificates to satisfy incrementality, temporal matching and deliverability requirements.

Annual matching remains permitted through 2029. From January 1, 2030, qualifying EACs generally need to represent electricity generated in the same hour that electricity is consumed for hydrogen production. The requirement applies to qualifying production represented by EACs from 2030 regardless of when the hydrogen facility entered service.

Under 45V, time is not simply additional information attached to the certificate. It becomes part of determining whether the electricity attribute can support a federal tax credit.

The regulations also require geographic deliverability. In general, the electricity generator and hydrogen production facility need to be in the same qualifying grid region, although certain interregional transfers can qualify. A certificate therefore cannot be evaluated only by technology and volume. Location and timing matter as well.

The IRS acknowledged that many existing EAC registries did not yet generally provide the hourly functionality required by 45V when the rules were finalized, but concluded that the market had sufficient time to develop the necessary systems before 2030.

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Corporate Scope 2 is moving in the same direction

The GHG Protocol is considering a similar shift for corporate electricity accounting, but its proposed changes are not yet final.

In 2025, the GHG Protocol published proposed revisions to its Scope 2 Guidance. The proposed market-based method would require contractual instruments used for qualifying market-based claims to be matched to consumption on an hourly basis and sourced from generation considered deliverable to the consuming load.

The proposal also included feasibility measures such as load profiles, potential exemptions for smaller organizations, legacy treatment for existing contracts and phased implementation.

Those proposals triggered substantial feedback. The GHG Protocol reported in July 2026 that its Scope 2 consultation received nearly 1,100 responses from 56 countries and revealed materially different views about electricity procurement and how its effects should be represented in corporate inventories.

Companies should therefore not treat the 2025 hourly matching proposal as the final Scope 2 rule.

The GHG Protocol is now exploring multiple reporting approaches while it works with ISO on a consolidated corporate greenhouse gas accounting standard. A combined public consultation is planned for Q2 2027, with publication targeted for Q4 2028.

For corporate buyers, hourly matching is clearly part of the future Scope 2 debate, but the exact requirement, exemptions and implementation schedule remain unsettled.

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SBTi has moved further, but stopped short of mandatory hourly procurement

The final SBTi Corporate Net-Zero Standard Version 2.0, released in June 2026, provides another signal.

SBTi has strengthened its requirements for low-carbon electricity procurement around three principles: near, new and now.

Near means market instruments should correspond to generation that could plausibly serve the electricity load. New generally means the underlying project should be no more than 15 years old, subject to exceptions. Now addresses the timing of generation relative to consumption.

SBTi states that annual accounting does not fully reflect the round-the-clock requirements of a decarbonized electricity system and identifies hourly matching as a potential mechanism for creating stronger signals for storage, transmission and flexible clean generation.

However, Version 2.0 does not make hourly matching mandatory for target progress.

Companies using market instruments must continue to meet an annual matching requirement, with procurement matched to consumption within a maximum 12-month period. At the same time, Category A companies with significant electricity consumption are required to publicly report their hourly matching performance. Companies achieving specified hourly matching levels can also receive voluntary recognition.

This creates an intermediate stage between annual procurement and mandatory 24/7 matching. Large companies may have to measure and disclose hourly performance before they are required to close every hourly gap.

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The certificate infrastructure is already changing

The accounting debate would have limited practical relevance if certificate registries could not provide more granular data. That infrastructure is beginning to exist.

PJM Environmental Information Services already provides hourly, time-stamped functionality through the Generation Attribute Tracking System. GATS users can view hourly generation data for eligible PJM generators and convert monthly certificates into hourly certificates at retirement.

The IRS cited the development of hourly functionality across EAC registries when determining that a 2030 transition for 45V was feasible.

EnergyTag has also developed a Granular Certificate framework intended to standardize certificates containing time-specific generation information. Its registry specification covers the creation, transfer and cancellation of Granular Certificates, while its matching framework addresses the relationship between granular generation certificates and consumption.

This does not create one universal North American hourly certificate market. Existing REC systems remain fragmented by registry, geography and use case. What it does create is technical capability.

The market is moving from whether hourly certificates can exist to how they will be used, valued and recognized.

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Hourly procurement changes what a REC portfolio looks like

Annual matching can treat a megawatt-hour generated on a sunny afternoon as equivalent, for annual volume matching, to electricity consumed late at night.

Hourly accounting removes that assumption.

A company with a solar-heavy procurement portfolio may have strong clean electricity coverage during daylight hours and significant gaps after sunset. Wind, hydro, nuclear, geothermal, storage and other resources can therefore have different value depending on the consumption profile being matched.

Buyers may need combinations of technologies rather than a single annual REC contract. PPAs may need to be assessed against hourly load rather than annual consumption alone. Storage can become relevant not only to electricity prices and grid balancing, but also to environmental attribute matching. The 45V rules explicitly recognize storage as part of temporal matching where the required tracking and verification conditions are met.

Geography also becomes more important. Both 45V and the proposed GHG Protocol approach link stronger claims to electricity that is physically relevant or deliverable to the consuming load. That could reduce the usefulness of strategies based mainly on sourcing the lowest-cost eligible certificates from broad markets.

Granularity can also create differentiated environmental commodity values. If buyers need clean attributes during particular hours and within particular grid regions, scarcity will differ by time and location. An hourly certificate generated during abundant solar production may not carry the same commercial value as an eligible certificate available during a difficult evening or overnight hour.

Trading initiatives are already being developed around this principle. The Granular Certificate Trading Alliance is working on infrastructure intended to support trading and settlement of hourly carbon-free electricity attributes and increase price transparency by time and location.

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What companies should do now

Corporate electricity buyers do not need to abandon annual RECs because hourly matching may become more important. They do need to understand whether their current procurement structure can evolve.

Companies should establish whether electricity consumption data is available hourly and can be mapped to facilities, utilities and grid regions. They should review whether suppliers and registries can provide time-stamped generation information with clear ownership and retirement records.

Long-term PPAs and certificate contracts should also be examined for flexibility. Contracts signed today may remain active when the GHG Protocol's revised corporate standard is published and when 45V hourly matching begins.

Procurement teams should avoid treating all hourly strategies as equivalent. A voluntary 24/7 target, an SBTi reporting requirement, a future GHG Protocol Scope 2 rule and the 45V tax-credit requirements may use similar concepts without applying identical eligibility criteria.

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The commercial impact

Hourly electricity accounting is no longer theoretical.

For U.S. clean hydrogen, it is already embedded in federal tax rules with a 2030 implementation date. For SBTi companies, hourly performance reporting is entering the corporate target framework. For GHG Protocol users, hourly matching remains under development and could still change before the consolidated standard is finalized.

That combination is enough to change procurement planning now.

The next phase of the REC market is likely to place greater value on data, geography, timing, registry capability and the relationship between generation and actual consumption. Annual volume will remain important, but it may no longer provide all the information required for every climate claim or regulatory use.

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AFS Commodities works with corporate buyers across renewable electricity and environmental commodity markets. If your organization is reviewing REC procurement, preparing for more granular Scope 2 reporting or assessing how hourly matching could affect future electricity purchasing, contact AFS Commodities to discuss the market structures, certificate options and procurement strategies available.