Educational note. This article is for education only. It is not investment, tax, accounting, or legal advice, and it is not an offer of advisory services from FG Capital Advisors.
RE100 Criteria Corporate Buyers Should Apply to EACs
RE100 technical criteria tell member companies, and any buyer that chooses to follow them, how to procure renewable electricity and how to define progress toward a renewable electricity target. For I-REC(E) and other energy attribute certificates, the practical tests are cancellation, market boundary, exclusivity and contract type. This article is written for corporate buyers, not for certificate issuers.
Why should a buyer start with the current RE100 criteria, not a vendor summary?
The RE100 technical criteria are the campaign rules member companies observe, and that other buyers often adopt as a screen. The March 2025 edition is the document cited here. Vendor one-pagers are useful only after the buyer has read the criteria, including exceptions and the market-boundary rule. A summary that omits those points is a procurement risk, not a shortcut.
In markets where energy attribute certificates are in common use, the criteria generally require cancellation of those certificates to support a grid-sourced renewable electricity claim, with limited stated exceptions such as some self-generation and certain direct-line supplies. Certificates must also be issued to generation located in the same market as the electricity supply being claimed. A volume purchased in another market will not automatically cover the buyer's load.
These tests sit beside, but are not identical to, GHG Protocol Scope 2 market-based reporting. How I-RECs enter an inventory is covered in the companion article on Scope 2 market-based accounting. Inventory process more broadly remains on GHG accounting support for companies and carbon project sponsors.
What should a purchase contract actually require?
The contract should require cancellation or redemption in the buyer's name, for a stated period and market, with exclusive attribute rights and a defined instrument type. It should also require device-level identification and a path to evidence if an assurer asks. Volume alone, without those clauses, is not a claims-ready purchase.
Unbundled certificate purchases are allowed under the criteria, but they are an additional cost on top of a separate electricity purchase. They should not be described as a bundled project contract or as a physical power purchase agreement. If the buyer wants project-specific, longer-dated supply, that has to be written in, not implied by a short unbundled trade.
Operational buying already has a live page at I-REC procurement for corporates. Instrument comparisons remain on I-RECs vs solar tax credits vs carbon credits and on renewable energy certificates. This article adds the RE100 quality screen those pages should be read against.
| Buyer test | What to require in the contract or confirmation | Common failure |
|---|---|---|
| Cancellation | Cancellation or redemption statement in the company's name, for the reporting period | Certificates left active in a seller or broker account |
| Market boundary | Generation located in the same market as the load being claimed, using a stated market definition | Buying cheap volume in a distant market and allocating it to another country's sites |
| Exclusivity | Warranty that the same attributes were not issued or sold in another system | Silence on double issuance |
| Instrument type | A clear statement that the sale is unbundled, bundled, or another defined structure | Calling an unbundled trade a power purchase agreement |
| Vintage and technology | Any tighter internal policy the buyer has adopted, written as a specification | Discovering after delivery that the board policy rejects the vintage |
How should buyers treat exceptions and tighter internal policies?
Exceptions in the RE100 criteria are narrow. A buyer should document why an exception applies, if it wants to rely on one, rather than assuming on-site generation or a green tariff is automatically exempt. A tighter internal policy, such as a shorter vintage window, can be added, but should be written into the purchase specification so sellers are not guessing.
Hourly or 24/7 matching is tighter again and should not be conflated with RE100 annual matching. If the company also buys carbon credits, those purchases stay on a separate policy track, such as high-integrity carbon credit procurement and carbon insetting vs offsetting for buyers. An I-REC cancellation does not perform that function.
What belongs in the buyer's evidence file at year end?
The year-end file should include the cancelled certificate register, market mapping to sites, contract confirmations, exception memos if any, and a reconciliation to the market-based Scope 2 working papers. It should be ready for assurance, not assembled after the assurer asks. Gaps discovered in February are usually supply problems that started as loose contract language in the prior spring.
This article is educational. It is not a certification that any purchase meets RE100, and it is not a substitute for the current technical criteria or for the company's own assurance process.
Frequently asked questions
Do RE100 criteria require cancellation of I-RECs in every case?
In markets where energy attribute certificates are in common use, RE100 generally requires cancellation to support a grid-sourced renewable electricity claim. The criteria list limited exceptions, including some self-generation and certain direct-line supplies. Those exceptions are narrow. A buyer should read the current criteria before treating a supply as exempt.
Can a company use I-RECs issued in one market against load in another?
Generally no, if the company wants a claim that meets RE100 technical criteria. Certificates must be issued to generation located in the same market as the electricity supply being claimed. Volume bought in a different market may still be a valid instrument there, but it will not automatically cover the buyer's load elsewhere.
Is an unbundled I-REC purchase the same as a power purchase agreement?
No. An unbundled energy attribute certificate purchase is separate from the electricity supply. It can support a claim if the criteria are met, but it is not a bundled project contract and it is not a physical power purchase agreement. Contracts should say which structure is being used, in plain terms.
Does meeting RE100 mean the Scope 2 inventory is automatically complete?
No. RE100 is a renewable electricity campaign standard. Scope 2 reporting under the GHG Protocol still requires location-based and, where applicable, market-based inventories, with Quality Criteria applied to contractual instruments. A company can have work to do on one track even if it is confident on the other.
Should carbon credits be bundled into the same RE100 purchase?
No. Carbon credits and energy attribute certificates support different claims. Carbon credit procurement should follow a separate policy and a separate register, such as the company's high-integrity procurement process. Cancelling an I-REC does not retire a carbon credit, and retiring a credit does not meet RE100 electricity-attribute tests.
What evidence will an assurer usually want to see?
Typically a cancellation or redemption statement in the company's name, device and market information, period alignment with consumption, exclusivity wording or equivalent evidence, and a reconciliation to the market-based inventory. If the buyer relied on a criteria exception or a tighter internal policy, that memo should be in the file too.
