RE100 Technical Criteria — The Definitive Reference

Executive Summary

RE100 is the leading global corporate renewable electricity initiative, jointly led by the Climate Group and CDP and operated under a single rulebook — the RE100 Technical Criteria — that translates the high-level pledge of “100% renewable electricity” into a set of audited, comparable technical requirements. As of early 2026, RE100 has more than 440 corporate members representing combined annual electricity demand of approximately 570 TWh — enough that the membership, treated as a single jurisdiction, would rank as the world’s tenth-largest electricity consumer.

The criteria address the four questions that make or break the credibility of any renewable electricity claim. What counts as renewable? — five technology classes, with biomass and hydropower additionally subject to sustainability requirements. How is consumption matched to generation? — through retired Energy Attribute Certificates (EACs), sourced from the same market as the consumption, with vintage limits. Which assets qualify? — under the 1 January 2024 update, at least 85% of procured renewable electricity must come from assets commissioned or repowered within the preceding 15 years. Where can the renewable electricity come from? — operative market boundaries that, in Europe, were narrowed in 2024 to align with the AIB membership and the EU single market.

What RE100 Is

RE100 is an initiative, not a standalone standard. It is a corporate leadership campaign with a single technical rulebook attached to it, the RE100 Technical Criteria, which functions as the standard against which member claims are assessed. The distinction matters for three reasons.

First, RE100 membership is voluntary, gated by eligibility thresholds, and revocable. Companies that fail to meet the criteria over time are not penalised financially, but their public-facing status changes, and their progress is published transparently in the annual disclosure report. Second, the criteria themselves are operated independently of the membership process: the Technical Advisory Group sets the criteria, the membership accepts them as a condition of joining, and CDP operates the annual reporting platform that ingests member data and applies the criteria to assess claims. Third, RE100 sits on top of, rather than replacing, the GHG Protocol Scope 2 accounting framework. A company can be RE100-compliant and still have non-zero market-based Scope 2 emissions reported under the GHG Protocol — the two systems answer related but different questions.

Why RE100 Exists

RE100 was launched at Climate Week NYC in September 2014 to mobilise corporate buying power behind the global energy transition. The premise was straightforward: the world’s largest corporate electricity consumers, acting in coordinated demand, could send a signal strong enough to accelerate renewable capacity deployment, drive down costs, and influence policy. In the absence of an initiative like RE100, individual corporate renewable claims existed in silos, with no consistent way to compare ambition across companies, technologies, or geographies.

The technical criteria exist to close the comparability gap. They define exactly what a member must do to claim use of renewable electricity — which sources qualify, which instruments evidence procurement, which boundaries apply, and which year the claim must align with. Without the criteria, “100% renewable electricity” would mean different things across the membership; with them, the claim has a shared technical specification that auditors, regulators, journalists, and investors can interrogate.

The criteria have grown in importance as adjacent frameworks have come to depend on them. SBTi Corporate Net-Zero Standard Scope 2 requirements, CSRD ESRS E1 energy and emissions disclosure datapoints, IFRS S2, and the U.S. SEC climate-related disclosure rule all reference renewable-electricity sourcing, and all draw — directly or indirectly — on the conceptual architecture that RE100 helped formalise.

Version History and the January 2024 Update

The RE100 Technical Criteria are revised approximately every two years to reflect evolving market practice, advances in measurement technology, and lessons from the annual disclosure cycle. Treating the criteria as static is the single most common technical error made by sustainability teams returning to RE100 after a multi-year absence — the requirements that applied in 2021 are not the requirements that apply today.

Governance: Who Owns the Criteria

RE100 is operated jointly by the Climate Group and CDP. The Climate Group acts as the secretariat — recruiting members, running policy advocacy, publishing reports, and convening governance. CDP operates the annual disclosure platform, ingesting member data through the corporate questionnaire and producing the annual disclosure report that is the primary public record of member progress.

The Technical Criteria themselves are set by the RE100 Technical Advisory Group (TAG), a body of subject-matter experts drawn from across the EAC market, corporate procurement, climate policy, and adjacent standards bodies. The TAG develops proposed criteria changes through public consultation — most recently the 2024 consultation that closed on 27 May 2024 — and submits them to the RE100 Project Board for approval. The criteria document published by the Climate Group is the authoritative reference; CDP applies the criteria during the annual reporting cycle to assess member submissions.

This governance separation matters for the credibility of the criteria. The body that writes the rules (the TAG) is independent of the body that applies them to specific submissions (CDP), which in turn is independent of the body that runs the membership relationship (the Climate Group). The architecture mirrors the broader pattern in voluntary climate standards — for example, the separation between SBTi as standard-setter and SBTi Services as validator.

Membership Eligibility and Thresholds

RE100 is not open to every company. The initiative is designed to mobilise large electricity buyers whose demand signal is consequential to the renewable energy market, and the eligibility criteria are set accordingly.

Eligibility thresholds

• Annual electricity consumption ≥ 100 GWh. The primary eligibility threshold for global membership. A company with annual electricity demand at or above 100 GWh is eligible to apply. This threshold reflects the initiative’s focus on companies whose procurement is large enough to materially shift renewable energy markets.
• Significant market influence below the threshold. Companies below 100 GWh may still be eligible if they are recognisable Fortune 1000 names, sector leaders, or otherwise positioned to drive policy and procurement change beyond the volume of their own demand.
• Sector exclusions. Companies whose primary business is fossil-fuel extraction, generation, or distribution are excluded. The exclusion preserves the initiative’s role as a corporate buyer signal for renewable supply, rather than a vehicle for fossil-fuel companies to make renewable claims through their own electricity consumption.

What members commit to

Every member, on joining, commits to four things: (1) reaching 100% renewable electricity by a self-selected target year not later than 2050, (2) setting and reporting interim targets compatible with the headline trajectory, (3) annual disclosure through the CDP corporate questionnaire, and (4) sourcing in line with the operative Technical Criteria.

The commitment is voluntary and revocable, but membership status and progress are public. Companies that miss targets, fail to disclose, or fall outside the criteria appear in the annual disclosure report with their reported and verified performance side by side — a transparency mechanism that is itself a key part of the initiative’s accountability architecture.

Target-Year Rules and the 2050 Backstop

RE100 members select their own target year for reaching 100% renewable electricity, subject to a backstop and a structure of interim milestones designed to prevent back-loaded ambition.

The 2050 backstop

For companies joining RE100 today, the latest acceptable target year for reaching 100% renewable electricity is 2050. This is a backstop, not a recommendation — the average target year across the membership is materially earlier (around 2030–2031 in recent annual disclosure cycles), and companies in markets with mature renewable infrastructure routinely commit to 2025 or 2030.

Interim milestones

To prevent the 2050 backstop from becoming a vehicle for delayed action, RE100 expects members to align with interim milestones along the way. The standard reference points are 60% by 2030 and 90% by 2040 for companies setting later target years. Members may set milestones at other levels but are expected to demonstrate a credible trajectory that does not back-load reductions to the final years before the target.

Bringing the target forward

Members may bring their target year forward at any time. In recent annual disclosure cycles, dozens of members have done so, sometimes by multiple years. Pushing a target year backwards is technically permitted in narrow circumstances but is treated as a material change that requires written confirmation and is reflected in the public progress table. Companies considering pushing a target year back should expect the change to attract scrutiny.

The 100% Requirement: What It Actually Means

“100% renewable electricity” sounds self-explanatory. In practice, it answers three nested questions, each of which the Technical Criteria address.

100% of what?

The denominator is the company’s electricity consumption across its operational control boundary, as defined under the GHG Protocol Corporate Standard. Where a company has elected the financial control consolidation approach for its broader inventory, the same approach applies to RE100 reporting. Leased buildings where the lessee has operational control of the electricity supply are included; leased buildings where the landlord controls supply are excluded. Heat and cooling derived from on-site combustion or fuel use are not in scope of RE100 — RE100 governs renewable electricity, not renewable energy more broadly.

Matched how?

Annual matching, currently the dominant approach, requires the volume of renewable electricity claimed (evidenced by retired EACs or self-generation with retained attributes) to equal or exceed the total volume of consumption over the calendar year, market by market. Hourly matching — known in industry shorthand as 24/7 procurement, granular matching, or 24/7 carbon-free energy — requires the renewable electricity claimed to align with consumption on an hourly basis. RE100’s current criteria operate on annual matching with a “reasonably close” vintage rule; the framework recognises 24/7 procurement as best practice but does not currently require it.

Sourced from where?

Renewable electricity must be sourced from within the same market as the consumption. The market boundary definitions are codified in Appendix B of the Technical Criteria and are scope-specific (see Market Boundary Rules below). Buying RECs in the United States to cover consumption in the European Union is not compliant; nor is buying I-RECs in one country to cover consumption in another, except where both fall within an explicitly recognised single market.

Qualifying Renewable Technologies

The 2024 criteria recognise five renewable electricity technology classes:

Two technologies that are sometimes assumed to qualify do not. Nuclear is excluded — RE100 is a renewable electricity initiative, and nuclear, while low-carbon, is not classified as renewable under the criteria. Hydrogen is excluded as a primary energy source because hydrogen is a carrier rather than a primary resource; electricity generated from a turbine running on green hydrogen may qualify if the underlying energy used to manufacture the hydrogen was renewable, but the chain of custody must be traceable.

Energy Attribute Certificates: The Core Instrument

The Energy Attribute Certificate is the single most important instrument in the RE100 system. An EAC is a standardised electronic certificate, issued by a qualifying registry, that represents the environmental attributes of one megawatt-hour (1 MWh) of renewable electricity generation. The certificate is separable from the underlying electricity, can be traded, and is “consumed” — formally, “cancelled” or “retired” — when its owner uses it to make a claim. Once cancelled, an EAC cannot be reused.

EACs do three things at once. First, they prevent double-counting: because each MWh of renewable generation produces exactly one EAC, and each EAC can only be cancelled once, the system mathematically guarantees that two companies cannot both claim the same renewable MWh. Second, they create a market for renewable attributes that is separable from the physical electricity market, allowing companies in markets with limited renewable supply to participate in the energy transition. Third, they provide the audit trail that RE100, GHG Protocol Scope 2 market-based accounting, and CSRD ESRS E1 disclosure all require.

For a fuller technical treatment of how EACs work — issuance, tracking, cancellation, retirement statements — see the GreenCalculus glossary entry for Energy Attribute Certificates.

What an EAC is not

An EAC is not a carbon offset. It does not represent a tonne of avoided emissions; it represents a megawatt-hour of renewable electricity generation. Confusing the two is a frequent error in corporate communications. Under the GHG Protocol Scope 2 Guidance, an EAC reduces market-based Scope 2 emissions when applied correctly; under the SBTi standard, it cannot count as an offset against any reduction target. The same instrument has different roles in different accounting systems.

The 2027 CDP cancellation cutoff

From the 2027 CDP cycle onwards, every RE100 claim — including claims based on PPAs and bundled procurement — must be evidenced by a cancellation statement from the registry in the country of consumption. Contractual claims without registry-confirmed cancellation will not be accepted. This change is intended to close a gap in the audit trail that allowed some PPA-based claims to proceed without EAC retirement evidence in markets where the contract structure obscured the underlying certificate flow.

Qualifying EAC Types by Region

EACs are issued under regional or national systems, each with their own legal framework, registry, and qualification rules. RE100 recognises a range of EAC types, with eligibility depending on the issuing system, the underlying generation technology, and the market boundary in which the claim is made.

EAC Tracking Registries and Issuing Bodies

EAC tracking registries are the operational backbone of the system. Each registry issues EACs to qualifying generators, transfers them between accounts, and records cancellation when a claim is made. A complete map of recognised registries is published in the RE100 criteria appendices; the table below summarises the largest by jurisdiction.

The 15-Year Asset Age Rule

The most consequential change introduced on 1 January 2024 is the 15-year asset age rule. The rule is designed to direct corporate procurement toward newer renewable capacity, addressing the long-running additionality criticism that buying EACs from decades-old hydropower plants does little to drive new project development.

The rule

For grid-procured renewable electricity, at least 85% of a member’s renewable electricity consumption claimed in any reporting year must come from generation assets that were commissioned or repowered within the preceding 15 years. The remaining up to 15% is exempt — that is, it may come from older assets without breaching the criteria.

How the 15% exemption works in practice

The exemption is calculated against total consumption, not against renewable consumption. A worked illustration: a member with 100 GWh of total consumption that claims 50 GWh of renewable electricity must show that at least 85% of that 50 GWh — 42.5 GWh — comes from assets commissioned or repowered within the preceding 15 years. Up to 15% of the 100 GWh — 15 GWh — may come from older assets. Where the renewable share is itself 15% of total consumption or less, the entire renewable share fits within the exemption window.

What counts as “commissioned” and “repowered”

Commissioning date is the date the asset first produced electricity at commercial scale. Repowering — substantially upgrading an existing asset, replacing major components such as turbines on a wind farm — resets the clock for the purposes of the rule, provided the upgrade meets the criteria’s definition of repowering. Minor maintenance, component replacement, or routine refurbishment does not reset the clock.

Grandfathering of pre-2024 contracts

Forward contracts, including PPAs and project-specific bundled and unbundled EAC contracts, that were operational before 1 January 2024 are grandfathered: they remain compliant with the 15-year rule for the duration of the original contract. New contracts entered into from 1 January 2024 onwards are subject to the rule from inception.

Self-generation and on-site or private-wire procurement are outside the scope of the 15-year rule — the rule applies to grid-procured renewable electricity only.

Market Boundary Rules

RE100 market boundaries determine whether an EAC issued in one location can be used to make a claim about consumption in another. The principle is simple: renewable electricity must be sourced from the same market in which it is consumed. The implementation is more complex, because what counts as “the same market” depends on policy, grid interconnection, and EAC system design.

The redefined European single market (from 1 January 2024)

The 2024 update narrowed the European single market boundary. Under the redefined rules, a country is part of the European single market for renewable electricity only if it satisfies all three of the following: (1) membership of the European Union single market, (2) membership of the Association of Issuing Bodies (AIB), and (3) grid connection to a country meeting the first two criteria. Small nation-states (Monaco, the Vatican, San Marino, Andorra, Liechtenstein) are exempted from the strict three-test rule and remain inside the single market.

The redefinition has practical consequences for several countries:

• United Kingdom: excluded from the single market because of post-Brexit non-membership of the EU single market. UK consumption requires UK-issued REGOs.
• Poland: excluded because it operates a national EAC system distinct from the AIB framework.
• Bulgaria, Romania: excluded as they are not AIB members.
• Albania, Bosnia and Herzegovina, North Macedonia: excluded — interconnected grids but not EU single-market members.

Out-of-market sourcing

The 2022 criteria, carried forward and tightened in 2024, identify two non-compliant patterns: direct out-of-market sourcing (claiming use of renewable electricity in market A based on EACs issued in market B), and indirect out-of-market sourcing or over-procurement (where in-market EAC retirements exceed the underlying consumption in that market, with the surplus implicitly applied elsewhere). Both patterns are excluded from valid RE100 claims.

Grandfathering of forward contracts

Contracts for renewable electricity procurement that were operational before 1 January 2024 and that complied with the previous market boundary definitions remain compliant for the duration of the original contract, even where the redefinition would otherwise exclude the sourcing market. The grandfathering applies to physical and financial PPAs, bundled and unbundled EAC contracts, and similar arrangements.

Vintage Rules

EACs are dated by the period in which the underlying generation occurred. The vintage rule determines how closely the generation date must align with the consumption year for which the EAC is being used.

RE100’s vintage rule is described in the criteria as “reasonably close” matching. In practice this is operationalised by CDP as follows: an EAC may be used for a consumption year if its underlying generation falls within the same calendar year as the consumption, or within a window of approximately six months before the start or six months after the end of that year (i.e., generation between 1 July of the prior year and 30 June of the following year, depending on registry and certificate rules).

Two implications follow. First, EACs cannot be banked indefinitely — generation from many years before the consumption year does not qualify. Second, hourly matching (24/7 procurement) is a stricter form of vintage matching, requiring the generation to align with consumption on an hourly basis, which is materially harder to satisfy than annual matching with the “reasonably close” window.

The Procurement Quality Hierarchy

Not all RE100-compliant procurement is equivalent in market impact. The criteria — and the wider corporate renewable energy practice — recognise an implicit hierarchy of procurement pathways, ordered roughly by additionality, traceability, and the strength of the demand signal sent to project developers. This hierarchy is not a hard ranking embedded in the criteria, but it is reflected in CDP scoring, in SBTi V2.0 expectations, and in the procurement priorities of the most advanced members.

All six tiers can satisfy RE100 if the technical criteria are met. The hierarchy matters for what comes next: SBTi V2.0 hourly matching, CSRD ESRS E1 disclosure expectations, and CDP scoring all reward the higher tiers more heavily than the lower ones.

Additionality: The Most Contested Criterion

Additionality is the principle that a corporate renewable claim should drive new renewable capacity, rather than simply rebadging electricity that would have been generated regardless. It is the single most contested concept in the RE100 framework, and the one most likely to evolve over the next several years.

RE100’s current position is that additionality is strongly encouraged but not a hard requirement. The 15-year asset age rule is the most direct mechanism by which the criteria reward additionality — by privileging assets commissioned or repowered within the past 15 years, the rule reduces the scope for claims based on long-paid-off legacy hydropower or aging wind farms. Beyond the 15-year rule, the criteria describe additionality as a desirable property and recommend procurement structures that demonstrate it (PPAs from new-build projects, direct project financing, on-site generation), without making additionality itself a pass-fail test.

The picture differs once the lens widens to adjacent frameworks. SBTi V2.0, in its current draft, leans materially harder on additionality through its hourly-matching requirement and its expectation of new-build sourcing. The EU Renewable Energy Directive’s hydrogen rules — the Renewable Fuels of Non-Biological Origin (RFNBO) framework — operationalise additionality through specific tests (geographic correlation, temporal correlation, additionality criterion). The 24/7 Carbon-Free Energy framework, originated by Google and now broadly accepted as the leading granular-matching approach, treats additionality as a defining feature.

For practitioners, the practical implication is that an RE100-compliant claim today may not, on its own, satisfy the additionality expectations of the SBTi V2.0 standard, the RFNBO framework, or sophisticated buyers seeking 24/7 CFE alignment. A procurement strategy designed for RE100 compliance today should be designed with the trajectory of these adjacent frameworks in mind.

Interaction with GHG Protocol Scope 2 Accounting

RE100 and GHG Protocol Scope 2 market-based accounting are related but not identical systems. Understanding the difference is essential for any company that holds an RE100 commitment and reports a corporate inventory.

The two systems answer different questions

The GHG Protocol Scope 2 framework, codified in the GHG Protocol Corporate Standard and the dedicated Scope 2 Guidance, requires companies to report purchased electricity emissions using two methods: location-based (grid-average emission factors for the geography of consumption) and market-based (contractual instruments such as supplier-specific factors, EACs, and PPAs). The market-based method asks: “What were the contractual emissions of the electricity this company purchased?” RE100 asks a related but distinct question: “Did this company source 100% of its electricity from qualifying renewable sources?”

For a fuller side-by-side comparison of the two methods see the Scope 2 Location-Based vs Market-Based comparison page and the Scope 2 Market-Based Methodology page.

Why a company can be RE100-compliant with non-zero market-based Scope 2

Several scenarios produce this outcome legitimately:

• Vintage and matching gaps. RE100 currently operates on annual matching with a “reasonably close” vintage window. A company can be 100% RE100-compliant on annual averages while still showing some market-based Scope 2 emissions in particular months or hours where retired EACs did not align with consumption.
• Heat and cooling. RE100 covers electricity only. Purchased steam, heat, and cooling are in scope of GHG Protocol Scope 2 but outside the RE100 boundary. A company achieving 100% renewable electricity will still have Scope 2 emissions from purchased heat or cooling.
• Sustainability-related EAC adjustments. Some EACs that satisfy RE100 may carry residual emission factors under the market-based method (for example, certain biomass certificates with documented life-cycle factors).

Why a company can have zero market-based Scope 2 yet not be RE100-compliant

A company might procure RECs that satisfy GHG Protocol market-based accounting but not satisfy RE100’s stricter criteria — for example, RECs from assets older than 15 years above the exemption ceiling, RECs from biomass that do not meet RE100 sustainability requirements, or RECs sourced outside the redefined European single market boundary. Under GHG Protocol the certificates may still reduce market-based Scope 2; under RE100 they will not be counted toward the 100% target.

The methodology pages at /methodology/scope-2-electricity/ and /methodology/scope-2-market-based/ document the calculation rules in detail.

The Residual Mix Problem

The residual mix is the fuel mix and emissions intensity of grid electricity after subtracting the share already claimed by EAC purchases. Conceptually, when a company buys a REGO or GO and applies it to its consumption, the underlying renewable MWh is “removed” from the residual pool that everyone else implicitly draws on. The residual mix factor is the location-based emission factor adjusted for this subtraction.

The residual mix matters for RE100 in two ways. First, it underpins the integrity of EAC-based claims: the existence of a tracked residual mix is what mathematically prevents double-counting. If a company in market A retires an EAC, the residual mix in market A reflects the absence of that MWh, and other consumers in market A who do not buy EACs are implicitly receiving the residual rather than the renewable share. Second, residual mix factors are the relevant denominator for assessing the additionality and emissions consequence of voluntary procurement — if the residual mix is already very clean (as in some Nordic and hydro-dominated grids), the additionality of an unbundled EAC purchase is correspondingly modest.

For the underlying location-based emission factors themselves, see the electricity emission factor glossary entry and the IEA Grid Emission Factors 2026 reference dataset.

RE100 vs. Adjacent Frameworks

RE100 sits in a dense ecosystem of overlapping frameworks. The table below maps the key differences across five frameworks practitioners encounter.

RE100 in the CSRD, IFRS S2, and SEC Disclosure Stack

RE100 membership and progress data feed directly into the most consequential mandatory disclosure regimes operating today.

CSRD and ESRS E1

The European Sustainability Reporting Standards’ E1 standard on climate change requires substantial energy and emissions disclosure. RE100 data informs several E1 datapoints:

• E1-4 Targets: the RE100 target year, interim milestones, and methodology are directly relevant to disclosure of energy- and emissions-related targets.
• E1-5 Energy consumption and mix: the share of renewable electricity by source, by geography, and by total — exactly the information RE100 requires members to disclose to CDP.
• E1-6 Gross GHG emissions: Scope 2 location-based and market-based are required disclosures; an RE100 member’s market-based Scope 2 will reflect EAC retirements applied during the year.
• E1-7 Removals and storage: RE100 procurement does not generate removals, but the disclosure architecture sits alongside it.

RE100 membership does not satisfy ESRS E1 disclosure on its own — E1 requires substantially more granular disclosure on energy mix, contractual structure, and risk exposure than RE100 captures. But the underlying procurement and reporting effort is largely the same. See the CSRD / ESRS E1 reference page for the full datapoint list.

IFRS S2

The IFRS Sustainability Disclosure Standards’ S2 (Climate-related Disclosures) requires Scope 1, 2, and 3 emissions disclosure aligned with the GHG Protocol. RE100 data feeds into the Scope 2 line item; members typically use their CDP submission as a primary source for IFRS S2 reporting on energy consumption and renewable share.

U.S. SEC climate disclosure rule

The SEC rule, finalised in 2024, requires registrants to disclose material climate-related risks and Scope 1 and Scope 2 emissions for accelerated and large accelerated filers. Scope 3 is excluded. RE100 progress feeds into the Scope 2 line and into the transition-plan and target-related disclosures. As with the SBTi standard, RE100 membership is not directly referenced in the rule but is widely cited by registrants as the substantive basis for their renewable-electricity claims.

Reporting and Verification Through CDP

RE100 progress is reported annually through the CDP corporate questionnaire. CDP is the disclosure infrastructure: members complete the relevant questions in their annual CDP submission, RE100 ingests the data through the CDP platform, and the RE100 secretariat publishes the annual disclosure report aggregating membership performance.

What members report

• Total electricity consumption for the reporting year, by market.
• Renewable electricity consumption, by procurement type (self-generation, PPA, bundled EAC, unbundled EAC, green tariff, default delivered).
• EAC volumes retired, by registry and instrument.
• Asset commissioning dates for all reported renewable procurement (for the 15-year rule).
• Market boundary information for each procurement arrangement.
• Vintage information for retired EACs.

How RE100 assesses claims

CDP applies the operative version of the Technical Criteria to the submitted data. Claims that fail the criteria — for example, EACs retired outside the operative market boundary, EACs from assets older than 15 years exceeding the exemption ceiling, or biomass-sourced electricity without sustainability documentation — are flagged as not recognised. The annual disclosure report publishes both the self-reported renewable share and the RE100-verified renewable share for each member, and the gap between the two is itself a public datapoint.

Assurance expectations

RE100 does not require third-party assurance of the underlying electricity consumption data, but increasingly the disclosure regimes that ingest RE100 data do. CSRD requires limited assurance of sustainability statements, with a planned transition to reasonable assurance. ISAE 3410 (the assurance standard specific to GHG statements) is the most common framework applied. Members should expect that, by the late 2020s, the underlying data feeding both their CDP submission and their RE100 progress reporting will be subject to the same assurance procedures as their financial statements.

Common Misinterpretations

Six high-frequency misreadings of the RE100 Technical Criteria. Each is the kind of error that surfaces in corporate sustainability reports, supplier briefs, and consultancy decks — and each is the kind of error CDP catches during the annual reporting cycle.

Common Reporting Errors

Eight technical errors that surface repeatedly during the CDP reporting cycle and during external assurance:

1. Reporting REC retirement without registry confirmation. Particularly an issue ahead of the 2027 CDP cancellation cutoff. Members should ensure every claimed EAC has a corresponding cancellation statement from the issuing registry.
2. Mismatching EAC vintage to consumption year. Submitting EACs with generation dates outside the “reasonably close” window — typically more than six months before the start or six months after the end of the consumption year.
3. Treating the 15% exemption as renewable-share-based rather than total-consumption-based. The exemption is calculated against total consumption, not against renewable share. Misapplying the denominator can produce non-compliant claims.
4. Out-of-market sourcing. Particularly common for multinationals with consolidated procurement structures — buying I-RECs in market A to cover consumption in market B without recognising that the two markets are not part of a single market boundary.
5. Counting biomass without sustainability documentation. The 1 January 2024 update converted sustainability for biomass and hydropower from a recommendation into a requirement. Procurement contracts that did not contemplate this evidence requirement may need supplementary documentation from the generator.
6. Counting nuclear or hydrogen as renewable. Both are excluded under RE100. Including them in the renewable share is a category error that typically signals a misreading of the criteria.
7. Double-counting between RE100 and SBTi or CSRD reporting. A retired EAC can support multiple disclosure pathways but cannot represent multiple renewable MWh. Disclosure teams should ensure the same retirement is documented once across all reporting streams.
8. Reporting self-generation without confirming attribute retention. On-site generation only counts where the company has retained the environmental attributes. Where SRECs or equivalent certificates have been sold, the underlying generation does not count toward RE100.

Sector-Specific Implementation Notes

Brief, opinionated notes on what tends to dominate implementation effort by sector.

Data centres and hyperscale technology

Scope 2 emissions are the dominant emissions line for hyperscale operators. The pressure from 24/7 Carbon-Free Energy is most acute here; Google’s 24/7 CFE framework was originated in this sector, and the largest hyperscale operators are setting hourly-matching commitments well in advance of any regulatory or SBTi requirement. RE100 compliance is treated as the floor; granular matching is the ceiling.

Manufacturing

Process electricity dominates Scope 2; the question is the mix between on-site generation, off-site PPAs, and unbundled EACs. Heavy manufacturing in markets with high industrial tariffs has driven the most mature corporate PPA market in Europe and North America. The 15-year asset age rule has a particular effect on manufacturers in markets where corporate PPAs were signed against older assets in the early 2010s.

Real estate

The landlord-tenant split is the central complication. RE100 reporting requires clear documentation of which entity controls electricity supply. For multi-tenant commercial buildings, landlord-procured renewable electricity benefits the building level; tenant-controlled supply requires tenant-specific procurement. The CSRD ESRS E1 disclosure pressure is reinforcing the documentation discipline.

Financial services

Operational electricity is typically a small share of total corporate footprint, but the 100 GWh threshold means that the largest banks, insurers, and asset managers comfortably cross the eligibility bar. Scope 3 Category 15 (financed emissions) is governed by separate frameworks (PCAF, the SBTi Financial Institutions standard) and is not addressed by RE100 — RE100 covers operational electricity consumption only, not the electricity consumption of portfolio companies.

Apparel and consumer goods

Operational electricity is dwarfed by Scope 3 emissions in these sectors. RE100 compliance addresses the operational footprint cleanly; the harder challenge is engaging the supply chain. Several apparel and consumer goods members have extended their RE100 commitments through supplier engagement programmes, requiring or incentivising suppliers to make their own RE100 commitments.

Implementation Workflow

For a company approaching RE100 for the first time, the practical workflow runs as follows.

1. Eligibility test. Confirm annual electricity consumption ≥ 100 GWh, or document the strategic-influence basis for application below the threshold. Confirm no sector exclusion applies.
2. Consumption baseline (1–3 months). Compile consumption data across the operational control boundary, by site and by market. Reconcile to GHG Protocol Scope 2 inventory data.
3. Market-by-market gap analysis (1–2 months). Identify the renewable share already in place by market, the gap to 100%, and the EAC market structure available in each location.
4. Procurement strategy (2–4 months). Assemble a portfolio across the procurement quality hierarchy. Self-generation and direct PPAs for high-impact markets, bundled or unbundled EACs to fill smaller gaps, mindful of the 15-year asset age rule and the 2027 CDP cancellation cutoff.
5. Target year selection. Set a target year not later than 2050, with interim milestones aligned with the 60% / 90% reference points. Bring forward where market readiness permits.
6. Application to RE100. Submit the application to the Climate Group with the target year, baseline, and procurement plan documented.
7. Annual reporting through CDP (ongoing). Complete the relevant CDP corporate questionnaire sections each year. Document EAC retirements, asset commissioning dates, market boundaries, and vintage. Reconcile to GHG Protocol Scope 2 market-based reporting.
8. Annual progress review. Track verified renewable share against the target trajectory. Address gaps before the next reporting cycle. Update procurement portfolio as criteria evolve (notably, prepare for the 2027 cancellation cutoff and any post-2025 criteria revisions).

Future Evolution

Three trajectories will shape the RE100 Technical Criteria over the next several years.

Hourly matching. The pressure toward 24/7 carbon-free energy is the single largest force acting on the criteria. SBTi V2.0 expects hourly-matched zero-carbon electricity for Scope 2; the EU Renewable Energy Directive’s hydrogen rules operationalise temporal correlation; the U.S. Department of Energy and several other policymakers are advancing granular matching frameworks. RE100’s current “reasonably close” annual matching is likely to be tightened over the next two-to-four-year revision cycle, with hourly matching either required for new claims or recognised through a formal premium tier.

The 2027 CDP cancellation cutoff. The hardening of evidence requirements for PPA-based claims — and the elimination of coal co-firing from qualifying generation — represent the largest near-term operational change for many members. Members that have built procurement architectures on long-term PPA contracts without explicit EAC retirement documentation will need to restructure. Expect a wave of contract renegotiation and supplier engagement through 2026.

Developing-market EAC infrastructure. The largest gap in the RE100 framework today is the limited availability of qualifying EACs in markets with rapidly growing corporate consumption — particularly in parts of South Asia, Southeast Asia, and Africa. The Climate Group, CDP, and several development finance institutions are actively engaged in EAC infrastructure development in these markets. Expect new I-REC issuance volumes to grow materially, alongside new domestic EAC systems in markets where corporate demand justifies them.

Frequently Asked Questions

Sources and References

Every numerical claim and methodological statement in this article reconciles to the primary sources below. Where RE100 has published a definitive document on a topic, the primary source is cited directly; secondary commentary is used only for interpretation.

Primary RE100 documents

• RE100 (Climate Group & CDP), RE100 Technical Criteria + Appendices, April 2025 release. there100.org/sites/re100/files/2025-04/RE100%20technical%20criteria%20+%20appendices.pdf
• RE100, RE100 Reporting Guidance 2024. there100.org/sites/re100/files/2024-12/RE100%20Reporting%20Guidance%202024%20v3.pdf
• RE100, 2024 consultation on RE100 technical criteria changes, April 2024. there100.org/sites/re100/files/2024-04/2024-consultation-on-RE100-technical-criteria-changes.pdf
• RE100, Annual Disclosure Reports (most recent: 2024 cycle). there100.org/our-publications
• RE100, Technical Guidance & FAQs. there100.org/technical-guidance
• RE100, main initiative site. there100.org

Underpinning standards and adjacent frameworks

• WRI & WBCSD, The Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (revised edition).
• WRI & WBCSD, GHG Protocol Scope 2 Guidance, 2015 (with ongoing revision toward a new version expected to influence RE100 reporting from 2026).
• Science Based Targets initiative, Corporate Net-Zero Standard, Version 1.3.1, April 2026, and Corporate Net-Zero Standard V2.0 Second Consultation Draft, November 2025.
• European Sustainability Reporting Standards, ESRS E1 (Climate change). EFRAG, 2023 (EU Delegated Act).
• IFRS Sustainability Disclosure Standards, IFRS S2 (Climate-related Disclosures). ISSB, 2023.
• U.S. Securities and Exchange Commission, climate-related disclosure rule, 2024.
• ISO 14068-1, Climate change management — Transition to net zero — Part 1: Carbon neutrality.
• ISAE 3000 / ISAE 3410 — assurance standards for non-audit engagements and GHG statements.
• Google, 24/7 by 2030: Realizing a Carbon-free Future, and the broader 24/7 CFE Compact body of work.
• EU Renewable Energy Directive (RED III) and the Renewable Fuels of Non-Biological Origin (RFNBO) Delegated Acts.

EAC system references

• Association of Issuing Bodies (AIB), European Energy Certificate System (EECS) Rules.
• I-REC Standard Foundation, I-REC Code.
• Green-e, Green-e Renewable Energy Standard for Canada and the United States.
• Ofgem, Renewables Obligation and REGO documentation.
• Clean Energy Regulator (Australia), Renewable Energy (Electricity) Act 2000 and LGC scheme documentation.
• Central Electricity Regulatory Commission (India), REC Regulations.

Related GreenCalculus reference pages

• GHG Protocol Corporate Standard
• SBTi Corporate Net-Zero Standard
• CSRD / ESRS E1
• ISO 14064-1
• Energy Attribute Certificates
• Scope 2 (market-based method)
• Scope 2 (location-based method)
• Residual mix
• Electricity emission factor
• Scope 2 location-based vs. market-based
• Scope 2 electricity methodology
• Scope 2 market-based methodology
• Scope 2 Electricity Calculator
• IEA Grid Emission Factors 2026

What changed in this revision

Updated 10 May 2026. Initial publication. Reflects the RE100 Technical Criteria as of the April 2025 consolidated release with appendices, the operative 1 January 2024 update (15-year asset age rule, redefined European single market boundary, biomass and hydropower sustainability requirements), the 2024 consultation outputs, the 2027 CDP cancellation cutoff, and the relevant cross-references to the SBTi Corporate Net-Zero Standard V1.3.1 and V2.0 draft.