Brussels, 2 February 2026 – While the European Banking Federation (EBF) welcomes the GHG Consultation on the Scope 2 Guidance, we are concerned abouts its potential impact on PPAs market. The key messages on the consultation response are: 

• The consultation proposes to tighten the Market-Based Method by turning two quality criteria into binding requirements. While framed as accounting refinements, these changes will reshape incentives in electricity markets, not just reporting outcomes as the  renewable energy projects depend on long-term Power Purchased Agreements with creditworthy counterparties, predictable cash flows, tax equity and debt. The proposed changes  will  shrink the pool of corporate buyers able or willing to sign long-term PPAs, reduce average PPA tenor or volume and increase price volatility and structuring complexity.
• As a consequence, financing costs will rise, risk premia will increase, and marginal projects will not reach financial close.This change could create a paradox: reported emissions may look more precise but investment, deployment, and grid decarbonization will slow down.
• For these reasons, we believe the GHGP should maintain current definitions and treat hourly matching and deliverability as an optional “may” pathway.All PPAs signed prior to the implementation of the new Scope 2  rules an their extention  must remain governed by the existing framework for the full term of their contracts. Furthermore, since many renewable assets are expected to undergo multiple re-contracting cycles over their 20–30-year lifespan, legacy protection should be applied at the asset level rather than solely to individual agreements
• Making the changes mandatory would hinder renewable energy procurement, delay the transition to a carbon-free grid, and create unnecessary logistical burdens and costs.

Denisa Avermaete, Head of Sustainable Finance, D.Avermaete@ebf.eu

Jānis Priekulis, Policy Adviser – Sustainable Finance, j.priekulis@ebf.eu