The latest Scope 2 Consultation document introduces and requests feedback on the concept of Standard Supply Service (SSS).
What Is Standard Supply Service, and what’s being proposed?
According to the recent Public Consultation document in section 5.3.1, the “approach would clarify how companies may account for electricity from shared or publicly supported resources while ensuring that each customer claims only their rightful share.” Furthermore, it instructs that reporting entities may only claim its “fair, proportional share based on electricity use,” and that if this entity does not claim that share, the share may not be transferred to someone else. The aim, in short, is to address the concerns around double counting of what’s on the grid by issuing clarity to regulated or publicly supported energy suppliers and their customers.
Who does this impact and how?
The proposed revision text states that “Suppliers should allocate SSS electricity supply and related EACs for energy used to serve customers on a pro rata share basis. However, the GHG Protocol cannot require suppliers to allocate SSS electricity to supply and related EACs to their customers.”
Said differently, the GHG Protocol is offering clarity on how they would like suppliers to clarify how allocation is done so that reporting entities have solid claims.
The SSS guidance is aimed to address situations where there is a “traceable and mandatory financial relationship between customers of a supplier or utility and the electricity and/or contractual instruments from deliverable generation resources (including carbon free and fossil resources) used to supply their load,” and they provide a few examples:
- Supply that is subject to regulated cost recovery from a monopoly supplier as part of default service.
- ”Competitive or regulated” suppliers complying with government-mandated clean energy procurement programs, including Renewable Portfolio Standards (RPS), Clean Energy Standards (CES), and nuclear-supported policies applied to state-level electricity supply.
- Publicly owned facilities where the majority owner is a government entity (such as a municipal organization).
The SSS guidance also impacts reporting entities by providing clarity on what can be claimed, and that claims need to be supported by “credible data that Scope 2 Quality Criteria.” The updated guidance reiterates that if a reporting entity does not opt to exercise the claim of CFE from SSS, then that claim cannot be transferred or sold off to another entity.
What is the intent of these proposed changes?
As stated above, these changes address a previously ambiguous area in the 2015 Scope 2 Guidance. By providing clear language for how CFE resources should be allocated in markets with a mandated financial relationship (as well as offering guidance for if a Supplier does not disclose SSS), the GHG Protocol aims to make it easier for reporting entities to have data-backed, variable claims on which to report.
What should our organization do?
The main call to action is for organizations to weigh in during the public comment period which runs from October 19th to December 19th 2025.
The working group is particularly interested in stakeholder feedback on the definition of a “monopoly supplier.”
Additionally, Section 5.3.3 contains 16 stakeholder consultation questions (numbers 97 to 112) seeking clarity on the new SSS language. You are not required to answer all questions; please focus on those most relevant to your organization.
Are you concerned?
If you work for an organization who would be obligated or encouraged to disclose a Standard Supply Service and are concerned about these changes, don’t fear! Cleartrace has developed solutions that make solving this allocation process simple and easy.
