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Scope-2 GHG Reporting in 2026: How On-Site Solar Beats RECs

Published 2026-03-13 Topic Scope 2, GHG Reporting, SECR Read ~5 min

From 2026 onwards, large UK companies (£36M+ turnover OR 250+ employees) must report Scope-2 emissions under SECR. On-site solar generation is the cleanest Scope-2 reduction — measurably better than renewable energy certificates (REGOs/RECs).

What SECR actually requires in 2026

Streamlined Energy and Carbon Reporting (SECR) applies to large UK companies (and LLPs). Reporting threshold: £36M+ turnover, £18M+ balance sheet, 250+ employees (any two met). Required: annual report disclosure of total UK energy consumption (kWh), GHG emissions (tCO₂e), and energy efficiency actions taken.

Scope 1 vs 2 vs 3 — the difference

Scope 1: direct emissions from owned sources (gas boilers, fleet, on-site combustion). Scope 2: indirect emissions from purchased electricity. Scope 3: everything else (supply chain, products in use, business travel). Most commercial solar reduces Scope 2 — the indirect emissions from your purchased electricity that solar displaces.

How to count on-site solar in Scope-2

Two methods: (1) Location-based — uses national grid emission factor (UK 2026: ~157 gCO₂/kWh). Your solar generation × this factor = avoided emissions, deducted from your total. (2) Market-based — uses your specific supplier's renewable mix + on-site generation. KMM provides monthly generation data feeding both methods.

Why on-site solar beats RECs

REC = Renewable Energy Certificate (REGO in UK). You buy 'evidence' that renewable electricity was generated somewhere on the grid. Auditors (CDP, SBTi, TCFD) increasingly discount RECs because: (a) Additionality is questionable (the renewable would have been generated anyway). (b) Location and timing are decoupled from your actual consumption. On-site solar is directly traceable and additional.

SBTi-aligned reporting

Science Based Targets initiative requires Scope-2 reductions to be physical + measurable. Their 2024 guidance explicitly favours on-site renewables over unbundled certificates. Companies aiming for SBTi-validation should treat on-site solar as a strategic move.

The CDP scoring impact

CDP (Carbon Disclosure Project) scores 9,600+ companies annually. Disclosure score depends on Scope-2 methodology. Companies using market-based + on-site generation typically score A or A- vs B/C for REC-only buyers. CDP-A is increasingly required for major procurement (NHS, central government, large enterprise tenants).

Auditing your solar generation

Auditable solar generation requires: (1) Meter-grade revenue-grade generation meter (MCS PV4 compliant). (2) Monthly data export (KMM provides per-site dashboards). (3) Annual independent verification — usually your existing carbon auditor. KMM's per-panel SolarEdge monitoring or per-string Sungrow monitoring delivers all of this.

Tenant pass-through reporting

If you're a commercial landlord with PV: tenants can claim the solar generation in their Scope-2 if it's documented in their tenancy agreement. We've helped landlord clients structure 'green lease' addenda that pass through solar generation rights, making the building more lettable to ESG-mandated tenants.

Want to apply this to your site?

Tell us your roof, your demand profile and your goals — KMM will model the maths against your half-hourly data and come back with a bound-in quote within 7 working days. No deposit, no pressure.

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