Climate Impact X

AI/crypto-driven load growth has made Scope 2 exposure unavoidable for data centres and semiconductor fabs. The case for high-integrity RECs/EACs has never been stronger.

If you work anywhere near sustainability, you’ve probably felt it: the world’s electricity-hungry sectors are running head-first into a new problem. The challenge is not just reducing emissions, but proving that how you measure and report them can withstand scrutiny.

Right now, data centres and semiconductor fabs sit at the top of the exposure table.

Why? Because both sectors run on enormous, continuous (24/7) electricity demand that is growing fast. According to the IEA, global data centre electricity consumption is growing at around 15% per year – more than four times faster than total grid consumption. In semiconductors, production emissions are projected to nearly double by 2030, with over 80% electricity-driven.

AI and crypto – the main forces driving that growth – combined consumed around 460 TWh globally in 2022 (equivalent of powering over 40 million homes for a year), and the IEA projects that figure to more than double by 2026.

The real exposure runs deeper. What makes data centres and semiconductor fabs exposed comes down to two structural realities. Both are concentrated on the world's most fossil-heavy grids – and their load is growing faster than those grids are cleaning up. By 2030, they are expected to account for half of all new electricity demand across many of those markets. And unlike most industries where emissions are spread across supply chains, logistics, and manufacturing inputs, electricity is by far the single largest driver and can account for more than half of total emissions. When electricity is where most of your emissions come from, Scope 2 stops being a category and becomes a liability.

It’s exactly the kind of load that regulators, auditors, activists and investors love to dig into – line by line.

The credibility gap

In 2026, Scope 2 auditability isn’t about volume. It’s about governance, traceability and integrity. I frequently hear from CSOs:

• “We have RECs but I don’t feel our story is defendable.”

• “Our auditors want more proof than our supplier can provide.”

• “We’re overspending on certificates but we still look exposed.”

That discomfort is justified.

As scrutiny rises, not all certificates hold up equally, and not all strategies scale. The regulatory environment is only tightening the stakes further.

The EU's Omnibus I Directive, adopted in February 2026, has narrowed the scope of the Corporate Sustainability Reporting Directive (CSRD) and delayed reporting timelines for many companies. But for lor large, electricity-intensive operators, the practical reality is unchanged: limited assurance requirements remain, ESRS climate disclosures (E1) are still mandatory for in-scope entities, and market-based Scope 2 claims must be documented to survive external audit. In fact, the delay for these large companies may amplify risk for those operators who interpret it as reprieve. Pausing governance programmes now will face a compressed and costly catch-up when full reporting obligations activate. The Omnibus I changes do not reduce what auditors will demand; they reduce how many companies are formally required to product it – yet.
The direction of travel is clear: greater scrutiny of how emissions are measured and attributed.

So what actually works?

The strongest Scope 2 strategies share two characteristics.

1.Adopting a portfolio approach – not a single product strategy.

A credible Scope 2 roadmap includes a blend of: high integrity, verified Energy Attribute Certificates (EACs) – such as Renewable Energy Certificates (RECs) used across Asia Pacific and North America, or Guarantees of Origin (GOs) in Europe – alongside Power Purchase Agreements (PPAs), where location and load profile make sense. Not to forget, clear governance over how certificates are procured and claimed.

Certificates and PPAs serve different strategic functions and should be structured accordingly, not listed interchangeably. PPAs offer price stability, potential additionality, and audit credibility, but require multi-year commitment, offtake capacity and grid proximity. RECs, on the other hand, offer speed, geographic flexibility and lower transactional complexity. One can think about the contrast as: PPAs cover what you can plan for and RECs cover what you cannot. For fast-growing, geographically distributed loads, RECs fill the structural gaps PPAs can’t fill in.

2.Moving towards traceable and integrity screened certificates.

This doesn’t mean “hourly matching or nothing”, but it does mean: regionally relevant supply, verified production data, ownership tracking, and alignment with recognised integrity criteria.

RECs/EACs remain the fastest, most flexible lever for decarbonising load that simply cannot wait for grid transformation.

RECs aren’t a silver bullet, but they are the most misunderstood and under optimised tool in the box.
Used well, they:
• plug the unavoidable gaps between operational reality and long-term PPA options,

• reduce exposure when your load grows faster than your projects,

• provide flexible procurement options across geographies,

• shield you from grid mix volatility,

• and meet regulatory expectations when purchased and documented correctly.

The sectors with the largest Scope 2 exposure don’t have the luxury of waiting for perfect solutions. They need reliable, traceable megawatt hours today, and that is exactly where RECs do the heavy lifting.

My view

Data centres and fabs aren’t just electricity consumers. They have become energy players. Their Scope 2 strategies shape markets, influence policy expectations, and set industry norms.

Getting this wrong carries real reputational and regulatory risk. Getting it right builds a climate story that stands up under pressure.
The companies that master this now will define what credible decarbonisation looks like for the next decade.

Learn more about developing a credible Scope 2 strategy here.