REGO certificates and SECR: what a green tariff really does to scope 2
Last reviewed 2026-07-16
SECR at a glance
- ~11,900
- UK organisations in scope
- Estimated companies and LLPs covered by SECR
- £36M / £18M / 250
- The size thresholds
- Meet two of three — turnover, balance sheet, employees — and you're large
- Unlimited
- Fine on conviction
- Leaving SECR out of the Directors' Report is a criminal offence under s.415 CA 2006
- £1,500 / £7,500
- Late-filing penalties
- Maximum Companies House penalty for private / public companies if you delay the accounts
Thresholds and penalties are set out in the Companies Act 2006 and the Companies (Directors' Report) and LLP (Energy and Carbon Report) Regulations 2018. The SECR thresholds did not change in the April 2025 company-size uplift, so a company now classed as medium-sized can still be in scope.
What a REGO certificate is
A REGO — Renewable Energy Guarantee of Origin — is a certificate issued by Ofgem for every megawatt-hour (MWh) of eligible renewable electricity generated in the UK. Suppliers use REGOs to evidence the renewable share of the electricity they sell: a "100% renewable" tariff is, in regulatory terms, a tariff backed by enough REGOs to match the supplier's sales.
The certificate travels separately from the electricity itself. The physics doesn't change — every grid-connected building receives the same mixed electricity — so a REGO is an accounting instrument: proof that somewhere on the grid, a megawatt-hour of renewable generation matched your consumption.
Location-based vs market-based scope 2
The GHG Protocol recognises two ways to calculate scope 2 emissions:
| Method | Factor used | What it reflects |
|---|---|---|
| Location-based | UK grid-average factor from the DEFRA conversion factors | The physical grid you draw from |
| Market-based | Your contractual instruments — a REGO-backed tariff can evidence a near-zero factor | The electricity you've chosen to pay for |
Under the location-based method, everyone on the UK grid uses the same average factor, whatever their tariff. Under the market-based method, a REGO-backed renewable tariff can support a scope 2 figure at or near zero for the electricity it covers.
What this means for your SECR report
The practical convention for SECR is:
- Report location-based scope 2 using the current DEFRA grid-average factor. This is the figure your year-on-year comparison and intensity ratio are built on, and it's what reviewers expect to see.
- Optionally disclose a market-based figure alongside it, stating that it reflects a REGO-backed renewable tariff. Dual reporting is legitimate and increasingly common — what fails audit scrutiny is silently swapping to the flattering number.
- Say what you did in the methodology note: which method(s), which factor set, and what evidence backs any market-based claim.
So no — a green tariff does not cut your headline SECR scope 2 figure. But it does give you a defensible second figure that shows your procurement choice, and that has real value in tenders and stakeholder reporting.
Watch-outs
- Unbundled REGOs: certificates bought separately from the underlying electricity are the weakest form of evidence and attract greenwashing criticism. A REGO-backed supply tariff is a stronger basis for a market-based claim than standalone certificates.
- Partial coverage: if the tariff covers one site out of five, the market-based figure only drops for that site's consumption.
- The grid is decarbonising anyway: the DEFRA 2026 grid factor fell 26.8% year-on-year — your location-based figure improves every year without any procurement change, which is exactly why the narrative should explain why the number moved. See what changed in the DEFRA 2026 factors.
- Scope 2 is often not the biggest lever: for fleet-heavy or gas-heavy businesses, scope 1 dominates. Run the numbers in the carbon calculator before deciding where to spend.
Getting it right in your filing
If your company is in scope for SECR and you're weighing a renewable tariff — or being asked by a parent company or tender to show a market-based figure — a specialist can set up dual reporting properly: both figures, correct factors, and a methodology note that stands up to your auditor. Speak to a specialist — free and no obligation.
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