Regulatory Watch
A curated view of the regulatory moves pushing 24/7 CFE, hourly matching and physical deliverability into market-based emissions accounting. Updated as signals land. Last update: 23 April 2026.
Framing
The market-based method is moving from annual bookkeeping to hourly physics.
Annual Guarantees of Origin and grid-average emissions factors are no longer sufficient. Across jurisdictions, regulators are converging on three joint requirements: time granularity (hour or sub-hour), deliverability (physical delivery in the bidding zone or corridor where the load sits), and verification (evidence an auditor can cross-check).
DeliveryTag sits at the deliverability layer of that stack. We are natively compatible with Granular Certificates issued under the EnergyTag standard and add the spatial layer on top via hardware-signed PIN attestations and PTDF corridor attribution, for use cases where regulators require evidence beyond hourly matching.
Editorial note. The DeliveryTag-alignment commentary that follows each regulatory signal reflects the Integrity Protocol Foundation's own interpretation of the text, not an official endorsement, recognition, or acceptance by the regulators, standard-setters, or third-party assurance bodies cited. Mapping to any specific framework will be evaluated case by case by the auditor of record.
Active signals
Regulatory moves already in motion.
EC Commission Recommendation on PPAs
C(2026) 2676 · referencing CEN 16325:2025
The European Commission instructs Member States to allow Guarantees of Origin to be issued and transferred, in line with CEN 16325:2025, meeting four criteria:
- (a)time granularity down to market time unit (typically 15 minutes)
- (b)concern electricity provided by a storage unit
- (c)reflect the bidding zone in which the generation has taken place
- (d)can be exchanged across borders
DeliveryTag alignment
Criterion (c) on bidding-zone reflection is the deliverability layer. DeliveryTag's PTDF corridor attribution operationalizes it at a finer resolution than the bidding zone itself. Criteria (a) and (b) are carried by Granular Certificates issued under the EnergyTag standard, which DeliveryTag is natively compatible with.
EU CBAM enters binding phase
Carbon Border Adjustment Mechanism · embedded emissions become a pricing line
The Carbon Border Adjustment Mechanism moved from voluntary reporting (2023-2025) to binding compliance on 1 January 2026. Embedded emissions in imported goods now determine CBAM certificate purchases, creating direct financial cost for high-carbon electricity inputs.
Importers can claim cleaner electricity deductions only if the electricity is physically supplied and time-matched to production. Annual Guarantees of Origin are explicitly insufficient; the framework requires direct wire connections or physical PPAs with verifiable hourly delivery evidence.
DeliveryTag alignment
CBAM's "verifiable delivery evidence" standard is what DeliveryTag's PTDF corridor attribution, hardware PIN attestations and Hedera-anchored audit trail deliver. APAC exporters to the EU (China, Korea, India, Japan, Vietnam, ~33% of EU imports) face the sharpest compliance pressure and represent an adjacent addressable market.
Colorado SB26-102, hourly-matched clean electricity for data centers
Senate Transportation & Energy Committee · nation-leading US legislation
Colorado SB26-102 proposes that new or expanded large-load data centers in the state meet 100% annual clean-electricity matching from 2031, plus a Public Utility Commission-determined hourly matching percentage (up to 100%) with a feasibility analysis due by June 2030 and triennial updates thereafter.
EnergyTag's US Policy team testified in favor of the bill. Their quote: "100% annually matched power, using only solar, can equate to as low as 40% hourly matching across the year." If enacted, Colorado becomes the first US state to codify hourly matching for data centers, setting a precedent other states (Illinois hearings already underway) can replicate.
DeliveryTag alignment
The 100% annual / ~40% hourly gap is exactly what DeliveryTag closes: hardware-signed proof that certified MWh were delivered to the data-center node during the exact hours claimed. Precedent-setting US legislation opens a parallel commercial track in Colorado and follow-on states.
On the horizon
Converging by 2027-2028.
GHG Protocol Scope 2 revision
Multi-year standards update, direction: temporal + deliverability matching
The GHG Protocol is revising its Scope 2 guidance (market-based method). First public consultation closed January 2026; second consultation underway. Draft direction confirms both temporal matching (hourly) and deliverability as quality criteria for market-based claims. Final Standard expected late 2027, in parallel with the CSRD 2027-2028 audit cycle.
DeliveryTag alignment
DeliveryTag's two forensic pillars (temporal via EnergyTag-compatible GCs, deliverability via PTDF + PIN) map to the two proposed quality criteria. Position available today for early adopters before the final Standard lands.
Foundation context
The regulatory bedrock these signals build on.
RED III Article 19
The recast Renewable Energy Directive governs Guarantees of Origin in the EU. Establishes the underlying GO framework that the EC Recommendation 22 April 2026 operationalizes into granular criteria.
EU CSRD
Corporate Sustainability Reporting Directive. Requires large EU companies to disclose Scope 1, 2 and 3 emissions using the GHG Protocol. Audit cycle 2027-2028 overlaps with the Scope 2 revision final.
IRA Section 45V
US clean-hydrogen tax credit. Three-pillar rules (hourly matching, additionality, deliverability) set a US federal precedent for the same stack the EU is now codifying through the Commission Recommendation.
Read the protocol that answers these signals.
DeliveryTag is designed to sit on top of EnergyTag Granular Certificates and add the spatial-deliverability layer that the Scope 2 revision and EC Recommendation are converging on. Specification, governance, and EnergyTag compatibility are documented in the public whitepaper.