Sustainability reporting

On-site renewable generation reduces location-based Scope 2 emissions directly — a metered, auditable reduction that appears in ESRS E1-6 without requiring a Guarantee of Origin.

On-site renewable generation reduces location-based Scope 2 emissions at the property level — a direct, metered reduction that appears in ESRS E1-6 disclosure as reduced energy purchased from the grid.

Industrial and corporate sustainability managers evaluating HNordic's energy infrastructure programme have a specific version of the due diligence question: not whether the installation reduces energy costs, but whether it produces auditable Scope 2 data that a CSRD assurance provider can use without reprocessing. The answer is yes — but the mechanism is worth stating precisely.

What CSRD ESRS E1 requires on Scope 2

The Corporate Sustainability Reporting Directive (CSRD) requires companies to disclose both location-based and market-based Scope 2 emissions under ESRS E1-6. These are two distinct accounting methods:

Location-based Scope 2 uses the average emission factor of the local electricity grid — the carbon intensity of all the electricity flowing through the national grid in the reporting period. A company that draws 100 MWh from the UK grid in a period with a 200 gCO₂/kWh average factor carries 20 tonnes of location-based Scope 2 emissions.

Market-based Scope 2 uses the emission factor of specifically contracted electricity — from Guarantees of Origin (GoOs), Power Purchase Agreements with specified generation sources, or supplier-specific factors. A company holding GoOs for wind electricity carries zero market-based Scope 2 on the portion covered by the GoOs, regardless of what the grid average is.

ESRS E1-6 requires both figures to be reported. Neither can substitute for the other. And ESRS E1-6 is explicit: gross Scope 2 must be reported — no netting of credits against the consumption figure.

How on-site generation affects location-based Scope 2

On-site renewable generation reduces the building's metered grid import — the physical electricity drawn from the local distribution network. In the location-based method, less grid electricity consumed means a lower location-based Scope 2 figure, directly proportional to the reduction in grid import.

This is not a market-based mechanism. No GoO is required. No contracted renewable electricity tariff is needed. The location-based improvement flows from a physical fact: the building consumed X kWh less from the grid because X kWh was generated on-site and consumed directly.

Battery storage maximises the self-consumption of generated electricity — ensuring that the wind and solar generation is used within the building rather than exported to the grid at off-peak moments. Higher self-consumption means a larger reduction in grid import and a larger location-based Scope 2 benefit.

ESRS E1-6 disclosure format requirements

Under ESRS E1-6, companies must disclose:

HNordic's AI energy management system (EcoHub) records: generation by technology (wind, solar separately), self-consumption (kWh of generation consumed on-site), grid import (kWh drawn from the grid), and grid export (kWh supplied to the grid). These figures are exportable.

The specific data export format — whether it maps directly to GHG Protocol category headings in the form required by a CSRD assurance provider — should be confirmed with HNordic at the site assessment stage. EcoHub produces the underlying metered data; the format available for disclosure use is confirmed in the commercial agreement .

Guarantee of Origin compatibility

Companies holding GoOs for market-based Scope 2 reporting purposes may wonder whether on-site generation conflicts with or displaces those instruments. It does not.

GoOs are market-based instruments — they address the market-based Scope 2 figure. On-site generation addresses the location-based Scope 2 figure. These are two separate accounting columns. A company can hold GoOs for market-based purposes and install on-site generation for location-based improvement simultaneously — both improve the disclosure, neither cancels the other.

ESRS E1-6 requires disclosure of self-generated renewable electricity separately from purchased electricity — so the on-site generation must be reported as a distinct line, not netted against grid import.

EU Omnibus I and timing

The EU Omnibus I Directive (EU) 2026/470 amended CSRD scope and timelines. Large companies (those previously subject to NFRD) reported first on FY 2025 data. Medium and certain other companies begin in subsequent years depending on their category.

Companies whose first CSRD report covers FY 2026 or FY 2027 have a practical window: an energy infrastructure installation commissioned before the end of the first reporting year generates a full year of metered generation data for inclusion in the disclosure. The location-based Scope 2 improvement is real and auditable from the commissioning date.

Key takeaways

References

See also: What is MEES and the EPC B announcement? · What does the AI energy management system optimise against? · Full FAQ