Third-Party Attestation Strategy

Overview

The Granular Registry, owned and operated by Clean Incentive, is dedicated to providing high-integrity, transparent data for Scope 2 emissions reporting. Our SSS module delivers reliable, third-party verified estimates of retired Renewable Energy Certificates (RECs) and supplier-specific emission factors (SSEFs) for market-based GHG Protocol reporting. To ensure our outputs meet the highest quality standards and support seamless integration into your sustainability efforts, we are implementing a robust attestation strategy. This document outlines our approach to independent verification of methodologies, data processes, and calculations, aligned with evolving standards for granular and hourly-matched energy attributes as of mid-2025.

Our strategy focuses on building trust through phased third-party assurances, enabling users to confidently use our reports in audits and reduce internal validation burdens.

Key Concepts in Attestation

Audit-Level Rigor in GHG Scope 2 Reporting

Audit-level rigor involves systematic, independent verification to ensure the accuracy, completeness, and reliability of Scope 2 emissions data. It exceeds basic data gathering by confirming that emissions claims are free from material misstatements and align with GHG Protocol principles (relevance, completeness, consistency, transparency, and accuracy). This typically includes third-party assurance, ranging from limited (process reviews) to reasonable (full data testing similar to financial audits).

Key elements:

• Data Verification and Testing: Examination of source data (e.g., utility records, emission factors) via sampling, recalculation, and cross-checks against sources like EPA eGRID.

• Process and Internal Controls Review: Assessment of inventory systems to prevent errors or fraud.

• Third-Party Independence: Verifiers follow standards like ISO 14064-3 or AA1000AS.

• Documentation and Traceability: Full audit trails to address risks like double-counting.

• Materiality Assessment: Testing against thresholds (e.g., 5% of emissions).

While not mandatory, this rigor is essential for credible reporting under frameworks like SBTi or RE100.

Exclusive Ownership Attestation

This process ensures emission attributes (e.g., zero-emission claims from renewables) are uniquely assigned to one entity, preventing double-counting. It confirms attributes are retired exclusively for the reporting entity.

Core aspects:

• Attestation Mechanisms: Supplier declarations, third-party audits, or registry confirmations.

• No Double-Counting Assurance: Evidence that attributes are not claimed elsewhere.

• Implications for Claims: Essential for valid market-based claims, linking to criteria like temporal matching.

Attestation Roadmap

We are pursuing the following milestones to attest our SSS module, starting with foundational controls and advancing to GHG-specific assurances. Initial completions are targeted for Q4 2025.

SOC 2 Type II Report (Target: Q4 2025)

An independent audit evaluating controls for security, availability, integrity, confidentiality, and privacy, covering:

• Data sourcing from public and regulatory sources (e.g., EIA forms, RPS reports).

• Estimation workflows for RECs and SSEFs, including pro-rata allocations.

• Measures to prevent double-counting and ensure accuracy.

ISAE 3000/3410 Assurance Engagement (Target: Q1 2026)

Tailored assurance for non-financial data like GHG emissions, providing limited or reasonable assurance on:

• Compliance with GHG Protocol Scope 2 Guidance.

• Accuracy of SSS processes, such as non-bypassable charges and hourly proxies.

• Sample verifications of outputs like SSEFs and time-stamped RECs.

Ongoing GHG Protocol Alignment and Enhancements (Annual Reviews Starting 2026)

Incorporating WRI feedback and protocol updates, with extensions to hourly features for 24/7 matching.

Benefits to Our Users

Our attestations deliver value by simplifying net-zero pathways and minimizing reporting risks.

• Audit-Ready Outputs: Verified reports meet GHG Protocol criteria for credible datasets, allowing auditors to rely on our assurances.

• Enhanced Compliance and Transparency: Robust claims for SSS-embedded energy, supporting stakeholder confidence amid regulations like SEC disclosures.

• Time and Cost Efficiency: Outsource validation, freeing teams for strategic tasks like REC optimization.

Dimension	Verified (supplier-verified + third-party)	Public data-based
Assurance level	Limited/Reasonable under ISO 14064-3 or AA1000AS	None; self-verified
Data testing	Sampling, recalculation, traceable audit trail	Desktop QA; no independent sampling
Ownership attestation	Exclusive ownership/retirement attested; registry confirmations	Not guaranteed; potential residual mix conflicts
Double-counting risk	Explicitly tested and mitigated	Higher; depends on public disclosures
Uncertainty/materiality	Target ≤5–10% uncertainty; ~5% materiality threshold	Variable; can exceed thresholds
Audit effort	Lower—auditors rely on our attestations	Higher—auditors re-perform checks
Compliance readiness	Supports SBTi, RE100, SEC expectations	May be challenged/limited use
Strategic value	Enables premium claims, green financing	Baseline compliance only
Cost/effort	Higher fee, lower internal effort	Lower fee, higher internal effort
Update cadence	Attestation-aligned, annual+ reviews	Public release cycles (lag risk)

Practical Benefits of Verified Audit-Level Reports vs. Public Data-Based Reports

Verified reports (using supplier-provided data with third-party assurance) offer advantages over public data-based reports (from sources like EIA Form 861 or EPA eGRID) in credibility, risk mitigation, and value.

• Credibility and Compliance: Independent assurance ensures accuracy and standards compliance (e.g., SBTi); public data may lack verification, risking challenges.

• Risk Mitigation: Minimizes misstatement risks; public data can introduce uncertainties like outdated information.

• Strategic Value: Enables premium claims for investors or financing; public data supports basic compliance.

• Cost vs. Effort: Public data is low-cost but intensive; verified reports streamline processes despite added expense.

We recommend verified reports for high-stakes users to leverage our Granular Registry effectively.

Levels of Attestation and Rigor

• Public Data Reports: Limited rigor; self-verified sources with basic attestation, higher error risk.

• Utility-Verified Reports: High rigor; third-party independence, full testing, and exclusive ownership attestation for defensible claims.

Conclusion

Through this strategy, Clean Incentive ensures the Granular Registry provides reliable, attested tools for Scope 2 reporting. Contact us for updates or customization.