Third-Party Attestation Strategy

Overview

The Granular Registry is committed to delivering the highest standards of data integrity and transparency. The SSS module is designed to provide reliable, third-party verified estimates of retired RECs and supplier-specific emission factors (SSEFs) for market-based Scope 2 emissions reporting. To ensure our outputs meet rigorous quality criteria under the GHG Protocol and support seamless integration into your sustainability reporting, we are pursuing a comprehensive attestation strategy. This roadmap outlines our planned third-party assurances, aligning with evolving standards for granular and hourly-matched energy attribute tracking as of mid-2025.

Our approach emphasizes independent verification of our methodology, data collection processes, and calculation workflows. By obtaining these attestations, you can confidently reference Granular Registry reports in your audits, reducing the need for additional internal validations and enhancing the credibility of your carbon accounting claims.

Attestation Roadmap

We are actively working toward the following milestones to attest the SSS module's processes and outputs. This phased plan establishes foundational controls and progresses to specialized GHG-focused assurances, with initial attestations targeted for completion by the end of Q4 2025.

SOC 2 Type II Report (Target: Q4 2025)

This attestation, conducted by an independent auditor, will evaluate our system and organization controls for security, availability, processing integrity, confidentiality, and privacy. The SSS module it will cover:

• Data sourcing from public and regulatory sources (e.g., EIA forms, RPS compliance reports, and certificate-tracking systems).

• Estimation workflows for REC volumes and SSEFs, including pro-rata allocations based on retail sales.

• Quality assurance measures are implemented to prevent double-counting and ensure data accuracy.

• A Type II report provides evidence of effective controls over a sustained period, offering you assurance that our platform operates reliably and securely.

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

Building on the SOC 2 foundation, we will seek assurance under the International Standard on Assurance Engagements (ISAE) 3000/3410, which is tailored for non-financial information, such as GHG emissions data. This will provide limited or reasonable assurance on:

• Compliance with GHG Protocol Scope 2 Guidance, including quality criteria for market-based claims (e.g., auditability, representativeness, and alignment with residual mix factors).

• The accuracy of SSS-specific processes, such as quantifying non-bypassable charges, customer-funded resources, and optional hourly proxies for tracking carbon-free energy on an hourly basis.

• Sample verifications of outputs, like SSEFs and time-stamped REC allocations, to confirm they reflect real-world utility data.

• This GHG-specific attestation will be performed by an accredited verifier, ensuring our module supports precise, defensible Scope 2 reporting.

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

We will integrate feedback from the World Resources Institute (WRI) and updates to the GHG Protocol, including drafts for granular certificates. Annual reviews will update our attestations to incorporate policy changes (e.g., new RPS mandates or zero-emission credit programs). As hourly data becomes more prevalent, we plan to extend assurances to time-stamped features, positioning the SSS module as a leader in 24/7 energy matching.

Benefits to Our Users

By pursuing these attestations, we aim to deliver tangible value to energy buyers like you, simplifying your path to net zero while minimizing risks in reporting:

• Audit-Ready Outputs: Our verified reports and datasets can be directly referenced in your Scope 2 audits, meeting GHG Protocol requirements for "credible third-party datasets." This reduces the scrutiny on your end, as auditors can rely on our independent assurances rather than re-verifying underlying data.

• Enhanced Compliance and Transparency: Attested processes ensure your claims on SSS-embedded carbon-free energy (e.g., pro-rata shares of RPS RECs or nuclear credits) are robust and aligned with market-based accounting standards. This supports stakeholder confidence, especially in the face of increasing regulatory demands, such as SEC climate disclosures.

• Time and Cost Efficiency: Outsource the heavy lifting of data validation and methodology adherence to us. With our attestations, your sustainability teams can focus on strategic goals, such as optimizing REC purchases or expanding granular tracking, without having to duplicate verification efforts.