Can Open Access Improve ESG Scores Too?

India’s ESG disclosure regime is tightening faster than most industrial energy buyers realise. Understanding how green open access connects to Scope 2 emissions accounting is no longer a question for sustainability teams alone — it belongs in the energy procurement conversation.

What BRSR Core Actually Requires on Scope 2

Most conversations about open access in India begin and end with tariff economics: exchange clearing price, minus wheeling and cross-subsidy surcharge, versus the DISCOM tariff. That comparison is important. What is less frequently part of the conversation is the carbon accounting implication of the procurement decision.

India’s ESG disclosure framework has changed materially. SEBI introduced the Business Responsibility and Sustainability Reporting (BRSR) framework in 2021 and tightened it in July 2023 with the BRSR Core — a refined subset of 49 Key Performance Indicators. Scope 2 electricity emissions — the indirect emissions attributable to purchased electricity from the grid — are now a mandatory reported figure for India’s top 1,000 listed companies under the SEBI (LODR) Regulations, 2015.

The grid emission factor against which Scope 2 emissions are calculated has a specific, mandated source. SEBI’s BRSR Core Industry Standards, issued via SEBI Circular dated December 20, 2024, explicitly require companies to use Central Electricity Authority (CEA)-published grid emission factors for Scope 2 grid power reporting. India’s national grid weighted average emission factor for FY 2023–24 stands at 0.727 tCO₂/MWh, per CEA’s CO₂ Baseline Database (Version 20.0, December 2024).

The compliance quality gap is telling. A joint analysis by the Indian Institute of Corporate Affairs (IICA) and the Council on Energy, Environment and Water (CEEW), published in November 2025, found that while 998 of the 1,000 mandated companies filed BRSR for 2024, only 781 disclosed Scope 1 and 2 emissions — figures that have been mandatory since FY 2023–24. As third-party assessment requirements tighten, companies without credible Scope 2 accounting practices will face increasing scrutiny.

A listed industrial company consuming 10,000 MWh annually from the DISCOM grid must report approximately 7,270 tCO₂ in Scope 2 emissions against the FY 2023–24 CEA factor. That figure is assessed, third-party verified, read by institutional investors — and increasingly read by that company’s own customers. The BRSR Core value chain disclosure framework, applicable from FY 2025–26, requires the top 250 listed companies to report on ESG performance of value chain partners accounting for ≥2% of purchases or sales.

The Open Access–Scope 2 Connection

Scope 2 emissions are indirect emissions from purchased electricity. Under the GHG Protocol — which SEBI’s BRSR Core recommends, though does not strictly require — there are two calculation methods. The location-based method uses grid average emission factors (in India, the CEA factor). The market-based method uses supplier-specific factors, including through contractual instruments such as power purchase agreements and energy attribute certificates.

This distinction matters for what green open access can achieve. Under the location-based method alone, a facility consuming DISCOM grid power and a facility consuming verified renewable energy through green open access would report identical Scope 2 emissions — both would apply 0.727 tCO₂/MWh. Under the market-based method, a facility that holds documented proof of verified renewable procurement can report a Scope 2 emission factor of zero for the attributed renewable units.

In India’s regulatory architecture, that documentation takes the form of Renewable Energy Certificates (RECs) issued under the CERC REC Framework, or the green certificate issued to consumers under the Green Energy Open Access Rules, 2022. SEBI’s current framework permits but does not mandate the market-based method. The December 2024 Industry Standards require CEA factors for grid power, and separately require companies to classify renewable and non-renewable energy. The market-based route is where green open access can materially move the Scope 2 number in a way that survives third-party assessment.

India’s Green Open Access Architecture

The Electricity (Promoting Renewable Energy Through Green Energy Open Access) Rules, 2022, notified by the Ministry of Power on June 6, 2022, made a structural change that goes unremarked in commercial conversations: they reduced the minimum consumption threshold for open access transactions from 1 MW to 100 kW. Any consumer with a contracted demand of 100 kW or more is now eligible to procure renewable power through open access.

The rules also capped Cross-Subsidy Surcharge (CSS) for green open access consumers and removed the additional surcharge. Applications are processed through the GOAR portal (greenopenaccess.in), operated by Grid-India as the central nodal agency, with a mandated 15-day approval period — or deemed approval if the deadline lapses. A consumer who procures verified renewable electricity and holds the green certificate issued under these rules has the foundational documentation required for a market-based Scope 2 claim.

The reduction in eligibility threshold from 1 MW to 100 kW is not just a tariff reform. It is a carbon accounting reform. A manufacturing plant with a 250 kW connection can now access green power, hold the documentation proving it, and use that documentation in Scope 2 market-based accounting. The market that existed before 2022 was simply too narrow for most C&I buyers to access this route.

The Carbon Market Dimension

India is operationalising a compliance carbon market. The Ministry of Environment, Forest and Climate Change (MoEFCC)’s draft Greenhouse Gas Emission Intensity (GEI) Rules, 2024, put forward legally binding emission reduction targets for over 450 industrial entities beginning FY 2025–26. These rules form the backbone of India’s Carbon Credit Trading Scheme (CCTS), established under the Energy Conservation (Amendment) Act, 2022, with the Bureau of Energy Efficiency (BEE) as nodal agency for baseline setting, credit validation, and compliance checks.

The transition from the Perform, Achieve and Trade (PAT) scheme — which focused on improving specific energy consumption — to the GEI framework is a qualitative shift. Under PAT, the question was whether you used energy more efficiently. Under GEI, the question is whether your carbon intensity of production falls within a mandated limit. Non-compliance attracts a financial penalty set at twice the prevailing market price of carbon credits.

Renewable energy procurement through green open access has a direct role in GEI compliance. Reducing the carbon content of consumed electricity reduces the numerator of the intensity ratio — tonnes of CO₂ per tonne of output, per unit of revenue, or per unit of production. Industrial buyers in energy-intensive sectors — cement, steel, aluminium, textiles, petrochemicals — are the primary GEI targets. For them, green open access is not a voluntary ESG gesture. It is an emissions management tool with a calculable compliance value.

Value Chain Pressure and CBAM

SEBI’s BRSR Core value chain framework, applicable from FY 2025–26, requires the top 250 listed companies to report on ESG performance of their major suppliers and customers. A large FMCG, automobile, or pharmaceutical group with that obligation will begin asking its top suppliers — many unlisted mid-sized manufacturers — for emissions data. The question will be specific: what share of your electricity is renewable, and how is it documented?

This creates a cascade effect. An unlisted manufacturing plant with 500 kW of connected load may find its continued status as a supplier to a large listed buyer depends on its ability to produce credible renewable procurement documentation. Green open access, properly structured, is the most cost-effective route to that documentation in the Indian context. The financial incentive — lower power cost — and the commercial incentive — maintaining supply chain relationships — now point in the same direction.

The EU Carbon Border Adjustment Mechanism (CBAM), which entered its transitional phase in October 2023 and becomes fully operational from 2026, adds a third dimension for export-oriented manufacturers. CBAM applies to cement, steel, aluminium, fertilisers, electricity, and hydrogen, requiring importers to declare embedded carbon content. A steel plant exporting to the EU must demonstrate the carbon intensity of its production process, including Scope 2 emissions from electricity consumption. DISCOM power at India’s national average grid emission factor is a documented liability in that calculation. Verified renewable procurement through green open access is a documented offset against it.

For export-oriented industrial buyers in CBAM-covered sectors, the carbon documentation value of green open access procurement now extends beyond domestic ESG ratings. It is a direct input into customs declarations at the EU border from 2026 onwards.

What the Market Data Shows — and What Remains Unresolved

India’s C&I open access market has grown at a compound annual growth rate of 46% from FY 2022 to FY 2024, reaching cumulative installed capacity of 18.7 GW by end-FY 2024, per IEEFA and JMK Research’s joint analysis (December 2024). The solar open access segment alone crossed ~30 GW by March 2025, per Mercom India Research. The supply side is maturing rapidly — a C&I buyer seeking to shift from location-based to market-based Scope 2 accounting has an expanding pool of long-term renewable PPAs and short-term instruments through IEX’s Green Day-Ahead Market (GDAM) and Green Term-Ahead Market (GTAM).

There are genuine complications in this picture that merit acknowledgement. India’s BRSR framework does not yet mandate the market-based Scope 2 method — it permits it but does not require it. Until SEBI explicitly mandates the market-based method, companies making market-based claims must be prepared to defend the accounting basis under third-party assessment. State inconsistencies in GEOA Rules implementation are also real: as IEEFA and JMK Research documented, several states including Tamil Nadu, Karnataka, and Uttar Pradesh do not fully adhere to the central 100 kW eligibility threshold, and approval timelines frequently exceed the mandated 15-day window.

Not all documentation supporting market-based Scope 2 accounting carries equal weight. RECs issued under the CERC REC Framework and the green certificate under the GEOA Rules, 2022 are the primary domestic instruments. I-RECs are used by multinationals with global reporting obligations. The quality of the claim depends on the instrument — unbundled RECs purchased after the fact carry different additionality arguments than a direct long-term PPA with a renewable generator. Companies aiming for assessed BRSR Core disclosures should be clear-eyed about what their chosen instrument will support under scrutiny.

The Structural Point

Open access, in isolation, does not automatically produce a better ESG outcome in any reported metric. What it does is create the conditions for a verifiable, documented shift in Scope 2 emissions that can be disclosed under market-based accounting and defended under third-party assessment.

When those conditions are met, the benefit is material. For a manufacturing plant consuming 5,000 MWh annually, shifting 3,000 MWh to verified green open access reduces its market-based Scope 2 attributed emissions from approximately 3,635 tCO₂ to approximately 1,454 tCO₂ — a 60% reduction in the electricity emissions portion of the disclosure. In the context of an assessed BRSR Core filing, an ESG rating review, a value chain enquiry from a large listed buyer, or a CBAM declaration, that is a substantive change in documented climate position.

India’s regulatory architecture — the GEOA Rules, the BRSR Core, the CCTS framework, and the CEA grid emission factor methodology — has created conditions where the commercial and climate incentives for renewable procurement through open access are more closely aligned than at any previous point. The industrial buyers who recognise both simultaneously will be better positioned than those optimising for only one.