CRS Listed Updates and Greenhouse Gas Protocol Open Consultation
This notification was sent to all current Green-e® Energy Participants and CRS Listed Facilities to highlight changes that have been made to the CRS Listed tracking attestation process over the last year, which are intended to make use of CRS Listed easier and clearer.
In addition, CRS staff wants generators and sellers to be aware that the World Resources Institute is holding a consultation for the Greenhouse Gas Protocol Scope 2 Guidance, which could have a significant impact on REC markets.
GHG Protocol Public Consultation: Your Voice Matters
The GHG Protocol has opened a public consultation on proposed updates to its Scope 2 Guidance—changes that could have major implications for renewable energy generators and the voluntary clean energy market. The draft includes new “physical deliverability” rules that could limit where RECs can be sold, and an “hourly matching” requirement that could restrict how renewable generation is recognized and claimed. Both proposals risk narrowing markets and reducing the value of voluntary clean energy purchases, potentially affecting generator revenues.
CRS encourages all renewable energy owners and operators to review the proposed updates and share feedback with WRI before the December 19, 2025 deadline. Learn more and read CRS’s detailed perspective in our latest blog post.
CRS Listed Updates
New URL and Easier Renewals
The CRS Listed application form has been updated to offer a streamlined process for renewals, by preserving fields from the previous submission that are not required to be edited when renewing for the next effective period.
You can access the updated process on the CRS Listed Facilities webpage.
When selecting “Submit A CRS Listed Tracking Attestation,” you will be directed to a page where you will select whether you are submitting a New Application or a Renewal. No changes have been made to the original form if submitting a new attestation. When “Renewal” is selected, the page will request the Tracking System and Tracking System ID of the facility being renewed, and it will display general information about the facility to confirm. From there, the form will autofill fields that are publicly displayed on the CRS Listed webpage. If a facility’s information is not displayed when entering the Tracking System and Tracking System ID, then please reach out to forms@green-e.org for assistance, or check to ensure an attestation is already on file for that facility.
Easier Payments
The Stripe platform is used to process “Invoice Me” payment options during the CRS Listed attestation process. When selecting this option, a digital invoice is generated at the beginning of every week and emailed to the primary contact listed on the attestation. Attestation submissions that contain the same Primary Contact Information will have their processing fees consolidated into one invoice (unless requested otherwise via forms@green-e.org). Reminder emails are sent after 30 days of the invoice being sent out. Alternatively, you can pay instantly via Credit Card, which allows for a faster review from CRS. A facility”s attestation, whether new or a renewal, cannot be reviewed unless invoices are paid.
The Stripe invoice can be paid via ACH or Credit Card. If any additional requests regarding payment are necessary for consideration, please reach out to forms@green-e.org.
2026 Attestation Fees
As a reminder, the CRS Listed Tracking Attestations fee typically increases each year. On January 1, 2026, the processing fee will increase to $300. Facilities that will have their attestation expire at the end of 2025 may submit a renewal form before 1/1/2026 and pay the $225 fee before the increase takes effect.
To Know: Green-e vs. CRS Listed
While CRS Listed facilities meet some of the requirements for having their generation used in a Green-e® Energy certified product, the facilities themselves are not “Green-e® certified” (or otherwise certified by CRS), and additional criteria are reviewed as part of the facility’s use in a Green-e® Energy certified sale during the Green-e® Energy Verification Audit.
To help clarify the difference between CRS Listed Facilities and Green-e® Energy certified sales, CRS has published a one-pager comparing these options, also available on the CRS Listed Facilities webpage. The document also outlines the benefits of Green-e® Energy certification and clarifies the language that is preferred by CRS when marketing Green-e® Energy products and CRS Listed Facility’s supply.
Call for Feedback on CRS Listed
CRS staff is looking for your input on how you would like to see CRS Listed evolve over time. How can it be used better in its current state? What modifications are you interested in seeing? What information would you like to see on the list? If you are interested in having a discussion with CRS staff to provide any feedback about CRS Listed, please email forms@green-e.org to start the discussion.