Gas power pays full carbon price from day one — no free allocation, ever. At €77/t that's ≈€28/MWh inside the EU: carbon is now a fuel-sized line item, which puts heat rate back at the centre of plant economics. For the reporting desk that means: which frameworks bite, which KPI to disclose, and which completed measure to show. Here is the power profile.
| Framework | Applies to power? |
|---|---|
| EU ETS (if EU site) | Yes |
| CBAM (if exporting to EU) | Partially — electricity itself is a CBAM good when imported into the EU |
| SECR (if large UK company) | Yes — energy, Scope 1+2, intensity ratio, efficiency actions |
| ESOS (if large UK undertaking) | Yes — audit by 5 Dec 2027 (Phase 4) + public action plan |
| CSRD / ESRS E1 (if large EU company) | Yes — actions (E1-3), targets (E1-4), energy (E1-5), Scope 1-3 (E1-6) |
| Customer SBTi / CDP requests | Sector-independent — arrives with the RFQ |
The intensity ratio your sector benchmarks against: ≈0.37 t CO2/MWh at 55-60% efficiency (full ETS exposure). SECR requires an intensity metric of your choice; ESRS E1-5 wants energy per net revenue; CBAM (where in scope) uses exactly t CO2 per tonne of product. Reporting the same physical KPI everywhere keeps the numbers reconcilable — and auditors happy.
~100% of power CO2 is fuel-side — the share efficiency measures can touch. Heat-loss surveys typically recover 2–5% of fuel use, i.e. 2.0–5.0% of this sector's total CO2, at up to-2-year payback. Worked example at a 2,000,000 MWh/yr site (≈740,000 t CO2/yr at the benchmark intensity): an insulation programme is worth 14,800–37,000 t CO2e/yr — a complete, verifiable entry for SECR disclosure 4, an ESOS progress update, ESRS E1-3 and the tender CRP, plus €1,145,520+ off the carbon bill where ETS/CBAM applies.
Generate exact figures for your own kW finding: Carbon Savings Certificate → · sector decarbonization pathway: Power — gas (CCGT) →
