Adoption of Financial VPPAs
- What Treasury teams need to know
Author: Federico Bellanti
May 26, 2025
Why VPPAs are entering the Treasury Function
In recent years, energy-intensive industrial companies — particularly in the manufacturing sector — have shown growing interest in long-term energy procurement instruments such as Power Purchase Agreements (PPAs) and, more notably, Virtual Power Purchase Agreements (VPPAs). The motivation is threefold: a strategy to contain energy costs in volatile markets, the desire to actively support the energy transition, and, not least, the need to enhance their sustainability profile and ESG disclosures — especially with regard to Scope 2 emissions.
Among the various contractual options available, VPPAs are particularly attractive to companies that wish to maintain their existing physical procurement arrangements while adding price hedging exposure linked to a renewable asset — whether solar or wind. Unlike physical PPAs, which involve the physical delivery of electricity and grid interaction, VPPAs are purely financial contracts. They operate as contracts for difference, settling the difference between a fixed contractual price and a market-based energy price at a specific geographical zone and time.
It is precisely this financial nature that makes them directly relevant to the Treasury function, which — even if not initially involved in the project (often initiated by ESG or industrial teams) — becomes responsible for the instrument’s accounting, regulatory compliance, and valuation. In most cases, VPPAs meet the definition of a derivative under IFRS 9, with few exceptions, and therefore fall squarely within the governance responsibilities of the CFO and Treasurer.
This article focuses exclusively on VPPAs that qualify as derivatives, and are therefore subject to periodic fair value measurement and potentially eligible for hedge accounting treatment. Physically delivered PPAs will be referenced only incidentally, specifically in borderline scenarios where such contracts may fail to qualify for the Own Use Exemption and must be treated in the same way as a derivative.
What follows is a walkthrough of the entire VPPA lifecycle from a Treasury perspective — from contractual structure, mark-to-market (MtM) valuation, and IFRS 9 accounting treatment, to disclosure and governance considerations. The discussion remains operationally focused, without compromising technical rigor.
One Contract, Two Natures: Physical vs. Financial
In the landscape of long-term energy procurement, the term “PPA” is often used generically — yet it encompasses contracts that differ profoundly in form and impact. It is essential to distinguish between:
- Physical PPA: An energy purchase agreement that involves the
physical delivery of electricity to the buyer, typically via a third-party trader or supplier. The primary purpose is industrial, offering benefits such as cost stabilization and renewable energy sourcing. These contracts can often qualify for the Own Use Exemption, thus avoiding treatment as financial instruments.
- VPPA (Virtual Power Purchase Agreement): A financial instrument, structured as a contract for difference, which does not involve physical delivery. The buyer continues to purchase electricity through their traditional supplier, while the VPPA settles in cash the difference between the fixed price and the spot price at a designated market point (e.g. Northern Zone, PEAK period). The aim is to “mirror” the output of a renewable facility against corporate electricity usage — for ESG and financial hedging purposes.
This distinction has important accounting implications:
Characteristic | Physical PPA | VPPA (financial) |
---|---|---|
Physical delivery | And | No |
Own Use Exemption (OUE) | Often applicable | Generally not applicable |
IFRS Qualification | Commercial contract | Derivative (IFRS 9) |
Fair value measurement | Not required if under OUE | Mandatory |
Potential Hedge Accounting | Only if outside OUE and classified as derivative | Generally applicable (post-amendment) |
In most cases, VPPAs do not meet the criteria for the Own Use Exemption: there is no physical delivery, nor are the contracts linked to direct operational use of the energy, as required under IFRS 9. Accordingly, they are treated as derivatives for accounting purposes, subject to periodic fair value measurement with direct impact on profit or loss (FVTPL), unless designated within a hedge accounting relationship.
This article therefore focuses on VPPAs treated as derivatives, and explores their accounting, operational, and regulatory implications.
When the Contract Falls Under IFRS 9
When a company enters into a VPPA structured as a contract for difference (CfD), it will, in nearly all cases, be classified as a derivative instrument under IFRS 9.
The
Own Use Exemption, which allows companies to exclude certain contracts from fair value accounting if they are for physical self-use, is generally not applicable in the case of VPPAs, because:
- There is
no physical delivery of energy;
- The economic purpose is not tied to operational supply;
- The contract settles in cash based on the difference between a fixed and floating price.
As such, the VPPA:
- Falls within the
scope of IFRS 9
from the outset;
- Must be
measured at fair value;
- Requires appropriate documentation, ongoing monitoring, and — if applicable — designation as a hedge.
Whether hedge accounting is available, and under what conditions, depends on the version of the IFRS 9 standard in force at the time of designation.
For a detailed discussion of the December 2024 amendment to IFRS 9 and its implications, see the next section: “A Paradigm Shift: What Has Changed Under the IASB”.
From Price Risk to Accounting: The Role of Treasury
For many companies, a VPPA initiative is led by ESG or Operations teams, with the goal of reducing carbon emissions, enhancing sustainability reporting, and locking in long-term energy costs.
However, when the VPPA qualifies as a financial instrument — and, as shown, is classified as a derivative under IFRS 9 — the operational responsibility inevitably shifts to the Treasury function.
This is because a VPPA is not merely a sustainability contract. It is a financial instrument, subject to mark-to-market valuation, potentially volatile, and requiring precise accounting, valuation, and regulatory oversight.
From physical to market risk
A VPPA introduces a new risk exposure to the company’s financials: the differential between a fixed contractual price and a floating market price — applied to an output volume that, in the case of solar or wind, is inherently variable and uncertain.
This creates a form of
market risk that Treasury must:
- Monitor through periodic fair value estimates;
- Evaluate using forecast models (typically
Level 3 inputs);
- Reflect in the company’s accounting systems;
- Justify to auditors, audit committees, and — where relevant — regulators.
The Trade-Off: Volatility vs. Accounting Protection
Without hedge accounting, fair value changes are fully recognized through profit or loss (FVTPL), potentially introducing volatility and disconnect between operational economics and reported earnings.
That’s why Treasury must assess — even at contract inception — whether hedge accounting can be applied. If the new IFRS 9 amendment has been endorsed and adopted, this may simplify the path; otherwise, the older, more restrictive rules still apply.
The decision is not only an accounting one — it is a strategic risk management choice, requiring collaboration across Finance, Risk, Sustainability, and Legal, supported by a clear governance structure.
Go to the next page to learn about the news introduced by the IASB