The measurement of semiconductor sensitized solar cells (SSSC) using a liquid electrolyte, has been several time incorrectly reported, because the voltage was refered to a reference electrode. Then it can have any value! (depending on the RE chosen) and the power conversion efficiency is arbitrarily high. A couple of years back a paper in JACS showed such mistake. Now an excellent paper in JPCLby the master Gary Hodes clarifies every detail of the measurement. If you make photoelectrochemical measurements you must read it.
Photoelectrochemical Cell Measurements: Getting the Basics Right3 05 2012