As 2030 looms nearer, the build-out of renewable energy is picking up pace. This has a knock-on effect for the guarantees of origin (GoO) market, as more GoOs are created and more companies and consumers are choosing to buy electricity from renewable energy sources.
The increase is already evident, with AIB reporting a 10% increase between the volume of GoOs in 2024 compared to the previous year, now reaching 1,084 TWh in total. This is consistent with the upward trend we’ve seen over the last number of years, and with this rise in the volume of GoOs comes stricter regulation of the GoO market to ensure that all GoOs are validated, fully auditable, and that there is no double counting of generation.
In this article, we’ll walk through the regulatory and other requirements you need to be aware of—for both your own compliance and that of your counterparties—if you trade or manage GoOs.
In short: Top regulatory requirements that you should know if you trade guarantees of origin
In case you don’t have time to read the full article, here’s a summary of the main regulations and voluntary standards relevant to companies that manage guarantees of origin (GoO) in 2026.
- RED III defines the principles for how Guarantees of Origin (GoOs) must be issued, transferred, and recognized across the EU. Each Member State must transpose RED III into national law and decide how these principles apply to its national registry, thus GoO rules still vary quite a lot from country to country.
- EECS is managed by AIB and provides the voluntary technical standard that national registries must follow, as well as standardizing how GoOs move between registries (via the AIB Hub).
- Corporate sustainability and disclosure requirements (such as the CSRD, ESRS, and EU Taxonomy) require transparent, accurate sharing of ESG data, and GoOs are often used to validate claims relating to the purchase and use of renewable energy.
- Market and trading frameworks such as MiFID II and REMIT are not relevant to most market participants, however companies who own or trade GoOs that are wrapped into financial products (e.g. derivatives or structured PPAs) must also ensure compliance with financial market rules.
- Country-specific rules determine how registries work in the country (e.g. who can issue GoOs), including the country’s own implementation of EU-wide regulations like RED III and the EECS voluntary standard, and also any additional measures it puts in place to ensure the GoO registry is fit for purpose e.g. Switzerland’s OGOM.
Together, these requirements are putting pressure on companies that manage GoOs to ensure their systems and processes are compliant with both existing and emerging regulations—which will continue to become more stringent as the GoO market grows. This is essential to both protect their own reputation and their clients’. We’ll now take a closer look at each of these in more detail.
EU-wide requirements that affect your guarantees of origin portfolio
The rules for guarantees of origin vary by country or specific registry, but there are a couple of overarching EU regulations and requirements that set the principles and standards for how GoOs are traded and managed across the region.
EU Renewable Energy Directive (RED III)
Adopted in 2023, the Renewable Energy Directive III (RED III) updates and strengthens the previous RED II framework and essentially sets out how the EU will reach its 2030 renewable energy targets.
Member States are responsible for transposing RED III into their national laws, which means that ultimately they define how guarantees of origin are issued, transferred, and recognized in their national registry.
The main RED III Directive provisions that are relevant to GoOs include:
- Renewable energy targets: increasing the EU’s binding renewable share to at least 42.5% of final energy consumption by 2030.
- National GoO registry: each Member State must appoint a competent authority to run a national registry responsible for issuing, transferring and canceling GoOs, with strict audit and verification obligations.
- GoO requirements: all GoOs must be unique, traceable, and valid for 12 months after the energy is produced (although this may vary between Member States).
- Mutual recognition: GoOs must be recognized across all Member States to enable cross-border trading, unless there is a valid reason to refuse recognition e.g. suspicion of fraud.
- Transparency: electricity suppliers must disclose their energy mix and associated GHG intensity, with GoOs to validate their disclosures.
Impact on GoO portfolio managers
While RED III mainly governs how registries operate, it still affects companies that buy, sell, or manage GoOs. First, it defines what information must be collected and validated by registries, and enables GoOs to be traded between any Member State in a standardized way.
Second, it increases the level of transparency that utilities must provide about their own energy mix, meaning they need to have a robust and accurate system to manage their GoOs.
Finally, by increasing the EU renewable energy target, RED III will lead to more renewable generation coming online and thus more GoOs entering into circulation. For portfolio managers, this likely means growing GoO portfolios and of course more complexity in managing them (unless they have an appropriate solution to help manage this, such as CerQlar).
European Energy Certificate System (EECS) Rules
Managed by the Association of Issuing Bodies (AIB), the EECS defines how the principles of RED III are applied in practice in registries by providing a common technical standard for the issuance, transfer, and cancellation of GoOs across Europe. Similar to RED III, Member States are responsible for implementing it in their national registry.
AIB also manages the AIB Hub, which is essentially a secure platform that all participating registries are connected to. This ensures that each GoO exists in only one registry at a time, and that all cross-border transfers are verified, traceable, and fully auditable.
Impact on GoO portfolio managers
Similar to RED III, EECS applies mainly to governance of the registries and the AIB Hub, but it is still relevant for companies that manage GoOs because it sets strict compliance requirements for how GoOs are managed within registries and across borders.
Corporate sustainability & disclosure rules
Many companies buy guarantees of origin to validate their claims of using renewable energy in their internal and external reporting. This means that corporate sustainability regulatory requirements like the Corporate Sustainability Reporting Directive (CSRD), European Sustainability Reporting Standards (ESRS), and EU Taxonomy may be relevant for companies that manage GoOs.
Here’s a quick overview of what each of these requirements is and why it’s relevant for your GoO portfolio:
CSRD requires certain large companies to disclose how they source renewable energy and reduce emissions, among many other ESG data points. GoOs are often used to provide the verified proof they need to back up claims of using renewable energy and/or as an input for calculating their total emissions.
ESRS determines the metrics and reporting formats that companies must use for CSRD reports. Again, accurate GoO data is typically used to back up the renewable energy and emissions figures that companies report.
EU Taxonomy defines which business activities can be considered ‘environmentally sustainable’, based on set criteria. GoOs can help companies demonstrate that their investments in certain activities meet the Taxonomy’s criteria (if the activities involve use of electricity).
So in summary, these requirements do not directly set rules for GoO management but accurate GoO data is often needed to ensure compliance with them.
Market-based and trading regulations
While GoOs are not classified as financial instruments under EU law, some companies own or trade GoOs that are wrapped into financial products, such as derivatives or structured PPAs.
In this case, frameworks such as MiFID II (Markets in Financial Instruments Directive) and REMIT (Regulation on Energy Market Integrity and Transparency) are applicable to prevent market manipulation and ensure GoO transactions are properly tracked and reported.
This isn’t yet a concern for most GoO portfolio managers, but it’s worth keeping in mind as GoOs may increasingly be treated like financial instruments as the market continues to grow over the next few years.
Country-specific requirements for GoOs
All EU Member States are responsible for transposing RED III into their own law and following the standards set out in EECS, however some countries have gone a step further and also introduced their own national requirements. These requirements usually relate to:
- Issuing practices: guidelines on who can buy GoOs, how often they’re issued (e.g. monthly or quarterly), what production data is required etc.
- Cancellation policies: rules for cancelling GoOs i.e. what is permitted and what is prohibited.
- Disclosure/reporting periods: deadlines for reporting on your energy mix or related data, which is usually annually but is more frequent in some jurisdictions.
We’ll now look at a few examples from countries with national requirements for their GoO registry or market participants.
Examples from some European countries
Switzerland: Ordinance on the Guarantee of Origin and Marking of Electricity (OGOM)
From 1 January 2027, the OGOM will be in effect in Switzerland, requiring companies to make quarterly rather than annual disclosures and GoO cancellations. The reason for this is to reflect the seasonality of energy production and consumption i.e. you’ll no longer be able to purchase solar energy GoOs in the summer for consumption in the winter.
It also introduces some other changes like a requirement for electricity suppliers to source part of their energy supply via Power Purchase Agreements (PPAs) if they don’t own generation assets.
However, it’s also important to note that Swiss companies can import GoOs from EU countries but cannot export their Swiss GoOs for cancellation and disclosure in the EU. This may change in the future, but for now unless you’re based in Switzerland, you cannot use Swiss GoOs to fulfill your renewable energy needs.
Denmark: Energy Track & Trace
In Denmark, the transmission system operator (TSO), Energinet, is responsible for issuing GoOs, and is a participating utility in a granular (hourly) GoOs pilot called Energy Track and Trace. The idea is to ‘create an international solution for tracking and tracing the origins of sustainable energy from source to consumer’, that enables hourly matching between actual production and consumption of electricity.
This concept of hourly GoO matching has been getting a lot of attention in the media in the last year but is not yet in force anywhere in the EU other than in pilots. However, pilots like this—which also involves TSOs from Germany, Belgium, and Estonia—may well influence a wider rollout of this across the EU in the future.
Netherlands: VertiCer’s full consumption disclosure model
The Netherlands is one of the countries that decided to apply a ‘full consumption disclosure model’ where every single MWh of power must have an origin certificate issued by VertiCer, which is either a guarantee of origin if it is renewable energy or a certificate of origin (CoO) if its non-renewable energy. Each GoO/CoO represents 1 MWh and is valid for one year after the month in which the energy was generated.
This requirement is important to understand if you produce or purchase any non-renewable energy for your consumption, as you have to track your certificates for both that and your renewable energy certificates (or GoOs).
How using CerQlar ensures your EAC management is fully auditable and compliant
Whether you’re managing a small or large GoO portfolio, as the GoO market grows it’s getting more and more complex to manage GoOs in compliance with the existing and expected regulations for both your own company and your counterparties.
CerQlar is a purpose-built platform that gives you a single source of truth for your GoO portfolio by integrating directly with 30+ registries and standardizing your GoO data. This enables teams to automatically reconcile your GoOs with registry data, and accurately capture, manage, and report on certificates in one secure, fully auditable system.
Here’s a quick summary of how CerQlar helps you comply with some of the requirements we’ve covered in this blog:
| Requirement | Relevant regulations or rules | How CerQlar helps |
|---|---|---|
| Standardized and validated GoO data | RED III, EECS | Centralized GoO inventory management enables standardized collection and management of GoO data from any registry |
Accurate reconciliation with national registries | RED III, EECS | Automated reconciliation with 30+ registries, even if they don’t have an API |
Exportable data with audit trail | CSRD, ESRS, EU Taxonomy | Easily export data in standardized formats with a complete audit trail of all user actions and GoO movements |
More frequent reporting | OGOM (Switzerland) and some other jurisdictions | Provides real-time visibility of your portfolio data so you can report accurately on your GoO activities, whether you need to report quarterly, annually, or at another frequency |
Hourly matching | Energy Track & Trace but potential to be rolled out more widely | Platform supports granular matching between GoOs and delivery obligations, even at an hourly basis |
Full consumption disclosure | VertiCer’s full consumption disclosure model (Netherlands) | Enables accurate tracking of GoOs in alignment with full consumption disclosure requirements |
Beyond compliance and efficiency improvements, using CerQlar helps you minimize the risk of errors and thus protect your reputation and avoid penalties or audit issues in the future.
Want to learn how you can manage your GoO portfolio efficiently while also ensuring compliance with relevant regulatory requirements? Book a demo with one of our experts to see how CerQlar can simplify your GoO management.
