New supervisory framework for Guarantees of Origin for renewable gas

The Commission for Regulation of Utilities has published its Supervisory Framework for Guarantees of Origin for Renewable Gas, marking a significant step in the development of Ireland’s renewable gas market ahead of the new regime taking effect in January 2027. Our Energy team examines the key features of the framework, including the certification, trading and registry arrangements that will shape how renewable gas is verified, traded and disclosed in the years ahead.

What you need to know

• The CRU’s new Supervisory Framework establishes the rules governing the issuance, transfer and cancellation of Guarantees of Origin for Renewable Gas (gGOs), with the new registry expected to go live by January 2027.
• Renewable gas producers, traders and suppliers will be able to participate in the registry, but only producers can receive issued gGOs and only licensed suppliers can cancel them for fuel mix disclosure purposes.
• A valid sustainability certificate from an approved EU Voluntary Scheme will be required before gGOs can be issued, reinforcing traceability and compliance requirements across the renewable gas market.
• The framework confirms that gGOs will only apply to renewable gas injected into the grid and that trading with the UK will not be permitted, reflecting the post-Brexit non-recognition of guarantees of origin between the EU and UK.

The Commission for Regulation of Utilities (CRU) recently established a Supervisory Framework for Guarantees of Origin for Renewable Gas[1]. Guarantees of origin for renewable gas, or ‘gGOs’, are electronic certificates that represent one MWh of renewable gas produced and injected into the network. Gas Networks Ireland (GNI), as the issuing body for gGOs, will operate the new electronic registry under the framework.

Key features of the Framework

1. Registry and account holders

Producers, traders, and suppliers will all be able to hold accounts in the registry and have the ability to transfer gGOs freely. However, only producers may have gGOs issued to them, and only licensed suppliers may cancel gGOs, as they alone are subject to fuel mix disclosure obligations.

Account holders will ultimately be able to request GNI to export or import gGOs to or from the national registries of other EU Member States, the EEA and other third countries that have an agreement in place with the EU.

2. Sustainability certification

A valid sustainability certificate from an EU Voluntary Scheme is required before a gGO can be issued, e.g. from ISCC, SURE, or REDcert. Installations with a total rated thermal input under 2MW are automatically deemed to meet the sustainability criteria. Imported gGOs will also require sustainability certification, following transposition of the 2024 Internal Gas Market Directive (Directive (EU) 2024/1788).

3. Issuance

gGOs will be issued monthly by GNI, aligning with the existing electricity Guarantees of Origin framework. Where multiple plants share an injection point, GNI will seek further information to allocate volumes to the appropriate facilities.

4. Annual fees

• Producers: €2,000 per year, payable in advance
• Suppliers and traders: €3,000 per year, payable in advance

GNI will review fees during each Price Control cycle.

5. Limitations

The framework applies to grid-injected renewable gas only, and non-grid injected gas is excluded.

Trading with the UK is not permitted, reflecting the mutual non-recognition of renewable energy guarantees of origin between the EU and UK post-Brexit.

Fuel mix disclosure and Green Source Product Verification process

Fuel mix disclosure involves calculating and disclosing the mix of renewable and non-renewable energy sources used to produce gas that is supplied to customers. The CRU will consult separately on a fuel mix disclosure regime for gas suppliers. Depending on the approach taken to the fuel mix disclosure framework, a separate Green Source Product Verification process may also be introduced. This process would verify that renewable energy claims by suppliers are backed by gGOs. The CRU intends to align these processes as closely as possible with the equivalent electricity frameworks.

Next steps and key dates

GNI launched a pilot registry in May 2020 to track the first volumes of biomethane injected into the Irish gas grid. This pilot registry will continue to run in parallel with the new registry for a transitional period before being wound down. The CRU also notes that GNI may continue to use the pilot registry for issuing Proofs of Origin on an interim basis for both the Renewable Transport Fuel Obligation and EU Emissions Trading System sectors, until the new Union Database (UDB) is established at EU level.

The CRU has also flagged that the supervisory framework will need to be updated further in the near future, including to account for:

• The transposition of RED III (Directive EU 2023/2413) and of the 2024 Internal Gas Market Directive (which must be transposed by August 2026)
• The establishment of the UDB and details of how this will interface with the national registries, and
• Any requirements of the Renewable Heat Obligation scheme.

For more information on the Guarantees of Origin framework for renewable gas and its implications for market participants, please contact a member of our Energy team.

The content of this article is provided for information purposes only and does not constitute legal or other advice.

[1] As required under the European Union (Renewable Energy) Regulations (2) 2022 (S.I 350/2022) (as amended)