This service is for producers, suppliers, traders, and corporate buyers who use Guarantees of Origin (GOs), green certificates, or other support mechanisms and need to verify compliance, prepare for audits, correct issues, or handle disputes. We focus on documentation, eligibility, chain of custody, and practical remediation steps.
The information is general and does not replace legal advice. Facts, documents and chronology matter.
When you need this
- You need to set up or review your GO workflow (issuance, transfer, cancellation, claims).
- You received audit questions or findings about eligibility or documentation.
- There are discrepancies between production data and issued certificates or public claims.
- You must correct historical claims in contracts, marketing materials, or disclosures.
- You negotiate certificate clauses in supply or PPA contracts (quality, vintage, cancellation, remedies).
- A counterparty disputes delivery, cancellation, or warranties related to certificates.
- You want a documented approach to handle authority communications and remediation.
What we do in practice
- Clarify the applicable framework (national GO rules, EU renewable energy rules, and scheme-specific requirements).
- Review eligibility and documentation: facility data, commissioning, metering, and reporting.
- Check chain of custody in the registry: issuance, transfers, cancellations, and evidence of claims.
- Draft or review contract clauses on certificates (delivery, warranties, audit rights, remedies, dispute handling).
- Support corrections and remediation: evidence reconstruction, updated records, and consistent communications.
- Prepare audit-ready documentation packs and a clear chronology.
- Support disputes with counterparties or authorities: structured file, negotiation, and procedural options.
Documents / information useful for the first review
| Document | Why it matters | Notes |
|---|---|---|
| Facility identification and licensing documents | Defines eligible facility and scope | Include amendments, ownership history, and commissioning data |
| Metering and production data plus reports | Basis for certificate issuance and audits | Keep versions and validation records |
| Registry statements (issuance, transfer, cancellation) | Proves chain of custody and claims | Export logs with unique identifiers |
| Support scheme approvals (if applicable) | Shows eligibility for scheme benefits and conditions | Include compliance reports and correspondence |
| Supply, PPA, or trading contracts | Defines certificate obligations, warranties, and remedies | Check definitions of quality and vintage |
| External claims and disclosures | Matches marketing and reporting to evidence | Keep copies of web pages and reports for the relevant period |
| Audit communications or findings | Defines issues to be addressed | Preserve originals and attachments |
Risks and frequent mistakes
- Making renewable origin claims without matching cancellation evidence and correct timelines.
- Missing linkage between metering data and issued certificates (data integrity gaps).
- Contract clauses that do not define certificate quality, vintage, and remedies clearly.
- Late remediation after an audit finding, increasing correction complexity.
- Incomplete archiving of registry logs, certificates, and external disclosures.
- Using inconsistent terminology across contracts, disclosures, and internal records.
FAQ
What is a Guarantee of Origin used for?
GOs are used to evidence the origin of energy from renewable sources and support disclosure and contractual claims. A defensible claim usually requires correct issuance and cancellation aligned with the relevant period and product.
Can we correct past claims if documentation is incomplete?
Corrections are often possible, but the approach depends on the facts, the registry evidence available, and contractual obligations. A remediation plan typically focuses on evidence reconstruction, clear disclosure, and consistent communication.
What should be in a contract clause on certificates?
Typical points include certificate type, vintage, transfer and cancellation mechanics, warranties, audit rights, remedies, and a dispute process. Clear definitions reduce operational and legal friction.
How do audits usually check compliance?
Audits often focus on eligibility, metering integrity, traceability in the registry, and whether external claims match the evidence file. A well-structured document pack and chronology reduce misunderstandings.
When does a certificate dispute become a litigation issue?
When negotiation fails and the dispute affects payments, warranties, or regulatory exposure, litigation may be considered. The decision should be based on a quantified claim, evidence strength, and procedural options.
Internal links
Sources
- Government Decision no. 1232/2011 (Guarantees of Origin framework)
- Annex regulation to GD no. 1232/2011 (GO procedure details)
- Law no. 220/2008 (support scheme for renewable electricity)
- Directive (EU) 2018/2001 (Renewable Energy Directive, RED II)
- Directive (EU) 2023/2413 (amending the Renewable Energy Directive)
- ANRE (archive): Guarantees of Origin information