Key Contacts: Niall Donnelly – Partner |
Background
The Commission for Regulation of Utilities (“CRU”) has established a Supervisory Framework for Guarantees of Origin for gas from renewable sources (“gGOs”), as required under Statutory Instrument No. 350 of 2022, which transposed the Renewable Energy Directive (“RED II”) into Irish law. Gas Networks Ireland (“GNI”) has been appointed as the Issuing Body and will operate the gGO certification process through an electronic Registry.
Renewable Gas Guarantees of Origin are electronic certificates that prove renewable gas, such as biomethane or hydrogen, has been produced and injected into Ireland’s gas network. Each certificate represents one Megawatt hour (MWh) of renewable gas. Once issued, these certificates can be traded separately from the physical flow of the gas itself, including independently across the European Union, allowing companies in different jurisdictions to buy and sell the renewable attribute without physically moving the gas.
Key Decisions
Registry Account Holders and Permitted Transactions:
Producers, traders, and suppliers will be allowed to hold accounts in the Registry. All account holders will be permitted to transfer gGOs, with issuance restricted to producers and cancellation rights reserved for suppliers only. Only gas suppliers are licensed by the CRU, and since they are the only legal entities which will be obliged to comply with Fuel Mix Disclosure (FMD) requirements, the CRU has decided that only suppliers will be able to cancel gGOs.
Sustainability Certification Requirements
A valid sustainability certificate reference number issued by an EU Voluntary Scheme is the appropriate mechanism to confirm that renewable gas volumes qualify as gas from a renewable source. Importantly, installations with a total rated thermal input of less than 2MW are deemed to fulfil the sustainability and greenhouse gas emissions saving criteria automatically, so a sustainability certificate is not required for those facilities. gGOs will be mandated to have a sustainability certificate once the Internal Gas Market Directive (EU 2024/1788) has been transposed in Member States, with a transposition deadline of 5 August 2026.
Monthly Issuance of gGOs
GNI will issue gGOs on a monthly basis, in line with the consultation proposal and the broad support received from respondents. This aligns the gas framework with the existing electricity Guarantees of Origin framework.
Fuel Mix Disclosure (FMD) and Green Source Product Verification (GSPV)
There was broad consensus amongst respondents to align the FMD and Green Source Product Verification (GSPV) processes for renewable gas with those for electricity. While complying with EU and national legislation, alignment with the electricity FMD and GSPV frameworks will be a priority to the extent that is possible. The CRU will consult upon the FMD and GSPV processes for gas, including all relevant criteria, requirements, and timelines, in due course.
Registry Fees
The CRU has determined that an annual fee of €2,000 for producers and €3,000 for suppliers and traders is appropriate. These fees are notably lower than the €5,000 flat fee originally proposed in the consultation, reflecting stakeholder feedback and the early-stage development of the Irish biomethane market. The charge will be payable to GNI in advance of the first registration and annually thereafter at a time to be determined by GNI. GNI will be obliged to review the fee structure in alignment with every Price Control, with the option to review more frequently, and will be required to submit its review and associated recommendations to the CRU.
Additional Limitations
No trading with the UK: In accordance with current legal arrangements between the EU and UK, the Supervisory Framework will not permit trading of gGOs with the UK. This position follows from the mutual non-recognition of renewable energy certificates between the EU and UK post-Brexit.
Grid-injected gas only: The Framework will not be extended to include non-grid injected gas at this time.
What Happens Next?
Based on GNI’s plans, the issuance of gGOs in GNI’s Registry should commence no later than January 2027. GNI’s Pilot Registry will, for a period, continue to be maintained in parallel with the new Registry. No new Certificates of Origin should be issued using the Pilot Registry after 31 December 2026, and the Pilot Registry will be wound down and closed when all certificates have been duly processed. Producers, traders, and suppliers wishing to participate in the new gGO regime will be required to apply for registration, and GNI intends to publish its finalised requirements in this regard no later than September 2026.
Conclusion
This system brings two major benefits, it gives consumers confidence that the “green gas” products they choose are backed by genuine renewable energy, and it provides a financial incentive for biomethane producers, helping to grow renewable gas production in Ireland.
Under this Framework, and through the upcoming Fuel Mix Disclosure process, gas suppliers will be required to use gGOs to show customers how much renewable gas is included in their energy mix, meaning that customers can make informed choices and select suppliers based on their commitment to renewable energy.
The Framework also arrives at a critical juncture for Ireland’s domestic biomethane industry. The National Biomethane Strategy, published in May 2024, outlines a target delivery of up to 5.7TWh of indigenously produced biomethane by 2030 and requires that key Government Departments and agencies work to ensure that the necessary supports and infrastructure are in place for the biomethane industry. The gGO regime will be an important market mechanism supporting that ambition.
If you have any questions about how the new Framework may affect your business, whether as a renewable gas producer, trader, or supplier, please do not hesitate to get in touch with our team.
