Supervisory framework for Guarantees of Origin for renewable gas (“gGOs”)

As indicated in our briefing, Biomethane: Guide to project development in Ireland, biomethane producers injecting gas to the network can be issued with a gGO certificate for each MWh of renewable gas they produce.

gGOs are of value to gas suppliers because their purpose under law is to demonstrate to final customers the share or quantity of energy from renewable sources in a supplier’s energy mix, and in the energy supplied to consumers under contracts marketed with reference to consumption of energy from renewable sources. In Ireland, S.I. 350/2022 obliges the CRU to ensure that a supplier uses GOs for these purposes. GNI is appointed to issue GOs in response to a request from a producer of gas from renewable sources delivered to the transportation system.

The CRU has now issued a decision setting out the supervisory framework for gGOs. Key features are summarised below.

• Producers, traders and suppliers may hold accounts and trade, import and export gGOs in an electronic registry to be established and operated by GNI. The CRU has decided that only licensed suppliers will be able to cancel gGOs. Producers may hope that this will not be an enduring design feature, given that gGOs have value not just for suppliers, but also for non-supplier offtakers who wish to mitigate exposure to carbon tax or carbon prices (for those in scope of the EU emissions trading system) or more generally pursue decarbonisation goals.
  
  That such offtakers may use GOs is supported by Article 15(8) of the Renewable Energy Directive (“RED”), which requires Member States to ensure that any GOs associated with renewable energy purchase agreements can be transferred to the buyer of the renewable energy under the agreement. This was required to be transposed by 21 May 2025, and the CRU notes that changes to the supervisory framework may be made following transposition of EU law.

• A valid sustainability certificate reference number issued by an EU Voluntary Scheme will be required to confirm the renewable attributes of the gas produced. Imported gGOs will be required to have a sustainability certificate after 5 August 2026 (the transposition date for the Gas Directive (EU) 2024/1788, which provides that renewable gas shall be certified in accordance with provisions in the RED).

• gGOs are applicable to grid-injected renewable gas only. In the case of biomethane network entry facilities where multiple plants use the same injection point, GNI will request further information and cooperation from market participants to allocate an injection volume to the appropriate production plant.

• GNI will issue gGOs monthly. Initial metered values may be corrected for operational reasons, and GNI will develop rules for a reconciliation and adjustment process to take place in each issuing period.

• The CRU will consult further on a supervisory framework for the fuel mix disclosure (“FMD”) regime for gas suppliers and a potential green source product verification (“GSVP”) process. The CRU indicates that the GSVP process would be separate to the FMD regime and would be intended to ensure that renewable energy claims made by suppliers are verified and backed by gGOs.

• The CRU has decided to implement an annual fee of €2,000 for producers and €3,000 for suppliers and traders.

• Trading of UK GOs is not permitted.

The decision indicates that GNI is to develop software and industry facing documents, following consultation as appropriate. Producers, traders and suppliers wishing to participate will be required to apply for registration and it is expected that GNI will publish requirements for this process no later than September 2026.

GNI’s pilot registry will be maintained for a period in parallel with the new registry, but no new certificates of origin will be issued using the pilot registry after 31 December 2026. The CRU indicates that issue of gGOs in the new registry should start no later than January 2027.

Separately, GNI has, through the pilot registry, issued proofs of origin to track title to renewable gas injected into and withdrawn from the gas network on a mass‑balance basis. At EU level, a Union Database is being developed as a traceability tool to track renewable fuels and their feedstocks from point of origin to final consumption. The CRU indicates that, pending the establishment of the Union Database, it may be prudent for GNI to continue issuing proofs of origin for renewable transport fuel obligation and EU emissions trading system purposes on an interim basis. The RED provides for the linkage of gGOs with the Union database. The CRU indicates it will monitor progress of the Union database and potentially update the supervisory framework.

Reverse grid compression (“RGC”)

The EU’s Fourth Gas Package includes provisions to support reverse flow from the distribution network to the transmission network with the aim of facilitating market integration of renewable gas and low-carbon gas.

In Ireland, an enduring policy for RGC to support connection of biomethane plants to the distribution network is under development.

Pending the enduring policy, the CRU approved GNI’s interim solution for RGC (PDF, 773KB), which has been incorporated into GNI’s connection process: Biomethane Connection Brochure (PDF, 1.1MB).

Applicants must:

• submit a completed grid connection application and pay the application fee of €10,000,
• have been shown a minimum annual constraint volume of gas of 4 GWhs per annum in the network analysis report issued by GNI under the connection application process, and
• complete a biomethane producer connection application form (PDF, 312KB).

GNI will assess whether RGC will be offered based on whether:

• implementing it would avoid more expensive reinforcement on that network,
• the project supports the objectives of the National Biomethane Strategy, and
• sufficient monies remain in the Price Control 5 Flexibility Pot to meet the requirements of the project, with funding being allocated on a first come first served basis.

If RCG is offered, the connecting party would submit a fee of €370,000, to be paid at the same time as the 30% customer contribution for the grid connection. The connecting party would sign the connection agreement within four months of the date of offer and demonstrate that planning permission approval has been received (with no judicial review processes or appeals pending).

For further information on all aspects of market regulation and infrastructure development concerning renewable gas, low-carbon gas and hydrogen, please contact a member of any of our teams in environment and planning, construction and engineering, or energy and infrastructure.