Implementation of Guarantees of Origin in the Energy Community – Lessons learnt

Three years ago, we had the honor to win the tender organized by the Energy Community Secretariat to establish Guarantee of Origin (GO) registries in 8 energy community countries: Albania, Bosnia and Herzegovina, Georgia, Kosovo*, Moldova, Montenegro, North-Macedonia and Ukraine. Today, almost all of these countries have a functioning guarantee of origin registry in production or are in the process of launching one.  

Why did the energy community countries succeed in implementing GO systems and registries from scratch, and so much faster than their EU counterparts? 

The implementation project 

The implementation project with the Energy Community Secretariat ran from January to July 2022. The project started with a deep dive for the issuing bodies, focusing on what GOs and electricity disclosure are, how they were developed, their purpose and the role of the AIB and the EECS standard. 

The idea of the project was never to re-invent the wheel, but to adopt the existing standards, processes and technical implementations that AIB has carefully created and fine-tuned over the past 20 years. As a concrete example, the AIB V80 certificate standard was selected as the basis for certificates. Additionally, key EECS processes were introduced and recommended as the starting point of any national regulation (such as AH and plant registration, measurement and issuing, transfer, cancellation and disclosure). 

After the first inception of the basics, the focus quickly shifted to the registry. Less than 2 months into the project, we had the first registry “playground” for each issuing body where they could start practicing the GO processes. The dedicated domain was refined throughout the project and tailored for each issuing body based on their needs and local language. By the end of the project, with hands-on experience, each issuing body was able to clearly define what their domain should look like, and which features were essential in their case. 

The iterative process not only allowed the IBs to clearly define their needs but also analyze how their national regulations (often still draft) interact with a cloud-based registry. Running the technical and regulatory tracks in parallel saved both time and money which is a contrast to the more common approach where everything is set in regulation before any technical considerations are made. 

This already sounds like a lot, but the project went even further. Together with the Energy Community Secretariat, we drafted a ready-made contractual framework for the issuing body through which they could enter into a direct agreement with Grexel. In effect, the Secretariat conducted contract negotiations on behalf of the issuing bodies. This agreement includes all standard elements such as SLAs, liabilities, confidentiality, but also more advanced features, such as the compatibility guarantee with the AIB Hub. Thanks to this agreement, the issuing bodies never need to worry about changes in European legislation, standards or AIB processes as all required changes are handled as part of the contract. 

Naturally we carried out multiple training sessions covering all GO aspects during the project, including a training session for future Account Holders of the system. We also prepared a stepwise approach for AIB membership, allowing countries to be AIB Members at their own pace while remaining compatible with both systems. 

Figure 1 Stepwise approach from the energy community regional system towards AIB Hub connection 

Perhaps most importantly, after the project officially ended, the work didn’t stop. All decisions made bilaterally with each issuing body on how their domain should look and function were documented. Furthermore, the Issuing Bodies’ access to their demo systems remained active until a bilateral agreement with Grexel  was in place to start operation of GO registry in production mode.  

Moving to a production registry 

Even though our offer, including contractual terms for future bilateral agreements with the Issuing Bodies went through public procurement of the Energy Community Secretariat, some countries opted to run their own public procurement process for their GO registry. While in other countries, the central tender enabled a bilateral agreement directly. 

Countries moved at their own pace after the implementation project depending on a) their national rules for tendering, and more importantly b) the timeline on when the countries needed a live GO system. First domain in production was Georgia in the end of 2022, followed by Albania and Republika Sprska in Bosnia and Herzegovina in the spring 2023. In 2024, the registries for Kosovo*, Montenegro and Ukraine were implemented.  North-Macedonia and Moldova are expected to launch their GO registries in 2025.

Figure 2 Naida Haussman presenting the status of GO registry implementations in the Energy Community countries at the REC Market Meeting April 2024 

The implementation of these registries has been extremely smooth – thanks to the coordinated start organized by the Energy Community Secretariat and the fact that registries were kept active as agreed at the end of the project. Essentially, the only steps needed were to organize new training sessions, carry out acceptance testing and check if any preferences or final regulation changes needed to be reflected and revised in the previously agreed registry configurations and features. 

What happens next? 

Modern, EU-compatible GO systems are now a reality throughout the Energy Community, which is a major milestone. Technical compatibility, however, is just the first step. The immediate next step is to finalize disclosure regulation in some of the countries where it is missing. 

The ambiguity around mutual recognition between Energy Community and the European Union also needs to be resolved. Energy Community countries are bound by the same directives as the EU countries when it comes to GOs. 

Although the project concentrated on electricity, the GO system in the energy community will naturally expand to gaseous energy carriers and hydrogen through the implementation of the RED II. Fortunately, only small changes will be needed to the existing registries to support this transition. 

Main take aways: 

• Implementation of GOs can be fast, easy and cost effective. 
• Having a test registry helps avoid the pitfalls in regulation and accelerates progress. 
• The joint project enables issuing bodies to learn from one another while making real practical decisions. 
• Leveraging the existing EECS standard proved efficient – re-inventing the wheel was avoided. 

Figure 3 Energy Community and Grexel at the Energy Community Conference