Australia's new renewable energy certificate regime — what your organisation needs to know (part 1)

Australia's renewable energy certification system has changed fundamentally. The Large-scale Renewable Energy Target closed at the end of 2025, bringing with it the end of Large-scale Generation Certificates (LGCs) as the primary tool for certifying renewable electricity. In its place, the federal government has introduced the Guarantee of Origin (GO) scheme, with the Renewable Electricity Guarantee of Origin (REGO) certificate at its centre.

If your organisation buys, sells or finances renewable electricity, or makes public claims about using it, this change affects you.

What was the old system?

Under the former Renewable Energy Target, accredited renewable power stations generated LGCs – one certificate per megawatt hour of eligible electricity. Electricity retailers were legally required to surrender LGCs each year to meet their obligations under the scheme. This compliance demand gave LGCs their commercial value.

Corporate buyers used LGCs to back their renewable energy claims, typically through Power Purchase Agreements (PPAs) that bundled electricity supply with certificate transfer. The system was straightforward, but it was designed primarily as a domestic compliance mechanism. It was not built for the global decarbonisation reporting environment that businesses now operate in.

Legacy projects commissioned before the scheme's closure continue to carry LGC-related rights and obligations. Those transitional arrangements remain legally relevant and should not be overlooked.

What is the Guarantee of Origin scheme?

The GO scheme is established by a suite of federal legislation:

• the Future Made in Australia (Guarantee of Origin) Act 2024 is the foundation statute. It creates the GO scheme, authorises the Clean Energy Regulator (CER) to administer it, and provides the basis for detailed operational rules
• the Future Made in Australia (Guarantee of Origin Charges) Act 2024 sets up the cost recovery framework, covering fees for registration, certificate issuance and administration
• the Future Made in Australia (Consequential Amendments and Transitional Provisions) Act 2024 amends existing laws, including the Renewable Energy (Electricity) Act 2000 and the National Greenhouse and Energy Reporting Act 2007 to integrate the GO scheme and manage the transition from the old framework.

The detailed rules in subordinate instruments include:

• the GO Rules 2025, which govern registration, certificate issuance, transfer, retirement and enforcement
• the GO Measurement Standard 2025, which sets technical metering and verification requirements that generators must meet before certificates can be issued
• the GO Methodology Determination 2025, which specifies how attributes are calculated, initially focused on hydrogen, but expanding to cover additional product pathways including aluminium
• the GO Charges Regulations 2025, which specify the fees participants pay for scheme activities.

Further instruments are in development, covering energy storage, aggregated systems and First Nations energy attributes.

Why does it matter?

A REGO certificate is more than a compliance tick. It is a digital, traceable record of renewable electricity generation, recording not just the volume but also the source and timing of generation. This level of granularity is what corporate buyers, export partners and sustainability auditors increasingly require.

The GO scheme is designed to align with international certification standards, including frameworks used in Europe and emerging hydrogen export markets. For Australian exporters of green hydrogen, green metals and other energy-intensive products, REGOs will become a core part of demonstrating the renewable credentials of their supply chains.

This is the key structural difference from the LGC regime. LGCs confirm that renewable electricity has been generated, whereas REGOs confirm what was generated, when, and from which source – information that product-level emissions accounting demands.

The transition period

The shift from LGCs to REGOs does not happen overnight. Many existing projects, PPAs and financing arrangements were structured around the LGC framework. During the transition, both regimes remain legally relevant. Legacy LGC entitlements may coexist with REGO eligibility for some projects, and counterparties may have contractual, financial and reporting frameworks built around the old certificate language.

Careful management of this dual regime environment is essential. Getting it wrong can affect revenue, compliance positions and the validity of renewable energy claims.

In the second part of this series, we explore how the transition between LGCs to the new REGO system affects Power Purchase Agreements, and what organisations need to consider from a legal and commercial point of view.

If you have any questions about Australia's new renewable energy certification system, please contact us here.

Disclaimer
The information in this article is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, we do not guarantee that the information in this article is accurate at the date it is received or that it will continue to be accurate in the future. 

Published by:

Jeanne Vallade

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