Australia’s Guarantee of Origin Scheme: Verification, Compliance, and Market Access

Australia’s Guarantee of Origin (GO) Scheme commenced on 3 November 2025, creating a national framework for verifying renewable electricity and low-emissions products. Administered by the Clean Energy Regulator, the scheme responds to a practical question many companies now face:

How can we substantiate environmental claims with credible, independently verified data?

As regulatory expectations and global trade requirements tighten, the GO scheme offers a government-backed, standardised way to prove low-emissions performance.

Why the GO Scheme Matters: Regulatory and Market Context

The GO scheme addresses a specific challenge for companies operating in regulated and export-oriented markets. Environmental claims are no longer optional marketing statements; instead, they are subject to growing legal and commercial scrutiny.

For example:

• The European Union’s Corporate Sustainability Reporting Directive (CSRD) requires audited environmental data.

• Trading partners including Japan and South Korea increasingly demand verified low-emissions credentials for imports.

Without standardised verification mechanisms, companies risk:

• Regulatory penalties for misleading claims

• Barriers to export markets

• Reputational damage with customers, investors, and regulators

The GO scheme therefore provides a structured, government-backed verification pathway aligned with emerging international standards.

How the GO Scheme Works: Two Certificate Types

The GO scheme operates through two distinct certificate types designed for different, but complementary, applications: REGO and PGO.

REGO Certificates: Renewable Electricity Guarantee of Origin

REGO certificates track renewable electricity generation and consumption. They document:

• Source of the electricity (e.g. solar, wind, hydro)

• Timing and location of generation

• Key characteristics of the renewable generation

Key features include:

• Transferability – REGO certificates can be traded between registered participants.

• Retirement for claims – Certificates are retired when used to support environmental or renewable energy claims.

• Transition from LGCs – Under current law, REGOs will replace Large-scale Generation Certificates (LGCs) when Australia’s Renewable Energy Target expires in 2030.

As a result, REGOs are becoming increasingly central to corporate renewable energy strategies and long-term contracting.

PGO Certificates: Product Guarantee of Origin

In contrast, PGO certificates apply to products, not just electricity. They provide comprehensive lifecycle tracking and document:

• Production methods and facility details

• Emissions sources and emissions intensity

• Emissions from transport, storage, and final use, where in scope

Key characteristics:

• Not tradeable – PGO certificates are not traded. Instead, they remain permanently associated with specific product batches.

• Chain-of-custody clarity – This design prevents double counting and maintains a clear chain-of-custody.

Initially, PGO certification covers hydrogen produced from electrolysis. However, the scheme will expand to additional products, including:

• Ammonia

• Biomethane

• Low-carbon liquid fuels

• Green metals such as steel and aluminium

This staged expansion provides predictability for industry planning, allowing companies to prepare systems and processes ahead of time.

Registration: How Companies Enter the GO Scheme

Participation in the GO scheme requires registration with the Clean Energy Regulator. The process involves three main steps.

Step One: Fit and Proper Person Assessment

First, companies must satisfy a “fit and proper person” test. This assessment:

• Screens for convictions related to fraud, dishonesty, or environmental law breaches.

• Considers insolvency status and related risk factors.

The test ensures participants meet baseline compliance and integrity standards. Registered status can be:

• Suspended temporarily, or

• Cancelled permanently for cause.

In addition, companies must notify the Regulator within 28 days of relevant changes, such as new convictions or changes in control.

Step Two: Profile Registration

Once accepted, companies then establish profiles that reflect their role in the supply chain:

• Production profiles – For manufacturers and generators; document facility locations, production processes, and emissions sources.

• Delivery profiles – For transporters and storage operators; record emissions associated with transport and storage after production.

• Consumption profiles – For end-users; document where and how certified products are consumed.

Although information requirements vary by profile type, they consistently include:

• Facility and operational details.

• Emissions measurement and calculation methodologies.

• Relevant operating procedures.

Step Three: Certificate Creation and Registration

Finally, companies create certificates when they:

• Produce eligible products (for PGO), or

• Generate eligible renewable electricity (for REGO).

For PGO certificates in particular:

• Certificates are created for each batch, recording production pathway, facility, emissions intensity, and emissions by source.

• Companies then request the Regulator to register the certificates on the GO Register.

• The Regulator checks completeness and accuracy before recording the certificates.

Importantly, PGO certificates must be registered within one year of the batch leaving production. This requirement creates operational discipline while still allowing practical time for supply chain coordination.

The GO Register: Public Transparency and Market Confidence

All participants, profiles, and certificates are recorded on the GO Register, a public database administered by the Clean Energy Regulator.

The Register provides:

• Participant details

• Production, delivery, and consumption profile information

• Certificate holdings and transactions

• Historical records of activity

Because this information is public (subject to limited exceptions), it:

• Enables buyers to verify that suppliers’ certificates are genuine and current

• Allows stakeholders to assess scheme participation and track records

• Builds market confidence in certified products and claims

Companies can request that commercially sensitive information be withheld. However, the default position favours disclosure to maintain transparency and scheme integrity.

When Participation Becomes Strategically Necessary

While participation in the GO scheme is technically voluntary, several business situations make it strategically important, and in practice almost compulsory.

Hydrogen Producers

Hydrogen producers require PGO certification to access the Hydrogen Production Tax Incentive, which provides $2 per kilogram of eligible renewable hydrogen from 2027 to 2040. This incentive can effectively subsidise a significant portion of production costs for certified producers.

Moreover, PGO certification is increasingly required by export markets, especially in Asia. Without certification, producers risk losing access to key buyers.

Renewable Energy Generators

Renewable energy generators can create REGO certificates, which:

• Enable participation in renewable energy markets

• Support corporate buyer claims around renewable electricity use

As corporate renewable energy targets expand and REGOs become the standard tracking mechanism post-2030, participation will shift from optional to routine.

Energy-Intensive Manufacturers

Energy-intensive manufacturers that use renewable electricity can leverage REGO and PGO certification to:

• Demonstrate low-emissions product credentials

• Support export market access

• Differentiate in markets where green attributes influence purchasing decisions

Supply Chain Participants

Transporters, storage operators, and distributors can contribute post-production data to PGO certificates. In doing so, they:

• Support full lifecycle transparency

• Demonstrate their own compliance practices and emissions performance

Companies Making Environmental Claims

Finally, companies making environmental claims for:

• ESG reporting.

• Sustainability marketing.

• Regulatory compliance.

Can base those claims on certified GO records rather than unverified internal estimates. This directly addresses regulatory expectations for substantiated environmental claims.

Ongoing Compliance: What Participants Must Maintain

Registration is not a one-off event. Once in the scheme, companies have ongoing obligations.

Annual Reconciliation

Each year, the Regulator issues statements to certificate holders summarising:

• Certificates created and registered

• Transfers and retirements

Recipients must respond with declarations confirming accuracy. This reconciliation ensures that operational records and register entries align.

Compliance Audits

The Regulator also conducts compliance audits. During an audit, companies may be required to:

• Provide data, records, and supporting documentation

• Allow facility access where relevant

• Explain methodologies and processes

Audits can be scheduled or triggered by specific concerns.

Record Keeping

Participants must maintain prescribed records, including:

• Production process documentation

• Emissions calculations and methodologies

• Certificate creation data and transaction histories

These records must be available for inspection and form the backbone of credible verification.

Notifications

Companies must notify the Regulator within 28 days of specified events, such as:

• Relevant convictions

• Changes in operational control

• Other material changes affecting fit and proper person status

Timely notification is part of maintaining good standing in the scheme.

Integration with Government Programmes

The GO scheme is tightly integrated with several broader government initiatives.

• Hydrogen Production Tax Incentive – Provides $2 per kilogram of eligible renewable hydrogen, conditional on PGO certification. This can translate into substantial cost reduction for certified producers.

• Future Made in Australia Investment – A $22.7 billion commitment supporting emerging industries such as green hydrogen, critical minerals, and advanced manufacturing. GO certification often underpins eligibility and strengthens proposals.

• Renewable Energy Target (RET) Transition – As the current RET expires in 2030, REGOs become the primary mechanism for tracking and certifying renewable electricity. Companies will progressively transition from REC-based systems to REGO-based systems during this period.

Export Market Context: Access and Differentiation

Australia exports about 97% of its hydrogen production. Trading partners including Japan, South Korea, and European countries increasingly require verified low-emissions credentials.

GO certification:

• Provides the verification mechanism buyers expect

• Supports due diligence and border measures relating to embedded emissions

• Helps secure market access and long-term offtake agreements

Companies without GO certification may face barriers or exclusion. In contrast, certified companies gain access, credibility, and competitive positioning.

This dynamic extends beyond hydrogen. Export markets for manufactured goods are progressively evaluating:

• Carbon footprint.

• Renewable energy content.

• Provenance and chain-of-custody.

GO certification enables substantiated claims in these areas, supporting both market access and, in some cases, price premiums.

Practical Considerations for Implementation

Implementing GO scheme participation requires structured preparation across several areas.

1. Eligibility Assessment
   • Determine whether operations qualify (e.g. renewable electricity generation, hydrogen or other eligible products).
   • Assess whether regulatory, investor, or customer expectations make participation advantageous.
2. Systems Preparation
   • Develop or upgrade emissions monitoring and data management systems.
   • Ensure systems can generate accurate, auditable data for certificates and reporting.
3. Process Documentation
   • Document production processes, emissions sources, measurement methods, and calculation approaches.
   • Use this documentation as the foundation for certificate creation and audit readiness.
4. Supply Chain Coordination
   • Coordinate with transporters, storage operators, and end-users to capture chain-of-custody data.
   • Clarify roles and responsibilities for data provision and verification.
5. Compliance Culture and Training

   • Determine whether operations qualify (e.g. renewable electricity generation, hydrogen or other eligible products).

   • Assess whether regulatory, investor, or customer expectations make participation advantageous.

Forward Planning: Product Expansion and Regulatory Evolution

The GO scheme begins with hydrogen and renewable electricity, but its scope will expand. Planned future coverage includes:

• Ammonia

• Biomethane

• Low-carbon liquid fuels

• Green metals

Therefore, companies should:

• Monitor methodology determinations and expansion announcements

• Plan system upgrades that can accommodate additional products over time

Regulation will also evolve as the scheme matures. Methodologies, measurement standards, and compliance processes may be refined. Consequently, companies should:

• Subscribe to Clean Energy Regulator updates

• Review internal processes periodically to maintain alignment

International alignment will remain important. Australian methodologies are expected to converge with EU, Japanese, and other international standards, particularly where export markets are involved.

Getting Started

Companies considering participation should:

• Evaluate internal capability for emissions measurement, data management, and verification.

• Consider engaging specialist advisers where operations or supply chains are complex.

The Guarantee of Origin scheme is now operational. Companies with eligible activities should assess whether participation supports:

• Business strategy.

• Regulatory obligations.

• Market positioning and access.

For many, this assessment will identify clear value in participation. For others, active monitoring of the scheme’s evolution will be a prudent interim step.

How Evolveable Can Help You

The team at Evolveable was originally involved in the Australian Guarantee of Origin working group for hydrogen certification, contributing to early standards and methodologies that underpin the scheme. Since then, Evolveable has built over three years of experience working with OEMs globally, particularly on digital product passport requirements in the battery sector.

By combining expertise in:

• Emissions tracking and lifecycle analysis

• Regulatory alignment and scheme design

• Digital passport and data management solutions

Evolveable can support companies through the full GO journey:

• Assessing eligibility and designing participation strategies

• Registering for the GO scheme and setting up profiles

• Implementing robust compliance and record-keeping systems

• Preparing for audits and future regulatory developments

• Positioning for new market opportunities as GO expands

Based in Perth and operating internationally, Evolveable works with companies to translate environmental regulations into practical operational strategies.

For more information:

• Web: www.evolveable.com

• Email: info@evolveable.com

• LinkedIn: EvolveableConsulting