Australia's New Renewable Energy Certificate Regime — What Your Organisation Needs To Know (Part 1)

Australia's renewable energy certification system is undergoing fundamental change. The Large-scale Renewable Energy Target (LRET) continues to operate until 31 December 2030 — meaning large-scale generation certificates (LGCs) can still be created and liable entities remain subject to surrender obligations until that date. After 2030, no further LGCs can be created and no further LRET liability arises in respect of electricity generated after that date. Alongside the LRET, the federal government has introduced the Guarantee of Origin (GO) scheme, with the Renewable Electricity Guarantee of Origin (REGO) certificate at its centre. Until 31 December 2030, both schemes operate in parallel.

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

Corporate buyers use LGCs to back their renewable energy claims, typically through Power Purchase Agreements (PPAs) that bundle 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.

The LRET will close on 31 December 2030. Projects commissioned before that date will continue to carry LGC-related rights and obligations during the remaining life of the scheme, and those 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 creates Product Guarantee of Origin (PGO) certificates. While REGO certificates record the renewable electricity attributes of generation, PGO certificates record where a product was made and the emissions associated with its production, transport and storage. For producers and exporters of products such as hydrogen and green metals, PGO certificates are the primary tool for demonstrating the emissions credentials of their products to export markets.

The GO scheme is also 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, REGO and PGO certificates 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. PGO certificates go further, capturing the full emissions profile of the product itself.

The transition period

The LRET and REGO schemes now operate in parallel. The former will continue to operate until 31 December 2030, with LGCs continuing to be created and liable entities remaining subject to surrender obligations until that date. Many existing projects, PPAs and financing arrangements were structured around the LGC framework. As both regimes are simultaneously in operation, 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.

While it might be assumed that both an LGC and a REGO could be created in respect of the same megawatt hour of electricity during this transition period, this outcome is expressly precluded by legislation. The Renewable Energy (Electricity) Act 2000 and the Future Made in Australia (Guarantee of Origin) Act 2024 ensure that only one certificate — either an LGC or a REGO — can be created for a given megawatt hour.

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.

This publication does not deal with every important topic or change in law and is not intended to be relied upon as a substitute for legal or other advice that may be relevant to the reader's specific circumstances. If you have found this publication of interest and would like to know more or wish to obtain legal advice relevant to your circumstances please contact one of the named individuals listed.