By Sarah Pick, Consultant

What is ‘the GO Scheme’?

The Future Made in Australia (Guarantee of Origin) Act 2024 (Cth) (GO Act) establishes the ‘GO Scheme’ which:

• is a scheme to certify renewable electricity and other products (including hydrogen);
• provides for the creation of Renewable Electricity Guarantee of Origin certificates (REGO Certificates); and
• provides for the creation of Product Guarantee of Origin certificates (PGO Certificates).

The GO Scheme will initially apply to renewable electricity and hydrogen and then will be expanded in the future to apply to carbon liquid fuels and green metals.[1]

The purpose of the GO Scheme is to show and record where a product has come from, how the product was made and the product’s emissions throughout its lifecycle.

In particular, REGOs are designed to replace Large Generation Certificates (LGCs) that are created in accordance with the Renewable Energy (Electricity) Act 2000 (Cth) (REE Act). The LGC scheme is set to end in 2030, and REGO Certifications will replace LGCs. However, there will be a period of time in which either LGCs or REGO Certificates can be created in respect of eligible electricity (this is noted in more detail below).

The Department of Climate Change, Energy, the Environment and Water provides that the GO Scheme will:

• empower Australian producers to make confident, objective and credible claims about the renewable electricity they generate or use and the products they make; and
• support consumers of renewables and low-emission products with a publicly accessible record of that use.[2]

The Clean Energy Regulator will administer the GO Scheme, and it will be responsible for participant enrolment, certification and management of REGO Certificates and PGO Certificates and compliance activities.[3]

The GO Act (and consequently the GO Scheme) will commence on a date to be fixed by proclamation (which has not yet occurred). If a date is not fixed by proclamation by 10 December 2025, the GO Act will commence on 10 December 2025.[4]

What are REGO Certificates?

REGO Certificates are voluntary certificates created to provide certainty for renewable electricity investment and procurement. The mechanism to create REGO Certificates:

• retains the basic design of the LGC regime and introduces features to make it more fit-for-purpose now and into the future; and
• proposes to expand the eligibility for certifying renewable electricity to energy storage systems and below-baseline generation.[5]

A person registered for the purpose of the GO Act (a Registered Person) may apply to the Regulator to register a renewable electricity facility that is:

• a facility that is an accredited power station and that facility generates electricity from at least one eligible renewable energy source;[6]
• an electricity generation system that is not an accredited power station;
• an energy storage system; or
• an aggregated system if each electricity generation system included in the facility generates electricity from at least one eligible renewable energy source.

The GO Act defines energy sources that are eligible renewable energy sources (e.g. hydro, wind, solar, wave, tide, wood waste, food waste) as well as energy sources that are not eligible renewable energy sources (e.g. fossil fuels, biomass from native forests).[7]

Following the receipt of a registration application for any of the facilities described above, the Regulator must decide whether to register the facility or refuse to register the facility.[8]

The eligible Registered Person for a registered renewable electricity facility may:

• create REGO Certificates in respect of the eligible amount of electricity for the facility and a time period (noting that one REGO Certificate may be created for each whole megawatt hour included in the eligible amount);[9]
• create REGO Certificates in respect of the residual amount for a facility and a calendar month in a calendar year in certain circumstances (noting that one REGO Certificate may be created for each whole megawatt hour included in the residual amount) ;[10]
• apply to the Regulator to register REGO Certificates created[11] in respect of:
  • the eligible amount of electricity for the facility and a time period; or
  • the residual amount for the facility and a calendar month.

The GO Act provides that there is no double counting, and a REGO Certificate cannot be created in respect of electricity if another certificate (i.e. a LGC) has been created under the REE Act in respect of that electricity.[12] The REE Act will also be amended to include a similar provision noting that a LGC cannot be created in respect of electricity to which a REGO Certificate has already been created.[13]

If the Regulator registers the REGO Certificates, the Regulator must record in the register that the eligible Registered Person is the registered owner of the REGO Certificates.[14]

The registered owner of a REGO Certificate may request that the Regulator transfer the REGO Certificate to another Registered Person.[15]

The name of each Registered Person, each registered renewable electricity facility and each registered REGO Certificate will be recorded by the Regulator in the GO Register.[16]

What are PGO Certificates?

PGO Certificates are certificates created by Registered Persons to certify projects (such as hydrogen and ammonia) and record information about the production, delivery and consumption of products and the associated emissions.[17]

A Registered Person may apply to the Regulator to register:

• a ‘production profile’ for a product that sets out specific information relating to the process and location of the production of that product;[18]
• a ‘delivery profile’ for a product that sets out specific information relating to the method and location of delivery of that product;[19] and/or
• a ‘consumption profile’ for a product that sets out specific information relating to the receipt and consumption of the product.[20]

Following the receipt of an application to register a production profile, a delivery profile or a consumption profile, the Regulator must decide whether to register the profile or refuse to register the profile.[21]

The holder of a registered production profile for a product may:

• create PGO Certificates in respect of a batch of the product that is produced at the facility specified in the production profile (noting that only one PGO Certificate may be created for each whole functional unit of the product in the batch);[22] and
• authorise one (and only one) holder of a delivery profile for the product to add post-production information to the PGO Certificate (and may also withdraw such authorisation);[23] and/or
• authorise one (and only one) holder of a consumption profile for the product to add consumption information to the PGO Certificate (and may also withdraw such authorisation).[24]

The holder of a production profile for a product who creates PGO Certificates in respect of a batch of the product may request that the Regulator register the certificates.

The name of each Registered Person, each registered profile and each registered PGO Certificate will be recorded by the Regulator in the GO Register.[25]

Other relevant legislation

The Future Made in Australia (Guarantee of Origin Charges) Act 2024 (Cth) that imposes charges on profiles and facilities registered under the GO Act was assented to on 10 December 2024 and will not commence before the GO Act commences.

The Future Made in Australia (Guarantee of Origin Consequential Amendments and Transitional Provisions) Act 2024 (Cth) deals with consequential and transitional amendments associated with implementing the GO Act was assented to on 10 December 2024 and will not commence before the GO Act commences. This Act amends the REE Act, the Clean Energy Regulator Act 2011 (Cth) and the National Greenhouse and Energy Reporting Act 2007 (Cth).

Next steps – the Rules

The Australian Government is in the process of consulting with stakeholders on draft subordinate legislation that will set out the details of the GO scheme.

Exposure Draft (Tranche 1) (Tranche 1 Exposure Draft) of the Future Made in Australia (Guarantee of Origin) Rules 2025 (GO Rules) was released for consultation earlier this year (consultation closed on 27 March 2025).

The Tranche 1 Exposure Draft sets out all required rules under Parts 1-3 of the GO Act which are set out in the following parts of the GO Rules:

• Part 1: Preliminary matters of general application;
• Part 2: Matters relating to the registration of persons;
• Part 3: Certification of products (registration of profiles, certification of products and certification of PGO Certificates); and
• Part 4: Certification of renewable electricity (eligible renewable energy sources and registration of renewable electricity facilities that are generation systems).

It is expected that over the next few months exposure drafts will be released for consultation for other Parts of the Rules including the Methodology Determination for Hydrogen production from electrolysis (which sets out how emissions will be calculated for this pathway), the Renewable Electricity Guarantee of Origin (REGO) Measurement Standard, the Cost Recovery Impact Statement and the Cost Recovery Regulations.[26]

Want to know more or look to ‘future proof’ agreements?

Contact Sarah Pick to learn more about the GO Scheme, how it may impact your organisation and what you can do to ‘future proof’ your agreements in advance of the GO Schemes commencement later this year and the LGC scheme’s completion in 2030.

Stay tuned for further updates regarding the GO Rules and commencement of the GO Scheme.

[1] https://www.dcceew.gov.au/energy/renewable/guarantee-of-origin-scheme

[2] https://www.dcceew.gov.au/energy/renewable/guarantee-of-origin-scheme

[3] https://cer.gov.au/schemes/guarantee-origin#:~:text=The%20Renewable%20Electricity%20Guarantee%20of%20Origin%20(REGO)%20certificate%20mechanism%20builds,and%20support%20Australia’s%20energy%20transformation.

[4] Section 2 of the GO Act

[5] https://cer.gov.au/schemes/guarantee-origin-scheme/renewable-electricity-guarantee-origin

[6] Section 74 of the GO Act

[7] Section 69 of the GO Act

[8] Sections 78(1), 79(1), 80(1) and 81(1) of the GO Act

[9] Section 91 of the GO Act

[10] Section 92 of the GO Act

[11] Section 104(1) of the GO Act

[12] Section 99 of the GO AcT

[13] Sections 18(4) and 23A(1) of the REE Act will be amended in accordance with the Future Made in Australia (Guarantee of Origin Consequential Amendments and Transitional Provisions) Act 2024 (Cth)

[14] Section 104(8) of the GO Act

[15] Section 106 of the GO Act

[16] Section 112 of the GO Act

[17] Section 27 of the GO Act

[18] Section 30 of the GO Act

[19] Section 34 of the GO Act

[20] Section 38 of the GO Act

[21] Sections 33(1), 37(1) and 41(1) of the GO Act

[22] Section 49(1) of the GO Act

[23] Section 55 of the GO Act

[24] Section 59 of the GO Act

[25] Section 112 of the GO Act

[26] See page 4 of the Consultation Paper: Future Made in Australia (Guarantee of Origin) – Exposure draft (tranche 1) – Future Made in Australia (Guarantee of Origin) Rules 2025