The long-awaited launch of the register of guarantees of the origin of electricity from RES

The great news for electricity market participants is the approval of the application form and instructions for filling them out, which makes it possible to create an account in the register of guarantees of origin of electricity generated from renewable energy sources (the “Register”).

The Regulator adopted the relevant decision on August 14, 2024 (NEURC Resolution №. 1475) and it has already entered into force.

Importantly, for business entities that sell electricity at a “green” tariff or provide services to a guaranteed buyer using the market premium mechanism, the deadline for acquiring the status of a Registry user is set for October 1, 2024. The guaranteed buyer, the transmission system operator and universal service providers must acquire the status of the Registry user by September 1, 2024. 

Thus, business entities that sell electricity at the “green” tariff or provide services to the Guaranteed Buyer using the market premium mechanism, the guaranteed buyer, the transmission system operator and universal service providers are required to obtain the status of the Register user within the established timeframe. All other persons wishing to obtain the status of the Registry user may apply to the NEURC with an application for creating an account in the Registry.

In accordance with the Instruction, applications for the creation, termination and restoration of an account in the Register shall be submitted exclusively in electronic form (in the form of an Excel file in accordance with the form developed by the NEURC) to the email address box@nerc.gov.ua with the qualified electronic signature of the director (owner) (or other authorized person) of the licensee and/or the qualified electronic seal of the licensee in compliance with the requirements of the Laws of Ukraine “On Electronic Documents and Electronic Document Management” and “On Electronic Trust Services”.

The date of submission of the application is the date of its receipt by the NEURC. Within 10 business days from the date of receipt of the application, the regulator is obliged to send the applicant a confirmation of its receipt, indicating the date of receipt. If the applicant does not receive such confirmation, it is considered that the application has not been received by the NEURC.

In addition, the Instruction establishes requirements for the file name of the application for creation, termination and restoration of an account in the Register. The file name is formed as follows: ХХХХХХХХ_DD_MM_YY, where “ХХХХХХХ” is the legal entity’s EDRPOU code or company’s LEI code (for non-residents of Ukraine) or “ХХХХХХХХХ” is the registration number of the individual’s taxpayer account card; “DD” is the calendar day on which the application is submitted; “MM” is the month in which the application is submitted; “YY” is the last two digits of the year in which the application is submitted.

Another good news is that the implementation of the Registry using the specific G-REX software has been successfully completed and access to it has already been provided on the regulator’s website. That is, after the NEURC makes decisions on creating accounts for each applicant, a user account will be created in the Registry.

Accordingly, the electronic Registry will start functioning in full and will allow participants to trade in guarantees of origin for electricity generated from renewable energy sources.

Thus, with this document, the regulator has actually launched the electronic Register in Ukraine and ensured the possibility of registering market participants in the Register. It is worth reminding that recognition in Europe and international trade of guarantees of origin issued in Ukraine will be possible only after the NEURC becomes a member of the Association of Issuing Bodies (AIB). On May 30, 2024, by the decision of the AIB General Meeting, Ukraine, represented by the NEURC, acquired the official status of a member of the Association. The NEURC expects to become a full member of the AIB in 2025.

If you need legal advice, please fill out the form below to request it.

Oleksandr Melnyk

Oleksandr Melnyk

Partner, Head of Corporate Law and M&A practice, Attorney at law

Khrystyna Zimenko

Khrystyna Zimenko

Associate

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