Introduction of Guarantees of Origin for Renewables


On January 25, 2022, the State Agency of Energy Efficiency (the “Energy Efficiency Agency”) presented the roadmap towards the implementation of guarantees of origin for energy produced from renewables (the “GO”) in Ukraine. The Ukrainian GO system should comply with the 2018/2001/EU Directive (RED II); Ukrainian GOs should be compatible with the EU rules.

The roadmap discloses some basic terms of Ukrainian GOs

Issuing authority: has not been yet determined; however, it would be independent of the energy production, trading, and supply activity.

Energy sources: electricity, biomethane, green hydrogen, that complies with the 2018/2001/EU Directive (RED II). Ukraine overjumps RED I and is heading to move with RED II from the start.

Form of GOs: electronic form; the software used for the GO system shall comply with the CEN - EN 16325 Standard.

Transferability: GOs would be issued, transferred, and cancelled electronically, and should be compatible with the EU rules.

Validity period: 12 months.

The roadmap sets the deadline for the launch of the fully operative GO system in 2024.

The roadmap contemplates a series of actions towards reshaping the National primary and secondary legislation to enable the functioning of the EU compatible GO system.

On a separate note, the Energy Efficiency Agency considers Ukraine joining the Association of Issuing Bodies.


The implementation of the GO system requires significant work towards the development of primary and secondary legislation, especially to reach alignment with RED II.

Meanwhile, in expectation of CBAM, companies in Ukraine are pushed to look for green alternatives and guarantees of origin are the primary tool for achieving the CO2 reduction targets.

Since the Ukrainian authorities are implementing the National GO system too slowly we expect that I-REC might establish a presence in Ukraine rather sooner than later and start with a voluntary I-REC system.

We will monitor the implementation of the GO system in Ukraine and report on the new developments.

Publication prepared by Dr. Oleksiy Feliv, Managing Partner, and Serhii Datsiv, Senior Associate at Real Estate and Construction Practice