Assessing Iceland's Guarantees of Origin: A Report on Potential Double Counting

20 November 2023

The Association of Issuing Bodies suspended exports of Guarantees of Origin (GOs) issued out of the Icelandic registry in April 2023. The suspension was lifted in June of the same year on the condition that a report, assessing the potential issue of double claiming of Guarantees of Origin, would be produced later that year. 

The report titled 'Assessment of Potential Double Counting of Guarantees of Origin in Iceland' can be accessed here.

Concerns and Investigations

The concerns regarding double claiming are largely due to power intensive users claiming to use renewable energy for their production while Icelandic producers export the majority of the Guarantees of Origin they produce. The Icelandic Energy Regulatory Authority (ROE) has investigated this and found that none of the power intensive users have Guarantees of Origin to fully back these claims, as of 2022; yet many of them make claims, in their marketing material, websites and more, that they use renewable energy. However, this does not constitute a breach of AIB’s framework nor EU rules as those only deal with disclosure of the origin of electricity by the electricity supplier to the consumer, but not statements made by the consumer. Although Regulation No. 757/2012 does place an obligation on the consumer to base all statements, regarding the origin of electricity consumption, on disclosed origin supplied by their energy suppliers. The Icelandic Energy Regulatory Authority, however, generally does not have supervisory authority over electricity consumers, and neither Regulation No. 757/2012 nor the Electricity Act No. 65/2003 provide the Regulatory Authority with the legal basis for supervision or enforcement actions towards electricity consumers regarding this information disclosure obligation. The power intensive users are therefore in breach of an Icelandic regulation but not AIB’s framework nor EU rules. 

Conclusion and Compliance

Disclosing and double counting are clearly defined in European Energy Certificate System (EECS) rules and there is no evidence to indicate that double counting is taking place in Iceland. Further, disclosure of origin in Iceland is in line with EECS rules. Double claiming is neither defined in the rules nor specifically prohibited so double claiming that is taking place in Iceland cannot be a breach of these rules. 

The Energy Regulatory Authority concludes that Iceland fulfils all the requirements of the Guarantees of Origin system and has adequately implemented the European Unions legislation on Guarantees of Origin and as such fulfils its obligations under the EEA agreement. Supervision and enforcement of laws regarding Guarantees of Origins in Iceland is in line with practices in of other member states. 

Assessment of Potential Double Counting of Guarantees of Origin in Iceland