The UK will stop accepting EU GoOs after CP21 (2022-23) reporting period, creating an anticipated demand deficit of 72 TWh in CP22 (2023-24). A 2 GBP premium for CP22 certificates already reflects the anticipated supply shortage, but if CP22 supply remains tight, higher prices can be expected.

EU GoO imports into the UK are still ongoing, but have reduced by approximately 50% from July 2022 to January 2023 (CP21 disclosure) compared to the same period in the previous year.

In the last three months, the prices of REGOs have remained relatively stable, with no significant changes in regulations or weather conditions affecting the supply and demand of REGOs.

Renewables generation in the first 10 months of CP21 increased 15% due to positive weather conditions and increased capacity, with total REGOs issuance expected to rise by 18% in CP21 compared to CP20

The Renewable Energy Guarantees of Origin (REGO) scheme is similar to the EU Guarantees of Origins scheme which informs consumers about the proportion of electricity that suppliers source from renewable generation and is primarily used in Great Britain and Northern Ireland for Fuel Mix Disclosure (FMD). Renewable generators of any size in Great Britain and Northern Ireland can apply for the scheme and are issued one REGO per MWh (Megawatt hour) of electricity generated.

In the last decade, the supply of Renewable Energy Guarantee of Origin certificates (REGOs) has experienced a Compound Annual Growth Rate (CAGR) of 11%, going up from 53 TWh to 116 TWh. The main contributors to this growth have been offshore and onshore wind, which have seen a more than threefold increase in issuance, going from 21 TWh in 2012-13 to 68 TWh in 2021-22. Since the UK does not have any limitation for REGO issuance for supported production, the total growth in REGO issuances correlates with the rapid increase in the renewable capacity. It is anticipated that this trend will continue, and the total REGO issuance is projected to reach 160 TWh in the period of 2025-26, in line with the expected growth in renewable electricity generation in the UK.

UK: REGOS: Total Issuance

Short Term- Weather and Renewables Generation

However, Wind, solar, and hydropower energy – which are the main renewable energy sources for REGOs – are susceptible to fluctuating weather patterns. The Weather statistics were available for all except one month of CP21. The weather statistics show CP21 had a higher average wind speed, sun hours and total rainfall by 3%, 13% and 7% respectively when compared to CP20.

UK: CP21 ROCS - weather stats

According to the BEIS DUKES data on renewables generation, renewable energy generation in the first eleven months of CP21 has risen by 21% YoY, driven by favorable weather and increased capacity. It is predicted that REGO issuance will increase by approximately 18% in CP21 compared to CP20.

UK: CP21 ROCS - renewables generation

Total cancellations in the UK amount to about 170 TWh of EU renewable energy GoOs and REGOs for predominantly FMD purposes, making the UK one of the largest consumers of renewable energy in Europe.

The REGOs were traditionally an oversupplied market with many certificates expiring. For instance, in the disclosure period 2016-17, almost 20% of the total issued REGOs representing about 16 TWh were expired. The proportion has since then decreased to less than 2% of REGOs (about 2 TWh) expiring in 2021-22 (latest available figures) as shown below.

UK: REGOS: Expiry

However, the demand for REGOs which are used exclusively for FMD has increased rapidly in recent years. The total REGOs redeemed in the UK has increased from 22 TWh in 2010-11 to 107 TWh in 2021-22:

UK: REGOS: Total Redeemed

This is mainly because several recent entrants in the UK domestic electricity supply business differentiated themselves from big suppliers by supplying only 100% renewable electricity, and established suppliers also moving to being 100% renewable. In total there were 14 suppliers supplying green energy exclusively in the UK (https://electricityinfo.org/fuel-mix-of-uk-domestic-electricity-suppliers/) (as of 2022). In addition, most UK suppliers offer at least one 100% green tariff to their consumers.

The UK also imported almost 42 TWh of GoOs from Europe in CP20 (latest available figures). However, this demand is since EU GoOs can be used for both FMD and to receive exemptions from the FiT and CfD levy (explained below)

UK: REGOS: Total Imports

According to the latest AIB data, EU GoO imports into the UK are still ongoing, but have reduced by approximately 50% from July 2022 to January 2023 (CP21 disclosure) compared to the same period in the previous year (CP20 disclosure), as shown below,

UK: REGOS: Import of EU GoOs from AIB countries

The decrease in EU GoO imports into the UK may be attributed to a combination of factors, such as higher EU GoO prices in 2023, lower FIT and CfD levies resulting from higher power prices, and some market players ceasing to import EU GoOs.

Green Excluded Electricity and Imports of EU GoOs


The Contracts for Difference (CfD) and Feed-in Tariff (FIT) schemes have a mechanism to not disadvantage green energy generation in other European Union countries (i.e. imported renewable energy). The exemption was originally granted to comply with EU state aid guidelines. This meant in practice after 2018, GoOs meeting certain conditions with corresponding power traded at power exchanges (implicit evidence mechanism) were deemed to be imported renewable energy and have been allowed CfD and FiT levy exemptions along with being eligible for disclosure for FMD (Fuel Mix Disclosure) purposes. These electricity amounts are referred to as Green Excluded Electricity (GEE).

GEE is determined after the end of the quarter (when Suppliers apply for exclusion based on their metered data for the entire quarter) and applied retrospectively when the quarter is reconciled. Each Supplier applies for their own GEE exemption amount, and this value is then adjusted in proportion to the total GEE amounts for all Suppliers, then capped in line with an overall total GEE maximum (quota or a cap). The bulk of the imports of EU GoOs by almost all suppliers except Octopus Energy is used for receiving FiT and/or CfD levy exemption, along with Fuel Mix Disclosure (FMD).

Since GEE backed by qualified EU GoOs can be used for CfD/FiT levy exemption, and also FMD, the imports of GoOs from Europe have been increasing. At the same time, the exports of REGOs have decreased due to the significantly higher prices of REGOs compared to EU GoOs, and regulatory barriers resulting in Britain becoming a huge net importer of EU GoOs within a short time.

UK: REGOS: Net Imports

OFGEM's acceptance of only explicit trading evidence, such as booked interconnector capacity for presentation of EU GoOs, from January 1, 2021, has led to a decline of imports of EU GoOs in CP20. The limited number of interconnectors connecting Great Britain's electricity market and the EU has resulted in an increase in REGO prices and a decrease in the import of EU GoOs from 2021 onwards.


The prices of REGOs, similar to their EU counterparts, have shown volatility. However, REGOs can only be used for FMD, while some EU GoOs can be utilized for both FMD and FiT/CfD levy exemption until the end of CP22, thus capping the prices of REGOs with the cost of acquiring supply evidence plus that of a EU GoO. This arrangement has traditionally led to REGO prices being low, trading at around 10-15 pence, until Q3 of 2019 when they increased to above 50 pence as they substituted for pricier EU GoOs. After 2019, prices fell back to around 20 pence until the beginning of 2021.

The requirement of explicit trading evidence, such as booked interconnector capacity for presentation of EU GoOs from January 1, 2021, has limited the import of EU GoOs, leading to a supply-demand imbalance of about 25TWh for the year 2021-2022 and a subsequent increase in prices. This increase in prices has also affected the REGO prices, particularly Non-Bio REGOs, which have surged significantly to over 6 GBP/MWh (monthly traded average prices are provided below).

UK: REGOs: Prices by CP

Bio(logical origin) REGOs (REGOs from Biomass, Waste, and Sewage) are usually cheaper than Non-Bio REGOs as most consumers for instance prefer electricity from wind rather than electricity from a Biomass plant.

The UK will continue to import during the 2022-23 reporting period. After the end of 2022-23 reporting period, the UK will no longer accept EU GoOs. Any requests to acknowledge EU GoOs must be submitted by midday on July 1, 2023. As a result of the stoppage, there will be a demand deficit of approximately 72 TWh for the CP22 period (2023-2024), which will create an imbalance in the market's supply and demand, as shown below.

UK: REGOS: Balance

Although this shortage of supply has already been factored into the current price of CP22 certificates, which are trading at a premium of 2 GBP, we anticipate that the supply of REGOs will remain tight, especially if the UK experiences lower wind speeds or harsh winters. This situation is likely to support higher prices in the future.


Appendix: Consultations on framework for strengthening disclosure

The UK government is currently reviewing (https://www.gov.uk/government/consultations/designing-a-framework-for-transparency-of-carbon-content-in-energy-products-call-for-evidence) to explore whether the current system is suitably transparent and whether the rules around what can be called a ‘green’ tariff remain fit for purpose. Options being explored include looking at increasing the granularity with hourly disclosure between M-RETS and Google being stated as an example in the consultation document (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1011032/carbon-content-energy-products-cfe.pdf), as well as whether suppliers need to provide clearer information to households about their green tariffs, including the type of renewable energy used (such as wind or solar), where the renewable power was generated and when.

These suggestions if implemented would most likely cause some price difference between Non-Bio technologies (For instance between hydro and solar) depending on consumer preferences and between months (for instance REGOs produced in winter months having higher prices than REGOs produced in summer months) or even in between hours depending on the granularity adopted. However, we think the implementation of hourly disclosure would result in much higher overheads leading to higher scheme costs and as such unlikely to be implemented. However, a move to monthly disclosure as seen in other European countries like France (https://portal.greenfact.com/News/1436/French-association-proposes-updates-to-monthly-disclosure-in-France), is more feasible.

Appendix: Top UK suppliers by REGO redemption volume (2021-2022)

Top UK suppliers by REGO redemption volume during CP20 (April 2021-March 2022) are given below: (last accessed on 16 August 2022)

UK: REGOs:Top redeemers

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