A guarantee of origin for energy is a document that assigns the renewable-origin attribute of a specified volume of energy to an end customer. For electricity in Poland, the document is expressed in MWh and operates within an electronic registry. It is not, however, proof that electrons from a specific wind farm, photovoltaic installation or hydropower plant physically flowed to a particular facility.
This distinction matters in energy procurement, emissions reporting and ESG communications. A company should document its energy consumption separately, then document the acquisition of the appropriate guarantees, and subsequently their cancellation for the correct end customer. Only this complete chain of documents provides a basis for a precise claim that a specified volume of consumption is covered by renewable-energy attributes.
In brief
- A guarantee of origin confirms that a specified amount of energy was generated from a renewable source and fed into the relevant network or another location permitted by law.
- A guarantee is not a “route” showing the physical path of energy from source to customer. The origin attribute and the physical supply can be separated.
- Merely purchasing or holding a guarantee is not sufficient to inform an end customer about the origin of energy. In the Polish system, cancellation and obtaining confirmation of cancellation are essential.
- A guarantee of origin is not the same as a green certificate, i.e. a certificate of origin forming part of a separate support scheme in Poland.
- For emissions reporting, guarantees may serve as a contractual instrument under the market-based approach, but the requirements of the applicable standard must be met and a complete audit trail retained.
Guarantees of origin for energy – what are they?
Under the Polish Renewable Energy Sources Act, a guarantee of origin is an electronic document certifying to an end customer that the amount of energy specified in it was generated from renewable energy sources and fed into the relevant network or another location permitted by the Act. For electricity, guarantees are issued in units of 1 MWh.
In practice, this means that the document transfers information about the origin attribute. The guarantee itself is neither an energy sales contract nor proof of physical delivery; it does not confer property rights. The Polish Act expressly distinguishes guarantees of origin from the property rights arising from certificates of origin.
Colloquial terms such as “renewable energy certificate” or “RES certificate” are sometimes used. In documents, contracts and reports, however, the precise term guarantee of origin should be used because, in the Polish system, a “certificate of origin” denotes a different instrument.
A guarantee may state, among other things, the energy source, the production period and information about the installation. A buyer can therefore define technology requirements, such as wind, solar or hydropower, if this criterion is relevant to its procurement policy. A technology preference still does not mean that energy from the selected installation is physically delivered to the facility.
How does the guarantee-of-origin mechanism work?
The simplest way to understand the mechanism is to divide it into four stages: issuance, registration, transfer and cancellation.
1. Energy generation and application for a guarantee
Guarantees of origin are issued upon a written application by the producer; the Polish Act excludes micro-installations from this procedure. For electricity generated and fed into the grid, the application is submitted to the relevant distribution or transmission system operator. In other cases provided for by the Act, including certain arrangements involving a direct line, the application is submitted to an accredited body. Poland’s Energy Regulatory Office (URE) describes the current procedure and publishes a sample application form.
The application must be submitted within 30 days after the end of generation of the amount of energy covered by the application. The production period specified in the application may cover one or more consecutive calendar months within the same year, but it may not exceed 6 months.
A specific restriction has also applied since 30 April 2026: guarantees of origin are not issued for electricity generated during periods in which activities are carried out under Article 33b of the Polish Energy Law Act, i.e. during the special period preceding the obtaining of the required licence. This follows from the amendment of 13 March 2026.
2. Verification and issuance by the President of URE
The operator or competent body verifies the data and forwards the complete application to the President of URE. The Polish Act provides 30 days for issuing the guarantee from the date on which the complete application is forwarded. The guarantee is electronic and is entered directly in the Guarantees of Origin Registry.
For a purchasing company, the producer’s procedure itself is less important than ensuring that the volume being acquired is actually recorded in the registry and has the appropriate status, production period and characteristics required by the procurement policy or reporting standard.
3. Registry and trading of guarantees of origin
In Poland, the Guarantees of Origin Registry is operated by Towarowa Giełda Energii (TGE, Polish Power Exchange). Under the Polish Act, a guarantee is transferred when the relevant entry is made in the registry. The commercial terms of the purchase may be agreed between the parties, but an effective transfer of the guarantee must be reflected in the RGP registry.
The current TGE guide to the RGP states that a sale requires cooperation between two registry members and that the transaction includes, among other things, the volume and the net price per 1 MWh. TGE provides the registry system but does not financially settle transactions between the parties. Separate registry fees apply to specified operations.
4. Cancellation of a guarantee for the end customer
This is the most important stage for subsequent reporting and communication. The Polish Act states that an end customer may be informed about the origin of energy for which a guarantee has been issued only after the guarantee has first been cancelled and confirmation of cancellation has been obtained.
The holder of the guarantee submits a cancellation instruction in the registry. Cancellation takes effect when the instruction is registered and is irreversible. At the request of the entity that performed the cancellation, TGE confirms the cancellation; the Polish Act provides 10 working days from receipt of the relevant request.
A guarantee remains valid for transfer for 12 months from the end of the generation period covered by the application. It must be cancelled within 18 months from the end of generation; if it is not cancelled by that deadline, it expires.
Guarantee of origin vs physical delivery of energy to a facility
In the public electricity grid, energy from many sources is supplied into a common system. A customer drawing electricity from the grid does not receive a separate stream of electrons assigned to a specific power plant merely because it has purchased a guarantee of origin.
It is therefore useful to think in terms of two parallel layers:
- physical layer – energy is generated, fed into the system and consumed by customers according to how the grid operates;
- attribute layer – information about the renewable origin of a specified MWh volume is registered, can be transferred and can then be cancelled for an end customer.
This separation is also consistent with EU Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources, which allows guarantees to be transferred separately from, or together with, the physical transfer of energy.
If a company needs a relationship with a specific source, it should also analyse the structure of the power purchase agreement, a PPA, a direct line or other supply arrangements. A guarantee of origin alone does not replace these instruments. We discuss the organisation of contracting in more detail in our guide to the electricity and gas procurement process.
What can and cannot be claimed on the basis of a guarantee of origin?
The safest rule is: a claim should correspond exactly to what can be demonstrated by the documentation – without extending the origin attribute to the physical flow of energy, investment additionality or the company’s overall climate neutrality.
| Example claim | Assessment | Condition or explanation |
|---|---|---|
| “Guarantees of origin from renewable sources were cancelled for 10,000 MWh of our consumption in 2026.” | Yes | Consumption, volume, period and beneficiary must match the cancellation documentation. |
| “100% of the documented electricity consumption at the facilities covered by the report was matched with cancelled guarantees of origin.” | Yes, conditionally | Only if the number of eligible MWh represented by the guarantees is at least equal to consumption within the same reporting boundary. |
| “Electricity from wind farm X physically flows to our facility.” | Not on the basis of the guarantee alone | A guarantee does not trace the physical flow of electricity through the grid to a specific customer. |
| “Purchasing the guarantees financed the construction of a new renewable-energy installation.” | No | A guarantee alone does not prove additionality or a causal link to a new investment. |
| “Thanks to the guarantees, we are a zero-emission company.” | No | The document covers the origin attribute of a specified volume of energy; it does not cover all emissions of the company. |
| “We comply with all legal requirements relating to renewable energy.” | No | Obligations depend on the specific regulation. A guarantee can serve as evidence only where the applicable provision expressly allows it. |
| “We used guarantees in our market-based Scope 2 calculation.” | Yes, conditionally | The criteria of the applicable standard must be met, including requirements relating to contractual instruments and the prevention of double claiming. |
In external communications, it is better to state that guarantees of origin were cancelled for a specified volume of consumption than to use shorthand such as “our energy physically comes from…”, unless the company has additional grounds for making that statement.
Does every energy-intensive company have to purchase guarantees of origin?
No. That conclusion would be too broad.
The Polish Renewable Energy Sources Act contains a specific obligation for certain industrial consumers that have benefited from particular entitlements under the RES Act or the regulations on high-efficiency cogeneration and at the same time meet the conditions specified in the Polish Energy Efficiency Act. For this group, one way of fulfilling the obligation is to demonstrate that at least 30% of the electricity used for own purposes in a given year came from sources that avoid greenhouse-gas emissions.
In this specific option, Article 54a of the Polish RES Act provides, as one form of evidence, confirmation that guarantees of origin were cancelled for the relevant industrial consumer within the required period. A purchase alone, or the balance of guarantees in an account, does not replace this confirmation.
For example, if an eligible industrial consumer used 40,000 MWh of electricity for its own purposes, 30% is:
40,000 MWh × 30% = 12,000 MWh.
This calculation only illustrates the required volume under this one statutory option. Before relying on it to demonstrate legal compliance, the company must confirm its status, the scope of the entitlements used, the year to which the obligation applies and the documents permitted under Article 54a.
Guarantees of origin vs green certificates – they are not the same instrument
In Polish terminology, it is easy to confuse a guarantee of origin with a certificate of origin, commonly referred to as a green certificate.
| Guarantee of origin | Certificate of origin / green certificate |
|---|---|
| Documents the origin attribute of a specified amount of energy for an end customer. | Forms part of a separate support scheme and is associated with property rights. |
| A guarantee alone does not confer property rights. | Property rights are the essence of the certificate trading mechanism. |
| Can be transferred independently of the physical energy. | Operates under separate statutory and registry rules. |
| For an end-customer claim, the key stage is cancellation of the guarantee for the correct beneficiary. | Cancellation of certificates serves other obligations and does not replace cancellation of a guarantee. |
The terms “RES certificate”, “green certificate” and “guarantee of origin” should therefore not be used interchangeably in procurement or reporting documentation.
How much do guarantees of origin cost?
There is no single statutory price for a guarantee of origin. The commercial price is a transaction term agreed between the parties and may depend on factors such as the technology, country or installation of origin, production period, available volume, validity of the guarantee and additional buyer criteria.
The RGP system provides for stating the net price per 1 MWh when a transaction is reported. TGE also charges separate registry fees for specified operations in accordance with the current fee schedule. An offer should therefore be broken down at least into the price of the attribute itself, registry costs and any intermediary margin or service fee.
A decision should not be based on a random “guarantee price found online”. When comparing offers, check whether they concern the same technology, the same production period and the same market, and whether the price includes cancellation and the document confirming cancellation.
Which documents and information should a company verify before using guarantees in reporting?
Good documentation starts with consumption data, not with the invoice for the guarantees themselves. In practice, at least the following should be collected and reconciled:
- Energy consumption scope – legal entity, locations, reporting period, metering points and documented MWh from invoices or measurements.
- Claim scope – whether the statement relates to the whole company, selected facilities, a product, a country or only a specified period.
- Guarantee parameters – number or identifiable batch, MWh volume, energy carrier, technology, production period, installation details and country of origin if relevant to the intended use.
- Status and validity – whether the guarantee can still be transferred and cancelled within the required deadline.
- Acquisition document – contract, transaction confirmation or invoice showing the number of MWh and the party responsible for performing the registry operations.
- Cancellation confirmation – a document identifying the correct end customer and the volume cancelled for that customer.
- Beneficiary alignment – the name and scope of the entity stated in the confirmation should correspond to the entity that will make the claim or report the consumption.
- Period matching – the guarantee production period and the consumption period should be assessed against the requirements of the applicable reporting system or procurement policy, not only against the statutory validity period.
- Rules for foreign guarantees – if a company uses instruments issued outside Poland, it must check whether they are recognised and can be used in the relevant registry and reporting standard.
- Audit trail – retain consumption data, the purchase agreement, transfer confirmation, cancellation, the coverage calculation and the final wording of the claim.
From an auditor’s perspective, I would first establish the consumption boundary, the entity and the period, and only then match the volume of guarantees. A certificate does not correct an incorrect reporting boundary or missing metering data – it documents the origin attribute for the assigned MWh volume.
How do you calculate the share of consumption covered by guarantees of origin?
Assume that a company has three facilities covered by a single report. Documented annual electricity consumption is 10,000 MWh, and 7,500 MWh of eligible guarantees have been correctly cancelled for the company.
The coverage ratio is:
7,500 MWh ÷ 10,000 MWh × 100% = 75%.
The company can therefore demonstrate that 75% of the consumption volume within that scope was covered by properly cancelled guarantees. It should not claim 100% coverage on this basis. The percentage calculated in this way still describes coverage by the origin attribute, not the percentage of physical electrons from renewable sources that reached the facility.
If there are 10,000 MWh of guarantees and all of them meet the requirements of the intended use, coverage may be 100%. Any surplus of guarantees above consumption should not be used to artificially increase the share above 100% within the same scope.
Guarantees of origin in Scope 2 and emissions reporting
Under the GHG Protocol Scope 2 Guidance, guarantees of origin fall within the broader category of energy attribute certificates and may constitute a contractual instrument used to calculate Scope 2 emissions under the market-based method, provided that they meet the relevant quality criteria. For organisations operating in markets where contractual instruments are available, the GHG Protocol provides for parallel reporting of location-based and market-based results.
This has two important implications. First, using guarantees under the market-based approach does not change the location-based result, which reflects the average characteristics of the grid serving the place of consumption. Second, simply holding a guarantee is not enough: checks are required, among other things, on the exclusive allocation of attributes to the customer, the absence of double claiming, the appropriate reporting boundary and data quality, and the remaining requirements of the applicable standard.
A guarantee is also not automatic proof of “additionality”, i.e. that the company’s purchase caused a new renewable installation to be built. If an organisation wants to communicate the impact of its energy procurement on the development of new capacity, it needs separate evidence and a carefully formulated methodology.
As of 19 August 2026, the published 2015 Scope 2 Guidance remains a reference point for the GHG Protocol, but the standard is undergoing revision and harmonisation with ISO. For reports covering later years, it is therefore worth checking which version of the standard applies to the relevant period and reporting programme rather than automatically carrying today’s rules into the future. GHG Protocol publishes updates on the process.
Common mistakes when purchasing and communicating guarantees of origin
Purchasing a volume before defining the reporting boundary
If procurement buys 20,000 MWh of guarantees but the ESG team later determines that the report covers different companies, locations or periods, some of the documents may not match the claim. Define the scope first; purchase the attributes afterwards.
Treating an invoice as proof that guarantees have been used
An invoice confirms the commercial transaction, but it does not replace the registry entry or the cancellation confirmation. The contract should clearly state who is responsible for transfer and cancellation and which documents the customer is to receive.
A “100% renewable energy” claim without defining what the 100% refers to
Does it refer to the entire group, one company, three facilities, a product, a calendar year or electricity only? The broader the statement, the greater the risk that the documentation does not support the entire claim. A precise scope is better than an attractive but unsubstantiated slogan.
Confusing a guarantee of origin with a PPA or physical delivery
Guarantees can be purchased independently of the energy itself. If a company wants to combine the purchase of attributes with long-term contracting from a specified installation, it should analyse both elements of the arrangement, not only the guarantee of origin.
Failure to monitor the guarantee’s deadline and status
When purchasing near the end of the reporting period, check the production date, transfer validity and cancellation deadline. Cheap guarantees that can no longer be used for the company’s intended purpose are not a good offer.
How should a company organise the purchase of guarantees of origin?
A practical sequence of steps may be as follows:
- calculate actual energy consumption within the planned scope;
- define what the guarantees are intended for: communications, a customer requirement, a GHG report, procurement policy or a specific legal obligation;
- check the criteria required for that purpose – technology, country, production period, cancellation method and beneficiary details;
- compare offers not only by price but also by the characteristics of the guarantees and the scope of registry services;
- specify in the contract the volume, guarantee parameters, transfer and cancellation deadlines, and final documents;
- after the operation, reconcile the cancelled MWh with the consumption data;
- only then prepare the final wording for the report, website or customer materials.
If guarantees form part of a broader procurement strategy, they should be analysed together with the consumption profile, contract structure and other contracting options. A useful starting point is an analysis of the energy procurement process and the available Energy Trend services.
FAQ
Does a guarantee of origin mean that I physically buy electricity from renewable sources?
No. A guarantee confirms the renewable-origin attribute of a specified volume of energy. When electricity is drawn from the public grid, it is not proof that electricity from the specific installation identified in the guarantee physically reached the facility.
Is purchasing a guarantee of origin enough to say that a company uses renewable energy?
The purchase alone is not sufficient under the Polish system. To inform an end customer, the Polish Act requires prior cancellation of the guarantee and obtaining confirmation. The wording of the claim must also correspond to the volume, period and scope covered by the documentation.
Are a guarantee of origin and a green certificate the same thing?
No. A guarantee documents the origin attribute for an end customer and does not confer property rights. A green certificate, i.e. a certificate of origin in the Polish system, forms part of a separate support scheme and is associated with property rights.
Do guarantees of origin have a fixed price?
No. The price of the guarantee itself is determined by the market and agreed between the parties; registry fees and service costs may apply separately. When comparing offers, compare guarantees with similar parameters and check whether the price includes transfer, cancellation and the final confirmation document.
Can a guarantee of origin be used in a Scope 2 report?
It may be used as an instrument under the market-based method if it meets the requirements of the current reporting standard. This does not change the location-based result and does not automatically provide a basis for claiming climate neutrality for the organisation as a whole.
How can guarantees of origin be used without overinterpreting them?
The main value of a guarantee of origin is that it creates an orderly, registry-based mechanism for assigning the renewable-origin attribute to a specified MWh volume. Its credibility, however, depends on correctly matching consumption, carrying out the transfer and cancellation properly, and communicating the result precisely.
For a company, the practical objective should therefore not be merely to “buy a certificate”, but to maintain a complete chain: consumption → appropriate guarantee → transfer → cancellation → confirmation → volume reconciliation → careful claim. This structure facilitates auditing and reporting and reduces the risk of statements that the documentation does not actually support.
Sources
- Polish Renewable Energy Sources Act – current consolidated ELI text as at 3.08.2026; Journal of Laws 2026, items 68, 516, 900 and 912.
- Act of 13 March 2026 amending, among other legislation, the Polish Renewable Energy Sources Act, Journal of Laws 2026, item 516.
- Poland’s Energy Regulatory Office – Guarantees of Origin.
- TGE Guarantees of Origin Registry and RGP System Guide, version 2.0 dated 29.04.2026.
- Directive (EU) 2018/2001 – consolidated text, Article 19.
- GHG Protocol – Scope 2 Guidance and Scope 2 FAQ.
