EUAA Submission: Guarantee of Origin Proposed Cost Recovery Implementation Statement FY2025-26
Emily Wood | June 5, 2026
Getting the cost recovery methodology right has large impacts on large consumers. At one end, costs could be prohibitively high for consumers, at the other, there may be a lack of incentive to new technologies to be invested in by developers.
‘…The EUAA supports the CER’s intent to smooth the introduction of cost recovery for renewable gases and low‑emissions products. The proposed alignment of Renewable Electricity Guarantee of Origin (REGO) cost recovery with the Renewable Energy Target (RET), combined with phased‑in remissions for Product Guarantee of Origin (PGO) methodologies, provides a sensible transition pathway for technologies already close to commercial deployment. These settings will allow early movers to participate in the scheme at low cost and begin building the market foundations needed for credible emissions accounting.
However, the key risk for our members is that these benefits will accrue almost exclusively to projects that are already well advanced. New entrants, particularly in emerging renewable gas sectors, will face the full cost curve much sooner as remissions decline and full cost recovery approaches. This creates a structural disadvantage for technologies that are not yet at scale and may unintentionally favour early movers over broader market development…’
Please download attached document to read full submission.
