Summary
Details
- Denmark
Legally binding for:
Energy suppliers and market participants use GOs for disclosure and claims.
Corporate buyers are relying on GOs to support renewable energy statements.
Entities not making renewable attribute claims are not required to use GOs, but cannot legitimately claim renewable sourcing without compliant instruments.
Claims based on other contractual structures may still require careful alignment with Danish and EU disclosure rules.
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What’s Required
Denmark operates a guarantee of origin (GOs) system that allows energy suppliers and consumers to document renewable energy attributes, administered through Energinet rules and registries.
Key requirements include:
GOs are issued, transferred and cancelled through authorised registry systems based on measured production.
Suppliers and corporate buyers must ensure claims about renewable electricity or renewable gas are supported by cancelled GOs or equivalent compliant instruments.
Market participants must follow registry rules, documentation standards and verification controls.
Misleading renewable attribute claims can trigger greenwashing exposure under marketing rules, especially where claims imply additional climate impact without a basis.
Important Deadlines
Ongoing: registry account maintenance and compliance with issuance, transfer and cancellation rules.
Event-based: cancellation must align with the reporting/claim period to substantiate supplier disclosures and corporate claims.
Current Status
Energinet continues to operate GO systems for renewable electricity and renewable gas, including documented notices and guidelines that define compliance expectations.
Penalties for Non-Compliance
Registry enforcement measures and potential restrictions for non-compliant market participants.
Elevated risk of enforcement under marketing law if renewable claims are misleading or poorly evidenced.
Reputational and contractual exposure where claims cannot be substantiated.
Examples of Known Violations
Claiming “100% renewable electricity” without cancellation of GOs matching the consumption period.
Double-counting risk where attributes are claimed by more than one party.
Claims implying climate additionality from GO purchases without a clear basis or context.
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