UK industrial and commercial (I&C) organisations have spent a decade building renewable energy strategies on a single instrument. One Renewable Energy Guarantee of Origin (REGO) per megawatt-hour consumed: clean, auditable, Ofgem-recognised. For a market where renewable output was growing steadily and ESG scrutiny was still finding its footing, that model was sufficient. It no longer is.
The certificate model under pressure
REGO prices reached record highs of around £20 per certificate in late 2023. For large energy users with significant consumption profiles, the cost exposure was immediate. Prices have since softened: the 2024–25 disclosure year saw average prices fall from £2.56 in January to £0.77 by April. The volatility itself is the signal.
The structural limitation is not price alone. REGOs operate on an annual redemption model: certificates are issued at the point of generation and retired against consumption across the disclosure year. Summer solar output in June can be retired against winter demand in December. The claim is compliant. The connection between consumption and generation is nominal.
The scrutiny closing in
Britain's renewable output is accelerating at a rate that makes the timing mismatch harder to obscure. By mid-August 2025 solar had already generated 14.08 TWh, roughly one-third more than at the same point the previous year.
Investors, supply chain auditors and Scope 2 reporting frameworks are starting to ask a question that the REGO model was not designed to answer: can you demonstrate that your renewable electricity was generated at a time and from a source that actually corresponds to when and how you consumed it?
The decision already made elsewhere
Large I&C buyers with the appetite and credit profile for corporate power purchase agreements (PPAs) have been structuring direct relationships with renewable generators for several years. Those arrangements provide asset-level traceability as a feature of the contract.
Half-hourly matching models, renewable energy consortiums and asset-level traceability tools allow renewable business electricity to be linked more closely to a company's actual load shape without requiring every business to hold a long-term corporate PPA directly.
What the procurement review now has to answer
For energy managers and sustainability leads reviewing their flexible business energy contracts in the next twelve to eighteen months, the REGO question has shifted. It is no longer simply: do we hold the right volume of certificates? It is: can we demonstrate when and where our renewable electricity was generated?
→ Ready to move beyond standard business energy suppliers? Discover how Evolve Energy delivers transparent, traceable renewable energy for UK businesses.
