Why renewable energy traceability matters for UK I&C businesses

By Hazel Cockerill, Head of Trading & Renewables, Evolve Energy 

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. A renewable energy supply strategy built on a single instrument, priced by a market it does not control, carries more commercial risk than most organisations have modelled. 

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. A manufacturing operation consuming heavily during dark winter evenings can claim 100% renewable business electricity backed by generation that occurred months earlier, at a different time of day, in a different part of the country. The claim is compliant. The connection between consumption and generation is nominal. 

That gap was always present in the book-and-claim model. What has changed is who is examining it. 

The scrutiny closing in 

Britain's renewable output is accelerating at a rate that makes the timing mismatch harder to obscure. According to Financial Times analysis of University of Sheffield data, by mid-August 2025 solar had already generated 14.08 TWh, roughly one-third more than at the same point the previous year. A new half-hour record of 14 GW was reached on 8th July 2025, accounting for almost 40% of demand in that settlement period. This growth is structurally positive for decarbonisation. It also makes the question of when renewable generation occurred more visible, not less. 

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? For I&C organisations with large overnight loads, high baseload demands or significant winter consumption, the honest answer under a certificate-only approach is no. 

That matters beyond disclosure. Scope 2 emissions reporting is moving toward market-based methods that require greater temporal granularity. The UK Government has extended Contracts for Difference for wind and solar projects from 15 to 20 years and increased administrative strike prices for certain technologies to maintain investor confidence following weaker auction rounds. Policy is reinforcing the long-term build-out of renewable generation. As that generation scales, so does the infrastructure for examining how it is allocated to end users. The expectation that allocation will be evidenced, not inferred, is already embedded in that infrastructure. 

The decision already made elsewhere 

The problem for energy managers and sustainability leads is not that traceability is emerging as a future requirement. It is that some of their peers have already repositioned. 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: consumption matched to specific generation assets, with settlement data to support it. 

The issue is not access to traceability itself. The issue is that the methods available for achieving it have, until recently, sat behind credit and contracting barriers that most mid-market I&C organisations could not clear. Book-and-claim was not chosen because it was optimal. It was chosen because the alternatives required scale, creditworthiness and contracting appetite that most buyers could not demonstrate. 

That structural barrier is narrowing. 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. The mechanism for credible matching now exists at a scale that mid-market I&C buyers can access. 

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, and does that demonstration withstand the scrutiny we expect to face from investors, auditors and supply chain partners over the life of this contract? 

The problem is not that a certificate-only strategy is wrong today. The problem is that it is being evaluated against tomorrow's expectations. The gap between what a book-and-claim model can evidence and what stakeholders are increasingly prepared to accept is widening with each disclosure cycle. 

For TPIs advising large portfolios, this creates a positioning decision that sits outside the contract renewal itself. Many business energy suppliers can provide REGOs as part of a supply contract. Fewer can structure arrangements that align renewable generation with consumption on a granular basis. The ability to offer asset-level traceability, half-hourly matching or consortium-based access to renewable energy from UK generators distinguishes procurement advice that is defensible under scrutiny from procurement advice that merely satisfies a reporting template. 

The strategic question is not whether your current renewable energy supply meets today's compliance threshold. The question is whether the evidence it generates will satisfy the stakeholders who will review it, and whether that threshold will look the same in three years as it does now. 

→ Ready to move beyond standard business energy suppliers? Discover how Evolve Energy delivers transparent, traceable renewable energy for UK businesses here.