On 23 June, the Norwegian Ministry of Energy published new guidance for companies on calculating emissions related to electricity consumption, with a clear emphasis on the distinction between physical electricity use and market-based certificate claims.

The logic behind Norway’s position is understandable. The electricity actually consumed in Norway is approximately 95% renewable, with an emissions factor of around 15 gCO₂e/kWh, compared with roughly 200 gCO₂e/kWh in the EU average. From this perspective, relying too heavily on market-based accounting through Guarantees of Origin may create a misleading picture of the actual electricity used by Norwegian companies.

This is where the issue becomes important.

Norway is not moving against Guarantees of Origin as a system. Rather, it is trying to ensure that the use of these certificates does not obscure one of the country’s strongest industrial advantages: access to a highly renewable and low-carbon electricity grid.

A large share of Norwegian Guarantees of Origin is sold abroad, with Germany being one of the major importers. However, selling certificates does not change the physical flow of electricity in the grid. Norwegian companies still consume electricity from a system largely supplied by renewable hydropower. Yet, in sustainability reporting, these companies may appear to use electricity with a higher carbon footprint simply because the associated certificates have been sold separately.

The Norwegian guidance is very direct on this point: Guarantees of Origin document the market-based or financial attribute of renewable electricity production, not the physical carbon footprint of the electricity actually consumed. It also points clearly to the risk of double-counting, where renewable electricity is physically delivered to one consumer while the associated certificate is sold as a separate claim to another.

As a researcher and critical observer of energy certificate markets, I believe this is an important development.

The problem is not the existence of Guarantees of Origin. They are valuable instruments for documenting renewable electricity production, creating additional revenue streams for producers, and enabling companies to support renewable energy through the market. The real problem starts when certificates are interpreted as if they automatically reflect the physical electricity consumed, or as if they erase the actual grid context in which consumption takes place.

In my view, Norway is not against GOs. It provides clearer guidance on how they should be understood, reported, and communicated. Climate reporting should not only be correct from an accounting perspective. It should also be understandable from a physical and climate-impact perspective.

This leads to a much bigger question for the future of renewable electricity claims:

Is it enough for a company to buy renewable electricity certificates?

Or should we also ask where, when, and under what grid conditions the electricity was actually produced and consumed? This is why I believe the future of energy certificates will move toward greater transparency, dual reporting of both location-based and market-based emissions, and eventually more granular instruments that reflect time and location more accurately, such as Granular Certificates.

In short:

Norway is not fighting Guarantees of Origin. It clarifies how they should be used when market-based claims risk becomes disconnected from physical electricity realities. That clarification is essential if renewable energy certificates are to remain credible tools for climate reporting, corporate procurement, and the energy transition.