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Submission

AHC FED Guarantee of Origin Scheme Exposure Drafts

You can download the full PDF here.

Emma Flanigan
Director, Guarantee of Origin and Trade Section
Department of Climate Change, Energy, the Environment and Water
Australian Government
GPO Box 3090, Canberra ACT 2601, Australia

Dear the Guarantee of Origin teams,

Re: Guarantee of Origin Scheme consultations

The Australian Hydrogen Council (AHC) commends the Australian Government on operationalising the detailed design of the Guarantee of Origin Scheme (GO Scheme) ahead of its commencement later this year.

The AHC is the peak body for the hydrogen industry and our membership includes companies from across the value chain. Our members are at the forefront of Australia’s hydrogen industry, developing the technology, skills and partnerships necessary to ensure that hydrogen and its derivatives play a meaningful role in decarbonising and strengthening Australian industry.

We are pleased to see the GO Scheme in its final stages of design; AHC has been supportive and strongly engaged with the mechanism since its inception. The GO Scheme enables the international trade of hydrogen and derivatives, aligning with emerging international best practice, and positioning Australia as a trusted and credible partner. Furthermore, this robust certification scheme continues to grow in importance as Australia develops domestic policies that will utilise its reporting, support decarbonisation claims and provide confidence in these nascent markets.

The AHC welcomes the opportunity to provide feedback on this round of GO Scheme consultation that looks to operationalise the certification scheme. This includes the proposed structure for the:

  • registration of persons;
  • certification of products;
  • GO Register;
  • cost recovery mechanism;
  • audits; and
  • methodology for emissions accounting regarding to hydrogen from electrolysis.


We are supportive of the direction that the Australian Government has proposed in the exposure drafts and note that these respond to many of the suggestions proposed by the AHC and members in previous consultations.[1]  

As you continue shaping the GO Scheme, please consider these comments and points of clarification from the AHC membership:

  • Consideration of mobility. The scheme is not clear in its consideration of the mobility sector (i.e. commercial hydrogen fuel cell electric vehicles), which raises various questions regarding:
    • Who registers the consumption profile. The language used for a consumption profile is a ‘facility’ which is not compatible with mobility. It remains somewhat unclear if the driver or owner operator of the fleet has the responsibility to register and pay CER fees as a consumer of the hydrogen.
    • How to incentivise voluntary scheme use by subcontractors. Larger companies (such as freight and logistics) looking to decarbonise their scope 3 emissions often rely on subcontractors and there is little incentive for these smaller logistics companies (often owner-drivers) to undergo the administration of registering and surrendering PGO certificates.
    • How redundancy of supply will be considered. An example was provided of a freight company contracted to use electrolytic hydrogen that also chooses to purchase hydrogen from other sources (e.g. blue or grey hydrogen from steam methane reforming) to cover any potential shortalls in supply or stoppages in the production or delivery. In this case, given that the GO Scheme is voluntary, will the freight company need to purchase both sets of certificates or can they volunteer to only report on the green hydrogen?
  • Timelines for scheme expansion. The timeline provided though the consultation mentions priorities for expansion, however, members that produce hydrogen through other methods (e.g. pyrolysis, photocatalysis, steam methane reforming with carbon capture, etc) or are working on alternative hydrogen carriers (e.g. methylcyclohexane) seek transparency on when these would likely be available for certification. If a comprehensive timeline cannot be provided at this stage, it would be ideal to understand the growing list of products and methodologies that the Australian Government is considering, and in priority order. This was covered in an earlier consultation[2] but the status of this proposal is uncertain.
  • Interoperability and export. AHC appreciates that the GO Scheme has been developed with interoperability in mind, aligning with international certification schemes and processes. Noting that the GO Scheme reports until the final Australian port for export, members request clarity on how the data will be transferred to international buyers and schemes.
  • Reporting on First Nations attributes. The consultation proposes the possibility of including optional reporting on First Nations attributes. AHC is deeply committed to the principles of inclusion and partnership with First Nations communities in the emerging energy industries and whilst we support the intention of the policymakers in suggesting the inclusion of First Nations attributes in the GO Scheme, AHC does not agree that the GO Scheme is the correct avenue for this reporting. Our contention is that the purpose of the GO Scheme is to verify objective, quantifiable and technical factors relating to emissions intensity in the production of hydrogen and derivatives, and is already a complex, new and voluntary reporting undertaking for industry. The quantitative measurement and reporting of carbon intensity is significantly different to the qualitative reporting being suggested and, we would argue, the evaluation of the policy intentions for the GO Scheme or broader Future Made in Australia agenda are better served via other reporting mechanisms. The AHC would welcome further discussions with the Australian Government.
  • Reporting requirements. We have previously provided comment on the proposed requirement to report on gas pressure and whether or not a project has received financial backing from government.[3] We continue to urge drafters of the GO Scheme regulations to ensure that all data collected is useful and satisfies a clear objective – a threshold that the requirement to report pressure and government support does not meet. AHC and members argue that this information should be supplied on an as-needs basis, only when requested by either the regulator or the customer.
  • Pace of implementation. AHC is supportive of the Australian Government’s prioritisation, ensuring that the GO Scheme commences in 2025. It is imperative that the GO Scheme is established and not delayed by the development and consultation of further methodologies and products. Adding these updates in a rolling manner, as they are finalised, maintains credibility. Similarly, the use of default values where necessary also facilitates uptake and pace, especially in the early phase.
  • Review mechanism. The GO Scheme has undergone significant trials and consultation, however, in a nascent industry, much of this has been based on modelling or on the experience of individual sites. Given that this is a voluntary scheme and international guidance around verification is still emerging, it is imperative that any issues, problematic processes or misalignments with international mechanisms are swiftly discovered and resolved. Any practical limitations in adhering to the scheme identified by early proponents should also be subject to further consideration and potential adjustment as appropriate. We therefore ask that you actively engage stakeholders and conduct regular reviews (6 and/or 12 month) with participants in the first few years of the scheme to be able to iterate the design of the program.


The AHC and its members are keen to see the extension of the GO Scheme to green metals and low carbon liquid fuels (including through the targeted discussion papers) and are eager to continue engagement on the GO Scheme through the final tranche of consultation.

If you wish to discuss any element of this submission in further detail, please contact us on [email protected] or [email protected].

Kind Regards,

Natasha Cerexhe
Policy Manager
Australian Hydrogen Council

[1] AHC (2025) Future Made in Australia (Guarantee of Origin) Rules 2025, submission, 27 March, https://aidc.org.au/wp-content/uploads/2025/03/250327-GO-Rules-AHC-submission.pdf ; AHC (2024) Future Made in Australia (Guarantee of Origin) Bill 2024 [Provisions] and related bills, submission, 26 September, https://aidc.org.au/wp-content/uploads/2024/09/240926-FMIA-GO-Scheme-AHC-submission.pdf ; AHC (2023) Consultation on Australia’s Guarantee of Origin Scheme Design, 24 October, https://aidc.org.au/wp-content/uploads/2023/10/231023-GO-Scheme-submission.pdf.  

[2] DCCEEW (2023) Australia’s Guarantee of Origin Scheme: consultation on scheme design, emissions accounting and renewable electricity certification, Australian Government, September, https://consult.dcceew.gov.au/aus-guarantee-of-origin-scheme-consultations-on-design.

[3] AHC (2025) Future Made in Australia (Guarantee of Origin) Rules 2025, submission, 27 March, https://aidc.org.au/wp-content/uploads/2025/03/250327-GO-Rules-AHC-submission.pdf