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Guarantee of Origin scheme exposure draft legislative instruments specific to renewable electricity (Sept 2025)

Australia’s renewable build-out will intersect with First Nations rights and interests.

Guarantee of Origin (GO) certificates and the public GO Register will shape market claims and investment.

Recognising verified First Nations outcomes on Renewable Electricity Guarantee of Origin (REGO) certificates is therefore central to integrity, social licence and Australia’s policy objectives (including the First Nations Clean Energy Strategy and various other policy and market schemes which highlight the importance of principles based on genuine partnership, benefit-sharing, capability and accountability). 

To be credible, investable and consistent with Australia’s commitments to self-determination and free, prior and informed consent (FPIC), including as set out in the First Nations Clean Energy Strategy, the framework must: 

  1. embed ongoing, revocable FPIC 
  2. prioritise Traditional Owner leadership and representation where projects affect Country; 
  3. ensure economic participation (ownership, equity, employment, procurement) is measurable, additional to business-as-usual (BAU), and improves over time; and 
  4. provide robust verification, audit and consequences for non-compliance. 

Key Recommendations 

  1. Convert “Consent Verified” to “FPIC — Current and Ongoing.” Consent must be current when each REGO is created, tied to the appropriate First Nations decision-making body, and be revocable with a clear, public status on the GO Register. 
  2. Broaden land-tenure recognition and visibility. Require mandatory registration fields where facilities are on native title land, subject to ILUAs, held under state/territory land rights regimes or on other First Nations-held land. 
  3. Adopt the full attribute suite from the Concept Paper: FPIC; Ownership; Equity; Majority Board Representation; Procurement; Employment Contribution; Cultural Heritage Management; Benefit-Sharing Agreement. 
  4. Lift and tier thresholds to avoid Business As Usual. Use bands for equity (e.g. 5–9%, 10–24%, 25–49%), employment (e.g. 5–9%, 10–19%, ≥20%), and procurement set at ≥3% of project expenditure (directly related to development/operations) with bands 3–4.9%; 5–9.9%; ≥10% — aligning with the Commonwealth’s Indigenous Procurement Policy direction. 
  5. On-certificate clarity of “who benefits.” For each attribute claimed, identify the First Nations group(s)/entity(ies), scope, evidence date(s) and status (e.g., “FPIC current to DD/MM/YYYY”). Make First Nations attributes machine-readable and searchable on the GO Register. 
  6. Consequences for cultural heritage breaches and FPIC withdrawal. Court-found / statutory authority contraventions of cultural heritage law should automatically suspend relevant attributes on future REGOs; withdrawal of FPIC must trigger a suspension/flag on the Register until rectified. 
  7. Verification integrity and CER capability. Statutory declarations are a floor, not a default. Specify documentary evidence and allow specialist third-party verification and targeted audits. Provide guidance on the “appropriate decision-making body” by tenure and region. 
  8. Suitability (fit-and-proper) alignment. Past cultural heritage contraventions and demonstrated capability to partner with First Nations should inform registration decisions and ongoing participation. 

Consistent with our previous submissions on the GO Scheme (see here and here), the Network’s recommendations above encourage FPIC and self-determination as core components of the GO Scheme’s framework, and they focus on what First Nations communities and buyers need to see: i.e. that consent is current and respected, and with protection of Country and real economic participation. 

These amendments will assist ensure that the GO scheme will signal not only the carbon provenance of electricity, but the quality of relationships with First Nations peoples that make projects possible (built on FPIC and principles of self-determination).

The changes we propose assist to place consent and First Nations community control at the heart of attribute claims, align procurement with Commonwealth expectations, and give the regulator simple tools to keep information accurate over time. 

Read our submission