In 2018 the Netherlands adopted an amendment for the implementation of Full Disclosure. For a number of reasons, the implementation of Full Disclosure will now be postponed to the 1st of January 2020.
Reasons for the delay include providing market players with enough time to comply with the new legislation, and avoiding the challenges that would have been caused by an implementation date that came halfway through a calendar year. As of 1 January 2019, transitional arrangements for the move to full disclosure have been implemented. These allow for voluntary use of the full disclosure system – making it possible for energy suppliers to prove the whole of their electricity mix, be it green or grey, with attribute tracking certificates. ‘Grey’ certificates will be issued by CertiQ on the basis of voluntary requests.
Specifically, the reasons for the delay are (1) the need to technically adapt the amendment to bring it in line with EU regulations and (2) a separate regulation is required for the implementation to be organized on the basis of the recast EU Renewable Energy Directive. The technical change concerns making it possible for Dutch suppliers to use foreign grey certificates to cover their electricity supply, which has not been accounted for in the current version of the amendment. It is against EU regulations to disallow the import of foreign certificates from EU, EEA and EFTA countries. Furthermore, separate regulation needs to come into place in order to have the amendment transposed into secondary legislation.
Market players need to be sufficiently informed and practical requirements from market players need to be taken into consideration. The aim is to publish the new regulation halfway through 2019, providing ample time for a smooth transition towards full implementation on 1 January 2020.