Sweden is consulting on a new Guarantees of Origin framework for electricity. Planned entry into force is 1 January 2026, subject to adoption. Consultation on the ordinance is open until 22 September 2025.
Why this is inconsistent with REDIII
Our primary concern is that the ordinance introduces a 50 kW minimum capacity for GO eligibility.
REDIII, specifically Article 19 (see also the supporting summaries from the AIB) allows Member States to set a minimum capacity, but it also requires simplified registration and reduced registration fees for installations below 50 kW and for renewable energy communities. Excluding sub-50 kW units makes it quite literally impossible to simplify participation for them, unless simplified participation and reduced fees means no participation whatsoever - which is blatantly inconsistent with the Directive's requirement.
IEA data shows that 91% of PV systems were under under 20 kW, while only 23,265 were in the 20 kW–1 MW range, and just 99 exceeded 1 MW. This means that small-scale PV dominates Sweden's rooftop segment, so a 50 kW floor would primarily hit actors where GO market revenue is most needed, and reduce market access for the producers that policy should aim to empower. This simply isn't the makings of a just energy transition, and it feels deeply unintuitive.
Soldera's position
Soldera exists to keep GO markets accessible, fair, and high performing so producers capture the best prices. Business case aside, it's in our DNA to support producers - we got into this industry to accelerate the energy transition with efficient and fair certificate markets.
Therefore, we strongly condemn the 50 kW exclusion and the fee design as drafted because they reduce access for the smallest producers and undermine market fairness.
We urge that Sweden do not exclude sub-50 kW production andmake participation truly light-touch. Keep micro and small producers in the GO system with simplified onboarding and proportionate costs, rather than excluding them outright. This aligns with the REDIII's obligation to reduce barriers for sub-50 kW and for energy communities.
How to submit views to the consultation
Ordinance consultation is open until 22 September 2025. Email your response to the Ministry of Climate and Enterprise registry at kn.registrator@regeringskansliet.se, referencing the ordinance consultation title in the subject line. Ministry contact formats are listed on the Government's site and the remiss page is here.
Bottom line: The weakest players in the GO market should not be forced out by misguided and contrarian regulatory pursuits. The 50 kW floor and minimal fee relief are not standard, they are inconsistent with REDIII, and make Sweden's GO market less accessible.
