AIB proposes responsibility-driven methodology to link Guarantees of Origin registries with the Union Database

AIB published a technical and policy paper ('Linking Guarantees of Origin and the Union Database – design follows responsibility') proposing a methodology to connect national GO registries with the EU Union Database (UDB), using shared identifiers, a single coordinated cancellation process, and a phased Member State rollout, while accommodating the national database route under Article 31a(5) RED.

The proposal addresses a structural interoperability gap between GO registries (governed nationally under RED Article 19) and the UDB (which records Proof of Sustainability data for renewable gas), aiming to prevent double counting/double claims and support a liquid cross-border market for renewable gas certificates. If adopted, it would shape the IT architecture and governance model underpinning future GO-sustainability tracking integration across the EU.

This is a foundational design intervention at the intersection of GO market infrastructure and sustainability-tracking systems for renewable gas. AIB's 'design follows responsibility' principle signals an attempt to pre-empt a top-down IT architecture imposed by the UDB team or Commission, instead anchoring technical design choices in existing legal competence allocation (Member States for GOs, UDB for PoS). The phased approach and accommodation of the Article 31a(5) national database route suggest sensitivity to heterogeneous Member State implementation capacity, which could affect the pace and uniformity of cross-border market integration for renewable gas GOs. This is an early-stage industry proposal, not yet subject to regulatory endorsement, and its influence will depend on uptake by the European Commission and UDB technical team.

Renewable Energy Directive (RED) Article 19 (GO national supervision); Article 31a(5) RED (national database route for Union Database)

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