Who Owns the REGOs Under a Solar PPA?
Under a solar PPA the REGOs can stay with the provider, pass to you, or be sold on. Why ownership decides your renewable claim, and the clauses to agree.
Signing a solar PPA gets you cheaper power from the array. It does not, on its own, let you call that power renewable. That right travels with the array's certificates, the REGOs, and under a PPA they go wherever the contract sends them. This post covers who can end up holding them and the clauses that decide it.
Why ownership of the REGOs decides your claim
Ofgem issues one REGO for each megawatt-hour of eligible renewable output, and it issues them on an accredited station's gross generation. Its guidance says a station that uses some or all of its output on site is still eligible. For an on-site PPA that means the array on your roof can earn REGOs on every unit, including the units your building consumes.
The GHG Protocol's Scope 2 Guidance then settles who may claim those units. A company consuming power directly from a generation facility that has sold its certificates forfeits the right to claim that generation, and must report those units using a residual mix or replacement certificates instead. If the provider sells your array's REGOs, your market-based renewable claim goes with them.
Sources: Ofgem — REGO Guidance for Generators, Agents and Suppliers, v4.0 (9 March 2026) (3.4, 5.10); GHG Protocol — Scope 2 Guidance (2015), 6.4–6.4.1. Verified 27 Sep 2026.
The three ways a PPA can allocate REGOs
| Arrangement | What happens to the certificates | What you can claim |
|---|---|---|
| Transferred to you, or cancelled in your name | The provider transfers REGOs for the units you buy, or has Ofgem cancel them with your organisation as beneficiary | A market-based renewable claim for those units, with an Ofgem cancellation letter as evidence |
| Kept and sold by the provider | The certificates become revenue for the provider | No renewable claim on those units; the price may be lower to reflect the certificate revenue |
| Split | An agreed share comes to you and the rest is sold | A claim for your share only |
None of these is wrong. The mistake is not knowing which one you have signed.
Clauses to agree before you sign
- Accreditation. Whether the provider will accredit the array for REGOs, and who pays for and maintains the generation metering Ofgem requires.
- Ownership. Who holds the REGOs for the units you buy, and for any exported units.
- Delivery. Transfer to your account, or voluntary cancellation in your name, within the 16-month life of each certificate.
- Evidence. A copy of the Ofgem cancellation letter, or the certificate report from the Register, each reporting year.
- Change in law. What happens if certificate rules move towards time-matching, a change the government and the GHG Protocol are both considering.
- Price. Whether the tariff changes if the certificates come to you rather than being sold.
Off-site deals work differently
On a sleeved PPA the farm's REGOs should pass through the supplier that delivers the power to your meters. On a virtual PPA no power changes hands, so the certificates have to be transferred to you separately. Either way the rule is the same: no certificates, no renewable claim. The full background on how REGOs are issued, redeemed and checked is in our guide to REGO certificates.
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