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Completed verification submissions due Monday, June 2, 2025

 

The Green-e® Energy verification documents for the 2024 Reporting Year (RY) are now available. In addition, all Green-e® Energy participants will receive a separate email with verification platform account and log-in information. Please note:

1. New Interface. For RY2024 verification reporting, you will use a new Salesforce-based web interface. Like our previous verification website, you may enter data through a step-by-step data entry flow or through a bulk upload spreadsheet. Your auditor will then review your data and submit it to CRS through this new website as well.
2. Training and Support. We will host trainings on the new interface and be available for questions and assistance throughout this Spring; details and registration links are further below in this email. Recordings of training are also available now on the new verification website.
3. Access. You should receive a verification access email (which will come from an @salesforce.com email domain) this week. If you wish to have another person in your organization be granted access, please contact us as soon as possible at verification@green-e.org or call +1 (415) 561-2100. The account access emails might be blocked by spam filters, so please check your Junk folder, but we can send you a new set-up email as needed.
4. Instructions and Documents. The Audit Protocol, Getting Started Guide instructions, worksheets and other verification documents are available on the new verification portal and also on the Green-e website’s verification@green-e.org or call +1 (415) 561-2100. Please note that your verification submission can only be submitted to one individual auditor account, meaning if multiple auditor staff are working on your review, they will share an account.
5. Deadline. A completed verification submission is due to CRS via the verification portal by 11:59 PM PDT, June 2, 2025. Failure to submit by this date or failure to submit a complete submission will result in the accrual of late fees as outlined in verification@green-e.org or call +1 (415) 561-2100.

Thank you, and please reach out if you have any questions as you begin entering data and working with your auditors.

 

Reminder of Recent State Policy Updates that Affect Reporting Year 2024

The Oregon Public Utilities Commission adopted an Order (No. 24-002) on January 5, 2024, on issues related to the implementation of HB 2021, the Oregon Clean Energy Targets bill. Beginning with January 1, 2024, generation, RECs associated with electricity generation reported to the Oregon DEQ for compliance with Oregon House Bill 2021 (HB2021) are not eligible for use in a Green-e® certified renewable energy product. For more background on HB2021 please see Market Advisory: Oregon House Bill 2021 and Green-e® Standard Change and Green-e® Energy Certification Program Approach to Oregon's Clean Energy Targets Bill.

Reporting by Oregon retail electricity providers to the Oregon DEQ for compliance with HB2021 is due annually on June 1. CRS staff will work with Oregon DEQ to obtain relevant data reported to DEQ to compare to supply used for Green-e® Energy certified sales. However, because this data will not be publicly available until after Green-e® Energy verification reporting deadlines, CRS reserves the right to notify participants of any ineligible generation identified as a result of HB2021 reporting and require corrective actions by affected Green-e® Energy participants, which may include procurement replacement supply.

Please note that HB2021 affects generation located both in and outside of Oregon, and renewable energy products sold to customers located in and outside of Oregon. For example, if an Oregon utility bought bundled renewable electricity from Washington state and reported that electricity to the Oregon DEQ for compliance with HB2021, the associated Washington RECs would not be eligible under the Green-e® Standard.

In Texas, Compliance Premiums (CPs) were only issued for solar through 12/31/2024 and for non-solar, non-wind facilities, through 12/31/2023. CPs for Texas facilities will only be required to be procured and retired through the dates that they are issued, as listed above. However, if CPs are for some reason issued beyond the dates above, they will be required for Green-e® Energy compliance.

In California, the Voluntary Renewable Energy Program (VREP) set-aside allowances have all been allocated to RY2023 sales. However, the California Air Resources Board (CARB) is requesting feedback on adding millions more allowances to the VREP account. While CARB has not released information on when that allocation would be made, CRS staff will submit comments on the process, stay in close touch with CARB, and alert participants of any updates. We encourage you to engage in CARB’s process as well and submit comments in favor of quickly replenishing VREP allowances. If no allowances are issued for RY2024, CRS will require CITSS allowances per the Green-e® Standard. Please contact us with any questions or to learn more about our plans to engage.

As of June 2023, Virginia is no longer participating in the Regional Greenhouse Gas Initiative (RGGI) cap-and-trade program. This means that Green-e® does not recognize Virginia as a RGGI state. As a result, Virginia RECs can be sold within and outside of RGGI and RECs from RGGI states cannot be sold into Virginia. If Virginia rejoins RGGI in the future, CRS will evaluate the implications for the Green-e® Standard.

Verification Training and Quarterly Participant Calls

Optional Verification Portal Training Calls

• Tuesday, March 27th at 11:00 AM PT. Link to Join. Passcode: 753735
• Tuesday, April 1^st at 10:30 AM PT. Link to Join. Passcode: 166393

CRS will host optional (but recommended) training calls for participants to drop in and ask questions about the new verification portal. Questions might include help logging in, uploading data, communicating with auditors, and submitting verification data to Green-e®, or anything else. These calls are not walkthroughs of the whole system; we are providing recorded trainings for that purpose, so please come with questions.

Please feel free to contact your contract rep or other CRS staff at verification@green-e.org or call +1 (415) 561-2100 if you need any other assistance with the portal.

 

Quarterly Green-e® Participant Call

 

Tuesday, April 8^th at 11:00 AM PT. Link to Join. Passcode: 725601

Please join us for a Zoom meeting for updates on the Green-e® Energy program, followed by a chance to engage with Green-e® program staff and to bring up any ideas for consideration by staff and the Green-e® Governance Board. This optional participants call is one way we solicit participant feedback that may be translated into Governance Board discussion. All Green-e® Energy program participants are welcome and encouraged to attend. Among the topics we will be covering are:

• Verification Portal Updates
• New Advisory Committee Chairs representing Green-e® participants on Green-e® Governance Board calls
• Market Updates
• Opportunities for participants to provide feedback

Thank you, and we look forward to meeting with you!

 

Verification Timeline Summary

Below is only a summary of the major deadlines. A complete timeline is posted on the new verification website, the Green-e website, and at: Reporting Year 2024 Annual Verification Submission Timeline and Deadlines

Monday, March 24, 2025
Last day to submit repowering or co-firing applications for facilities you wish to use toward RY2024 certified sales. Green‑e® Energy Repowering Worksheet application forms are available on the Green-e® Energy Participant Portal.

Friday, May 2, 2025
Last day to request an extension to the June 2, 2025, verification submission deadline. CRS staff will make every reasonable effort to respond to extension requests within 3 business days.

You must prove the need for an extension. See the full Timeline for details. The maximum extension is until Wednesday, July 2, 2025, though shorter extensions may be granted. Extensions will require that your Auditor perform and report on an additional audit step of checking that renewable MWh purchases were delivered to you by June 2, 2025.

If you exceed the deadline granted in your extension, the per-day late fees described below will apply for a period of up to 30 calendar days. If at the end of 30 calendar days you have not submitted your Verification Submission, you will be subject to the actions outlined in “Wednesday, July 2, 2025” below.

Monday, June 2, 2025
Verification submission deadline. All verification data, the Auditor's Agreed-Upon Procedures Report, all Attestations, all available Tracking System Reports, and all other required materials must be submitted by 11:59 pm PT. All supply must be finalized, delivered to you, documented through attestations/tracking system reports, and audited by this date; see Appendix B of the Green-e® Energy Getting Started Guide RY2024 for required documents.

Electronic submittal of all documents is required through the online verification platform. If a specific extension or separate deadline has been provided by CRS staff, refer to the related section of this document or communication from CRS staff on the matter.
For Tracking Systems that will not have certain Tracking System Reports available by June 2, 2025, such as NEPOOL-GIS and PJM-GATS, see the full Timeline for instructions.

If Verification Materials are Provided to CRS Late: If you have not submitted all required verification materials by 11:59pm PDT, the name of your company and the product(s) for which verification materials have not been submitted will be posted on the Green-e® website. You will be sent a letter notifying you of your product(s) being out of compliance in accordance with your contract for Green-e® Energy certification.
Your Auditor will perform and report on an additional audit step of checking that all renewable MWh purchases were delivered to you by June 2, 2025. The Agreed-Upon Procedures report will not be accepted after June 2, 2025, without this step being performed and documented.

Additionally, starting at 12:00 am PT on June 3, 2025, late fees (detailed below) will begin to accrue, accumulating at the assigned rate per business day that the Verification Submission is not submitted. Failure to pay late fees on time will be noted on the Green-e® website, and you will be re-listed as out of compliance with verification requirements until your payment has been received. If payment is not received within 30 days of the issuance of the invoice you will be considered in breach of contract with CRS as of that date. Remaining in breach of contract for 30 calendar days will result in decertification for all certified products for which late fees have not been received.

Late Fee Schedule. If a Participant misses the deadline for submission of verification materials, Participant will be charged late fees for submission of their annual verification materials after the deadline, as set forth in the table below. Late fees are capped at 3.5 times the amount of Green-e® certification fees invoiced for the product(s) at issue in 2024.

Business Days Late, up to 30 calendar days late, applies to all products (except Green-e® Marketplace Participants)	Base Late Fee, per Business Day	Per MWh or Ton Late Fee, per Business Day
Each business day	$200	$0.0008

 

Wednesday, July 2, 2025
Absolute last day for your Verification Submission to be submitted to Green-e® Energy, by 11:59 pm PT, if you have not been approved for an extension. Submitting later than 11:59 pm PT on the extension deadline will cause late fees to accrue as described above for 30 calendar days, after which the product may be decertified.

Green-e® Energy certified products for which Verification Submissions have not been received and that have not been granted an extension are immediately decertified. If your product(s) is decertified, you are still contractually obligated to complete all verification requirements for Reporting Year 2024 and for any Green-e® Energy certified sales made in 2025 up to the date of decertification. In the case of decertification, CRS retains the right to seek remedies including those described in the Green-e® Energy Code of Conduct and Customer Disclosure Requirements (“Code of Conduct”) (e.g., notifying customers, state Attorneys General, the Better Business Bureau, and other legal action). You will not be authorized to offer any new Green-e® Energy certified product starting on the date of decertification for a period of at least 12 months, unless you obtain approval from the Green-e® Governance Board. See Section V of the Code of Conduct.

Friday, August 1, 2025
Absolute last day that participants that received 30-day extensions may submit their Verification Submission to Green-e® Energy without product decertification. Not all extension requests will be granted a 30-day extension. Late fees will accrue for every business day passed from the submission deadline to this date.

Fall 2025
CRS may send a notice to all stakeholders including a listing all products decertified for failure to submit verification materials, and the corresponding sellers. CRS reserves the right to communicate decertification through other channels and to other parties at its sole discretion.

Extensions and Decertifications
The Green-e® Energy Verified Auditors listed on the Green-e® website have performed at least one complete and satisfactory Green-e® Energy audit in the past and wish to be listed there. They may not be able to take on new participants late in the process, given the workload. We advise you to retain an auditor early and begin compiling and sharing the necessary documents with them as soon as possible.

If you anticipate needing an extension, please request one as early as possible, and have a way to substantiate your need. Reasons that extensions may be granted include:

 

• Natural disasters / acts of God
• Death or serious illness of key personnel or lead audit staff
• Verification portal errors / bugs beyond your control that CRS staff have determined prevent completion of verification
• A dispute about a supply contract that is beyond your control where you can demonstrate to CRS staff that you have taken all possible steps to procure the supply prior to verification deadlines

Reasons that extensions will NOT be granted include, but are not limited to:

• Late retention of auditor
• Inadequate staff resources dedicated to completing verification
• Your auditor is too busy as the deadline approaches
• A large amount of supply or number of sales
• A request to CRS staff for repowering, co-firing or an exception to Green-e® Energy rules has been made but a final response has not been provided

If your product(s) is decertified (whether voluntarily or due to a contract enforcement action), you are still contractually obligated to complete all verification requirements for RY2024 and for any Green-e® Energy certified sales made in 2025 up to the time of decertification. You will no longer be authorized to offer a Green-e® Energy certified product starting on the date of decertification. The Code of Conduct details additional actions CRS may take in the event of non-compliance with verification requirements. In the event of the decertification of your product(s) due to non-compliance with verification rules, CRS will follow the procedures described in the Code of Conduct, which includes, at CRS's option, notifying applicable regulators, consumer advocacy groups and other stakeholders.

Participant verification performance is tracked year-on-year (such as late submission) and CRS staff may make this information available to the public.