Frequently Asked Questions – CertifHy EU Voluntary Scheme
Find clear answers to the most common questions about the CertifHy EU Voluntary Scheme, covering both the RFNBO scope (renewable hydrogen and e-fuels) and the Low-Carbon scope (low-carbon hydrogen and derivatives).
Whether you are exploring certification requirements, precertification, the audit process, Proofs of Sustainability (PoS), or the differences between the two scopes, this FAQ provides practical guidance aligned with the Renewable Energy Directive (RED II) and its associated Delegated Acts.
General Questions
A certification scheme operator such as CertifHy develops, maintains, administers and operates certification schemes that enable Economic Operators to demonstrate compliance with the requirements from the Renewable Energy Directive (RED). Demonstrating compliance with RED requirements is a prerequisite for RFNBOs to be counted towards Member State targets and to benefit from financial support mechanisms and other regulatory incentives implemented at national level to promote the uptake of renewable fuels. Certification schemes must be formally recognized by the European Commission for their defined scope of certification. The RFNBO scope of the CertifHy EU Voluntary Scheme was recognized by the European Commission in December 2024.
In comparison, a Certification Body is an independent, accredited organisation that audits fuel producers to verify their compliance with the requirements of a certification scheme. It issues certificates to companies confirming the renewable or low-carbon nature of the fuel produced. It acts as a trusted third party, providing credibility to producers, buyers, and regulators.
Precertification
Precertification is available to projects in pre-FEED or FEED. Projects below pre-FEED maturity are generally not eligible, though CertifHy may assess them on a case-by-case basis.
In practice, precertification is most effective as soon as key compliance-relevant design and commercial choices are sufficiently defined – such as the PPA strategy, metering and data model, mass balance boundaries, preliminary GHG model, and the evidence plan for correlation and “no double support.” Starting too early often results in many elements remaining “to be confirmed,” while starting too late (e.g., after EPC award) can reduce flexibility and increase cost/schedule impacts.
In a precertification exercise, the auditor performs the critical review and remains neutral.
Expert consultants can support the project developer throughout the process and prepares a comprehensive Precertification Report that goes beyond the auditor’s factual observations. In which case direct exchanges between the auditor and the project developer are not required; dialogue may occur via the consultant as intermediary.
Accordingly, the consultant and the auditor cannot be the same person or from the same organization. CertifHy supports the process by addressing technical questions and by reviewing and validating the final Precertification Report prepared by the consultant.
Precertification typically delivers (i) an Audit Report prepared by the auditor, (ii) the completed Auditor’s Checklist, and (iii) a Precertification Report prepared by the consultant. The Audit Report and Checklist capture the evidence reviewed, factual observations, control status, and items to be confirmed at certification stage.
The Precertification Report translates these findings into practical recommendations to de-risk the project ahead of commissioning and/or Final Investment Decision (FID). It can cover electricity sourcing compliance (including relevant PPA clauses), “no double support” checks, mass balance boundaries, and the GHG approach (e.g., system boundaries, by-product treatment, and conservative assumptions where needed). It typically concludes with a clear action plan, residual risks, and a baseline package that can be carried into the initial certification audit.
From a project development perspective, precertification is designed to increase maturity by clarifying what data, contracts, permits, and operational plans must be in place for RFNBO certification – and it can be used to provide stakeholders and investors with additional confidence in the project’s compliance readiness.
Precertification is for Economic Operators who wish to assess the compliance of their site or project before it is operational. It is conducted by a cooperating Certification Body (CB) as a desk-based assessment against the CertifHy EU Voluntary Scheme requirements. The objective is to evaluate whether the planned design and operational concept are aligned with the scheme requirements and identify any potential gaps at an early stage. The Economic Operator is required to provide documentation including process flow diagrams, plant design documentation, electricity sourcing strategy and contract structures, preliminary GHG calculation approach, operational and data management plans. Precertification is generally carried out pre-FEED or FEED phase. It is a key risk-mitigation tool, avoiding costly redesign or contractual restructuring at later stages. Pre-certification does not result in a certificate and does not allow issuance of Proofs of Sustainability (PoS). Its deliverables typically include a structured gap analysis and compliance readiness assessment.
Certification is the initial certification audit required before participation in the CertifHy EU Voluntary Scheme. Certification is based on actual operational data and, for a new operator or under a revised regulatory framework, conducted on‑site; claims cannot be made before the plant is fully constructed and operational. After a positive decision, the CB issues the certificate (normally within 60 days of the audit, accounting for corrective actions if needed). The certificate is valid for one year. Once certified, operators may issue Proofs of Sustainability for compliant production volumes.
Recertification is required to renew a certificate before it expires (validity is one year). It follows the risk‑based approach set out in the scheme; if the regulatory framework changed, the re‑certification audit must be on‑site. A desk-based audit is usually sufficient (unless major changes in set up or in case of major or critical non-conformities). If an operator changes CBs, the new CB must obtain and consider the previous audit documents; higher risk levels may be applied in certain cases once a site is operational to be able to issue PoS.
Certification
Step 1 – Registration & KYC (~ up to 10 business days):
Economic Operators register via CertifHy’s website and complete the Know-Your-Customer (KYC) verification process.
Operators will be required to submit key business and facility information, including:
- Legal entity details
- Site location
- Certification scope
- Prior experience with Certification Bodies (CB) and/or other Voluntary Schemes
- Supporting corporate and operational documentation
The timeline depends on the completeness and accuracy of the information submitted.
Step 2 – Pre-audit preparation (typically a few weeks):
Following successful KYC validation, operators select a recognized Certification Body (CB) and agree on an audit date. The dedicated auditor will usually request documentation in advance to prepare for the initial on-site audit. The duration of this phase depends on the readiness of documentation and CB availability.
Step 3a – Initial certification audit (on-site, ~1-2 days):
The on-site audit is coordinated between the Economic Operator and the CB and typically lasts one or two days, depending on the CB’s availability and the complexity of the installation. During the audit, the operator must demonstrate compliance with RFNBO requirements.
Step 3b – Recertification audit (before certificate expiry; ~1-2 days):
Re-certification must occur before the current certificate expires (typically 12 months, although shorter validity period may apply depending on initial audit findings).
Operators must report any material operational change affecting compliance. Advance planning is recommended due to potential CB scheduling constraints.
Step 4 – Audit reporting (~3-4 weeks after audit):
The audit report is generally completed within a few weeks of the on-site audit. If major or critical non-conformities are identified, corrective action must be implemented and verified which may extend the timeline. The report documents finding, corrective actions, and compliance status.
Step 5 – Certificate issuance (immediate after report; max 60 days post-audit):
Once the report is finalized and approved, the certificate is issued. This typically occurs promptly and, in any case, within 60 days of the audit.
Issued certificates are published on CertifHy’s website.
Please refer to our price list, and/or speak to a member of our team.
Certification under EU Voluntary Schemes is generally granted on the basis of operational data: a facility should be actively producing hydrogen for a certificate to reflect actual, verified compliance with applicable technical and regulatory requirements.
That said, initial certification may take place before a facility begins operations. Once the project design, documentation, and monitoring systems have been reviewed and validated by an accredited certification body under a recognized EU Voluntary Scheme, a certificate can be issued ahead of the first production run. This allows hydrogen to be sold as RFNBO- or low-carbon-compliant from day one, on the condition that all elements verified during the pre-operation audit remain in place and that operational data subsequently collected continues to confirm compliance. After this initial certification, the facility is subject to regular re-certification audits to ensure ongoing conformity. Project developers are advised to contact their Scheme Operator and Certification Body to confirm the procedure and timeline.
This approach provides developers with regulatory certainty and immediate market access at the start of operations, while maintaining the integrity of the certification through continuous compliance monitoring.
A CertifHy EU Voluntary Scheme certificate is issued to a facility following a successful audit by a recognized Certification Body. It confirms that a facility complies with the applicable scheme requirements (e.g., sustainability criteria, GHG emissions rules, and traceability requirements) for a defined validity period, typically 12 months. The certificate applies to the facility, not to individual fuel consignments.
By contrast, a Proof of Sustainability (PoS) is issued by a certified Economic Operator for a specific consignment of RFNBO or low-carbon hydrogen produced by the certified facility. The PoS serves as the traceability document that accompanies the RFNBO or low-carbon hydrogen along the supply chain and carries the relevant sustainability and GHG characteristics for that consignment.
Yes. All Economic Operators who own the hydrogen (or hydrogen derivatives) at any point in the value chain — including traders and storage operators — must be certified under the CertifHy EU Voluntary Scheme (in the relevant RFNBO or Low-Carbon scope).
Key clarification: Pure service providers such as transporters or storage facilities that do not take ownership of the molecule (i.e., they only provide logistics or warehousing services without owning the product) are generally not required to hold their own certification. However, they must supply the necessary data and evidence (e.g., on emissions, traceability, or mass balance) to the certified Economic Operators they work with.
The only full exception is the final end consumer, who does not need to be certified.
A Proof of Sustainability (PoS) is issued for each delivery of RFNBO or low-carbon hydrogen volumes and serves as the document transferring the associated sustainability and GHG characteristics along the supply chain. It is always linked to a specific consignment. Correct PoS issuance relies on a compliant mass balance system, which enables tracking and attribution of characteristics.
Before issuing a PoS, the Economic Operator must verify the site’s mass balance to confirm sufficient RFNBO-eligible or low-carbon-eligible stock with the corresponding characteristics. Where renewable and non-renewable products are co-produced, allocation must follow the applicable bookkeeping rules. Where deliveries are continuous (e.g., by pipeline), consignments are typically consolidated over a defined accounting period (often monthly), once the delivered volume and product characteristics can be reliably determined. Commercial contracts should reflect this approach.
GHG emissions and sustainability requirements
The default rule set out in CDR 2023/1185 is straightforward: when a fuel is a mix of RFNBOs, recycled carbon fuels (RCF) and other fuels, all fuel types shall be considered to have the same emission intensity. This means that, in standard production, a single GHG intensity value (in gCO2eq/MJ) applies to the entire output, regardless of the origin of the hydrogen inputs. No differentiation between fuel streams is performed. This emission intensity may be calculated as an average over a period of up to one calendar month.
The only permitted exception to the standard rule is co-processing, i.e. when RFNBO and/or low-carbon hydrogen only partially replaces a conventional fossil or biomass input in the production process. In that specific case, a virtual plant split is allowed on a proportional basis of the energetic value of relevant energy inputs, distinguishing between:
- The part of the process based on the conventional fossil input (or biomass), and
- The part of the process based on RFNBOs and/or low-carbon fuels, assuming both process parts are otherwise identical.
The RFNBO/LCF share of the output is then determined by dividing the relevant RFNBO/LCF energy input (LHV of the hydrogen entering the molecular structure of the fuel) by the total relevant energy inputs.
However, this virtual split only separates the “clean” inputs from the “conventional” inputs. The CDR rules do not allow any further splitting within the clean part between RFNBO and low-carbon hydrogen. As a consequence:
- All co-produced RFNBO and low-carbon fuel (LCF) outputs from the same batch will carry the same GHG emission intensity per MJ.
- It is not possible to assign a lower GHG intensity to the RFNBO portion and a different one to the LCF portion of the output.
In practice, when both RFNBO and low-carbon hydrogen are used together to produce e-fuels, the overall GHG intensity of the clean output is calculated as a weighted average reflecting all relevant inputs, and this single value applies uniformly to both the RFNBO-attributed and the LCF-attributed shares of the output.
No. A consignment is a defined quantity of product with uniform characteristics, including a single set of sustainability and emissions attributes.
As a general principle, producers should request Guarantees of Origin (GOs) in all cases to help avoid double counting. However, country-specific rules may restrict the ability to cancel GOs in support of RFNBO production. In such cases, certification may still be possible.
Low-carbon hydrogen certification
CertifHy has been developing a Low-Carbon Scheme since September 2025, aligned with the EU Low-Carbon Fuels Delegated Act. This work is supported by the CertifHy Technical Committee and follows CertifHy governance procedures, including consultation with Working Group 1 and validation by the CertifHy Steering Committee.
CertifHy is aiming to submit a first draft to the European Commission in Q1 2026, initiating an iterative feedback process. The objective is to obtain official EC recognition by mid-2026 and make the scheme available to market participants as soon as possible thereafter. In the future, Economic Operators will be able to obtain both RFNBO and low-carbon certifications to differentiate their products.
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