17 Days and counting …

United Kingdom
14/01/2014
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The registration window for the Initial Phase (formerly known as Phase 2 ) of the CRC Energy Efficiency Scheme (the CRC) will close on 31 January 2014. Failure to register when required to do so exposes organisations to potential sanctions including monetary penalties and publication of non compliance. Those who are unsure as to whether they need to register should seek urgent advice.

Initial Phase CRC Qualification

Organisations qualify if the following criteria applied to the group as a whole between 1 April 2012 and 31 March 2013:-

(a) it had at least one settled half hourly electricity meter and

(b) at least 6000 megawatt hours (MWh) or more of qualifying electricity was supplied to it on the settled half hourly market.

The relevant group for qualification purposes is that which existed as at 31 March 2013.

All organisations should review their group structure as at 31 March 2013 and determine whether the relevant qualification thresholds are met.

Consider ‘disaggregation’ when registering

Any part of a participant group other than the highest UK parent undertaking may disaggregate and register as a separate participant provided the parent and the relevant subsidiaries agree. Subsidiaries may disaggregate either as a group or individually. Each disaggregated subsidiary and the remaining organisation must continue to be part of the CRC.

Trusts and Private Equity – potential for separate registration

Those involved in trusts and funds should consider whether their arrangements would benefit from either disaggregation or, where feasible, separate registration along trust lines. Due to changes since Phase 1 registration, in certain circumstances trustees and/or regulated operators may register as a separate participant in respect of relevant trusts. This may prove attractive to some trustees and fund managers as a transparent solution to an artificial compliance situation and could assist with costs recovery.

Click here to view the existing CRC Guidance entitled “Assessing Qualification and Registering for Phase 2” dated May 2013

Click here to view the CRC Energy Efficiency Scheme Order 2013

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