In Germany, subsidised electricity under the EEG often cannot be backed by GoOs/HKN. Does ISCC accept this in an RFNBO audit?

Yes – EEG (Erneuerbare-Energien-Gesetz)-subsidised electricity can, in principle, be used and counted for RFNBO purposes once fed into the public grid. However, the renewable origin still must be evidenced to the auditor through a Power Purchase Agreement (PPA). Because Art. 80(2) EEG prevents transferring of HKN( Herkunftsnachweis or guarantees of origin) for subsidised volumes, ISCC audits accept an alternative verification package (PPA/contract, along with plant identification, and EEG-support evidence) subject to case-by-case auditor/Certification Body acceptance.