(1) The new white certificate mechanism applies to projects submitted after April 4, 2017, with a 180-day transition period allowing some projects under the old mechanism to still qualify. (2) Projects must create additional energy savings, fall under eligible categories, and follow submission and documentation rules to qualify for white certificates. (3) Savings are assessed using either the final balance method requiring before-and-after monitoring, or standard methods using approved models; in both cases prior consumption must be monitored for 12 months. (4) Requests for verification of savings must be submitted within 120 days of the monitoring period end and are evaluated by the energy authority within 90 days.

1. Hogan Lovells
New Guidelines on White Certificates – Summary of the key points
Effective date and
transitional regime
The new mechanism applies to all projects submitted starting from 4 April 2017 (date of entry into force of the DM).
Projects approved or submitted before such date are regulated by the old mechanism.
The DM also sets forth a 180 days transition period during which the former mechanism may apply to specific projects
at a certain (advanced) stage of completion.
Art 16
Entities
A distinction is made between applicant and holder.
The applicant: (i) must meet (for the entire useful life of the project – so called "U" factor, see below) the requirements
provided for under art. 5; (ii) is the entity who can submit the request to the public authority ("GSE") to obtain the white
certificates (with proxy from the holder if applicant and holder are not the same entity).
The holder: (i) is the entity who makes the investment; (ii) is the entity in whose name white certificates are awarded by
GSE; (iii) may apply for white certificates also in the name of the applicant (in such case the model contract shall be
signed by both of them, and they are jointly liable).
The contractual relationship between GSE and the holder (+ the applicant, if holder and applicant are not the same
entity) is regulated by a model contract (see "model contract" box below).
Artt 2
and 5
Projects eligible for
white certificates
scheme
In order to be eligible for the white certificate scheme, projects shall:
(i) create additional savings (as proven by suitable documentation);
(ii) be implemented by the same holder, at one or more facilities;
(iii) their starting date shall follow the submission of the request to access the mechanism with GSE;
(iv) fall within the scope of the works listed in Table 1, Annex 2 of the DM;
(v) be drafted and filed with GSE pursuant to Annex 1, along with the documents specified in Annex 1.4;
(vi) their starting date shall follow the date of submission of the application for white certificates (but shall fall within
12 months from the date of approval of the PC projects – see below).
Art. 2;
Annex 2

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Hogan Lovells
Methods for
assessment of the
projects
Two methods:
- final balance method ("PC", "progetto a consuntivo"): additional savings are measured both before and after the
intervention works. For such projects: (i) a share of additional savings not less than 10 TEP in the first 12 months of
monitoring is required; (ii) the project starting date must fall within the first 12 months from the date of approval of the
PC; (iii) specific rules are set forth to determine baseline consumption (see box –baseline);
- standard method ("PS", "progetto standardizzato"): (i) a share of additional savings not less than 5 TEP in the first
12 months of monitoring is required; (ii) PS are allowed for a specific kind of interventions whose list is still under
approval by the Ministry (but new types of projects may be submitted for evaluation by the public authority); (iii) savings
are measured in compliance with a model and a measurement program approved by GSE; (iv) as to the baseline: see
box – baseline.
Art. 9;
Annex 1-
points 1
and 2
Request for verification
and certification of
savings
Requests for verification and certification of savings with either the final balance method ("RC", "richiesta a consuntivo")
or the standard method ("RS", "richiesta standardizzata"): (i) must be submitted within 120 days from the end of the
monitoring period and must refer to a one-year monitoring period (shorter monitoring periods are admitted only for
projects with high savings, and upon GSE approval); (ii) are evaluated by GSE within 90 days from the application
(save for requests for supplements).
Art. 7;
Annex 1
Procedure
GSE has a 90-days period to evaluate the project (save for any supplements).
The former silent-approval procedure is no longer envisaged.
Art. 7
Baseline
Both in the PC and in the PS, the prior consumption monitoring shall be carried out in the 12 months before
implementation of the project, with daily tests (unless the applicant proves that lower frequency and duration of tests
are in any event sufficiently representative to calculate the baseline)
Art. 2;
Annex 1
Model Contract
The DM introduces the model contract to regulate the contractual relationship between GSE and holder (and between
GSE, holder and applicant, if holder and applicant are not the same entity).
The draft model contract will be approved with decree of the Ministry for the Economic Development in the 30 days
following DM entry into force.
Artt 2
and 5

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Tau Factor The DM removes the Tau factor and introduces the (less favourable) K factor. Annex 2
Useful Life (U) It is predetermined depending on the type of intervention. It cannot in any event exceed 10 years. Annex 2
Renewable energies
Only renewable energies for "non-electric" use will continue to benefit from the white certificate mechanism, upon
condition that they create additional savings.
Art. 6
Combination with other
incentives
The DM allows combination of white certificates with other non-state incentives destined to the same projects (within
the limits set forth by European regulations).
Art 10
Verification and control
activities
GSE monitors the interventions through document assessment or on-site inspections; it may carry out such activities
during the entire useful life of the project. The term for completion of the control procedure is set in 180 days; the
inspection shall be notified with at least a prior 2 weeks' notice; holder and applicant are entitled to submit written briefs
and documents.
If any non-compliance is found, GSE may apply the following sanctions: rejection of the application for white
certificates; revocation of the white certificates obtained; recovery of the amounts already granted. If GSE finds any
non-compliance affecting the calculation of incentives, it may re-determine the number of certificates, revoke the
certificates granted in excess or their monetary equivalent (these calculations may be carried out also on a purely
conservative basis).
Art 12
Decisions and decrees
to be adopted
Operational guidelines (within 60 days from the DM); list of model interventions for the PS; draft of model contract
(within 30 days from the DM); FAQ.
Art. 5, 9
and 15