As stated in our recent lawnow “'Simplified’ CRC becoming law”, the draft CRC Energy Efficiency Scheme Order 2013 (the “Draft 2013 Order”) is presently making its way through the legislative procedure. It is anticipated that the Parliamentary process will be ended by May 2013, with the law taking effect from June 2013.
Subject to Parliamentary approval of the Draft 2013 Order and revisions to the Allocation Regulations 2012, compliance deadlines for 2013 will be as follows:
- Annual reporting period for year to 31 March 2013 – 3 June 2013 to 31 July 2013
- Application period (ordering of allowances) - 3 June 2013 to 31 July 2013
- Payment period - 2 September 2013 to 20 September 2013
- Allocation period - 2 September 2013 to 15 October 2013
- Surrender of allowances deadline - 31 October 2013
- Start of registration window for Phase 2 – 1 October 2013
Failure to comply with the deadlines may render a participant liable to financial penalties.
Participants should note that whilst the last date to surrender allowances has been extended, importantly the period in which to apply for allowances has not.
Given that the most recent annual reporting year period and the qualification year for Phase 2 has just ended (as at 31 March 2013) energy data should be promptly collated and considered. For organisations with complex organisational structures such as funds and trusts, a strategy for dealing with the proposed changes to the scheme and assessments of Phase 2 qualification should be implemented well in advance of the compliance dates.