The Philippines renewables market has become one of the most talked about and active energy markets in the region. With a sophisticated liberal energy market, reductions in foreign investment restrictions, strong leadership from the top down and a vibrant number of options for routes to market, we summarise below some recent positive regulatory changes with respect to Round 4 of the Green Energy Auction Program.

Creation of GEA-All Fund and revised REPA

On 16 March 2025 the Energy Regulatory Commission (ERC) issued Resolution No. 6, Series of 2025, which provides guidelines establishing the framework for the collection and disbursement of the Green Energy Auction Allowance (GEA-All) Fund. The main purpose of Resolution 6 is to establish guidelines for the collection and disbursement of the GEA-All Fund separate from the Feed-In-Tariff Allowance (FIT-All) Fund. The GEA-All Fund is allocated for the payment of Actual GET Revenue to developers. The GEA-All Fund effectively operates in the same way as the FIT-All Fund.

The resolution also includes the ERC-prescribed template for the Renewable Energy Payment Agreement (REPA) that applies to all projects awarded capacity under the Green Energy Auction Program (GEAP), which have not yet executed a REPA. All developers of renewable energy plants awarded projects through a GEAP auction round will be entitled to payment of the Actual GET Revenue from the commercial operation date of their projects under the terms of the REPA. The REPA serves as the standard contract between TransCo, as the GEA-All Fund Administrator, and developers.

The new template REPA is consistent with the REPA used for the FIT scheme, with minor updates from the form of REPA originally proposed for the GEAP. 

The new template REPA now opens the possibility for the involvement of the Philippine Dispute Resolution Center, Inc (PDRCI). However, PDRCI arbitration is subject to the ERC’s determination of whether the issue is susceptible of arbitration. If the parties do not agree to arbitration or the ERC finds that the dispute is not susceptible of arbitration, the ERC shall resolve the dispute under its broad quasi-judicial power to exercise original and exclusive jurisdiction over all cases involving disputes between and among participants in the energy sector. The results of the arbitration shall be final and binding to the parties, but exceptions may be carved out by using one of the grounds to correct or vacate the award under the Alternative Dispute Resolution (ADR) Act, and the Special ADR Rules.

A key issue for developers is the funding of the GEA-All Fund. We understand that the GEA-All Fund will commence with a zero balance and it is possible that there may be a delay before the GEA-All Fund has sufficient funds to meet payments to those developers who are already delivering electricity under the GEA. 

GEA-4

The Department of Energy (DOE) launched the fourth round of the Green Energy Auction (GEA-4) on 12 March 2025. GEA-4 aims to add 9,378 MW of new capacity from ground-mounted solar, roof-mounted solar, floating solar, onshore wind projects and integrated solar and energy storage systems (ESS). GEA-4’s capacity targets are specified by technology type, location and year (see Appendix 1).

The ERC is yet to publish the Green Energy Auction Reserve (GEAR) Price, which is the ceiling price for bids.

GEAP guidelines

The DOE published Department Circular (DC) No. DC2025-03-004 in March 2025, which introduces updated GEAP guidelines, aimed at clarifying the qualifications of eligible suppliers and ensuring fair pricing mechanisms for projects under the GEA. Under the new guidelines, qualified suppliers must either hold a renewable energy service contract or possess a Certificate of Authority (COA) issued under the Revised Omnibus RE Guidelines.

Like previous GEA rounds, the supply period is 20 years. Payment of the Green Energy Tariff (GET) commences after:

1. The commencement of the applicable delivery commitment year (see Appendix 1);
2. The project obtains the Certificate of Compliance (COC) or Provisional Authority to Operate (PAO) from the ERC; and
3. Notice has been given to the Wholesale Electricity Market (WESM) that such commercial operations have been achieved.

Like previous GEA rounds, winning bidders will lose their eligibility for the GET if the commercial operation date occurs more than one year after the delivery commitment date (DCD) specified within their bids and their performance bonds will be drawn in full. On the point of performance bonds, a positive development in the terms of reference for GEA 4 is the reduction of performance bond amounts from 20% of capex in GEA 2 to 5% in rounds 3 and 4.

If a winning bidder does not give notice of the GET availment, it shall be paid for the actual energy generated and delivered in accordance with the WESM Rules until the later of DCD or the commercial operation date. This could potentially enable developers to earn additional early revenues from the WESM if they are able to connect early.

Winning bidders are required to post performance bonds to secure completion of the project. Like GEA-3, performance bonds are 5% of the cost of the project, down from 20% in previous GEAP rounds.

Encouragingly, for the first time, in the green energy auction program, the Terms of Reference for GEA-4 states that the GET for GEA projects will be subject to indexation, this is a welcome development since the earlier Feed-in-Tariff (FIT) rules did include indexation and is a reflection of the Department of Energy’s active engagement with market participants. 

GEA-5

GEA-5 is expected to be launched in the third quarter of 2025 and will call for offshore wind capacity.