Does the Granular Registry qualify as an "EAC Issuer" under US Hydrogen 45V rules?

The Granular Registry can satisfy Treasury/IRS § 1.45V-4(d)(2)(v) and therefore qualify as a “qualified EAC registry” for 45 V hydrogen claims, provided that it is operated in the U S., implements a public generator API, and can demonstrate those capabilities to a 45 V qualified verifier. A hydrogen producer could then match every MWh of electricity it uses with a “qualifying EAC” issued by the Granular Registry and retire those certificates inside the same platform.

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1. What does 45 V require from an EAC registry

The proposed 45 V regulations (Fed. Reg. 26 Dec 2023) define a “qualified EAC registry or accounting system” as one that Federal Register.

Requirement	45 V text	Practical meaning for registries
(A) Unique ID	“Assigns a unique identification number to each EAC”	serial-number per MWh
(B) One-to-one	“Enables verification that only one EAC is associated with each unit of electricity”	prevents double issuing
(C) One-time retirement	“Verifies that each EAC is claimed and retired only once”	locking/retirement function
(D) Ownership	“Identifies the owner of each EAC”	account structure, audit log
(E) Public generator view	“Provides a publicly accessible view … of all currently registered generators”	open list or API to stop duplicate registrations

After 1 Jan 2028 a qualifying EAC must also carry an hourly timestamp and fulfil incrementality + deliverability rules (same DOE “region”, new-build or uprate, etc.) Federal Register

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2. How the Granular Registry stacks up

45 V criterion	Evidence from Granular Registry design	Meets?
Unique ID	EnergyTag Standard § 1.4: “GCs shall have a unique identification number, received at issuance and maintained over the full certificate lifetime.” Granular-Certificate-Sc…	✔
One-to-one & one-time retirement	Standard assigns GC Issuer the duty to avoid double issuance and double cancellation; the GC Registry Operator “shall record the Accounts and the Certificates held in them”. Granular-Certificate-Sc…	✔
Ownership	Account-holder model identical to existing North-American EAC systems; owner changes are logged. Granular-Certificate-Sc…	✔
Public generator list	GC Registry White-Paper recommends “public, API-based generator database for duplicate-check & transparency.” GC Registry White Paper…	Mostly (must actually be implemented and exposed)
Hourly data	GCs record “production/storage discharge interval … maximum of one hour”. Granular-Certificate-Sc…	✔
Incrementality / new-build flag	EnergyTag Config-2 & 3 workflows allow COD and uprate data tags; Granular Registry data model already stores COD, fuel, capacity, etc. Granular-Certificate-Sc…	✔
Deliverability (DOE region)	Registry stores GPS or nodal ID; matching engine can filter by DOE regions.	✔ (requires region mapping table)

Gap to close: Treasury insists on (E) public generator disclosure “through an API”. The Granular Registry design anticipates such an API, but will need to:

• expose the generator table (ID, fuel, COD, location, capacity) publicly or via an unauthenticated endpoint;

• document it for verifiers; and

• Keep duplication checks automated.

If that API is launched, the Registry meets every listed element of § 1.45V-4(d)(2)(v). No additional federal “pre-approval” list is foreseen—the hydrogen producer has to demonstrate to its qualified verifier that the registry it used satisfies the five bullets.

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3. Practical implications for hydrogen producers

Item	Impact / action
Hour-matching from 2028	Producers will need hourly (not annual) GCs. Granular Registry’s sub-hour tagging is already compliant.
Incrementality rule (≤36-month COD)	Registry must surface COD metadata so verifiers can filter out non-incremental GCs.
Regional deliverability	Build a lookup that maps each generator’s balancing-authority or NERC region to the DOE 2023 “Transmission Needs Study” regions used by 45 V.
Verification workflow	Add export function so the qualified verifier can pull a signed retirement report (certificate IDs, hour, owner, region) to attach to Form 7210.
Engagement with Treasury/DOE	Publish a technical memo showing how the platform satisfies § 1.45V-4(d)(2)(v) and offer sandbox access to verifiers.

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4. Bottom line

Technically, the Granular Registry already checks every box that § 1.45V-4 sets out for a qualified EAC registry—unique certificate IDs, double-count protection, ownership tracking, hourly data, and (once the public API is live) a transparent generator list.

That means hydrogen producers could retire Granular Certificates within the Registry to meet the power-matching requirements of 45 V, as long as those certificates themselves meet the incrementality, temporal-matching, and regional deliverability tests and a qualified verifier attests to it.