The Turnbull government's National Energy Guarantee is "terrifically complex", and its problems will become "more significant" if its emissions reduction goal is increased, according to the first report by the Victorian government's new energy policy hub.

The report by Bruce Mountain,  director of the Victoria Energy Policy Centre, argues thorough economic analysis of the impact of the two arms of the policy - to reduce emissions and to improve reliability - has yet to be done even though state and energy ministers are being asked to approve it by August 10.

The emissions component of the scheme, which obliges retailers to contract with generators according to the carbon pollution associated with the electricity production, is particularly complicated because transactions won't be public but stored instead in a registry.

Mr Mountain said market participants would have buy a combination of electricity volume and emissions intensity without knowing the alternatives, nor penalties if they buy too much or too little.

Unlike current National Electricity Market operations, they would have no access to the range of hedging instruments that help them minimise risk.