Implementing renewable energy policies is a complex governance challenge that involves numerous jurisdictional levels. Transforming an energy system towards renewables requires not only top‐down activities from the central government, but also bottom‐up developments at subnational jurisdictions. This article investigates how complex multi‐level governance arrangements affect renewable energy policy implementation in a developing country. Speaking to current conceptual debates in multi‐level governance research, insights from pluralist power theories are incorporated into a multi‐level governance framework to investigate the role of governance structures, resources and capacities. The approach is applied exemplarily to discuss the implementation of the Philippine Renewable Energy Act. The national government struggles to implement this law due to powerful local authorities. Political factors such as unclear responsibilities, conflicting regulations, weak local capacity, a lack of awareness for national intentions and missing consultation are identified as major obstacles for renewable energy policy implementation. Results are primarily derived from documents and qualitative expert interviews. Copyright © 2017 John Wiley & Sons, Ltd and ERP Environment