The summer of 2025 was marked by a series of legislative changes in the field of electricity, initiated by the National Energy Regulatory Authority (ANRE). Two recent orders, Order no. 20/2025, applicable as of June 1, 2025, and Order no. 27/2025, which entered into force on July 2, 2025, introduce new rules both regarding the connection of users to the electrical grid and the obligations related to the acquisition of green certificates.
These two normative acts address practical needs: on the one hand, the necessity to ensure rigorous and efficient management of the grid connection process in the context of the surge in renewable projects, and on the other, the alignment of the green certificate mechanism with the new technological reality, where energy storage has become an active player in the market.
I. Order no. 20/2025 introduces changes to the grid connection procedure
The entry into force of ANRE Order no. 20/2025 on June 1, 2025 brings a set of rules explicitly aimed at eliminating speculative projects, prioritizing real investments, and protecting the capacity and security of the national electricity grid.
- The fundamental novelty is the introduction of the concept of “operational limitation”. This becomes an integral part of the technical connection approval (“ATR”), allowing the grid operator to temporarily restrict power evacuation under certain operating conditions to maintain system safety.
- On the other hand, a project prioritization procedure has been introduced for the preparation of solution studies, under which only complete files that meet documentation requirements are included on the analysis list. Priority is determined according to the registration date of the request, and each project is evaluated in the context of the local grid, together with those already authorized or in an advanced stage of development.
- For the first time, the technical process also becomes participatory. Operators are required to invite users to the study approval meeting at least 10 days in advance. The project is made available, and developers may submit proposals or objections, which are discussed and resolved on-site.
- One of the major changes introduced by Order no. 20/2025 is the establishment of a financial guarantee as a filter of seriousness. Without proof of this guarantee, which must be provided within a maximum of two months from the communication of the approved solution study, the study loses its validity, and the connection request is closed. Moreover, any delay in signing the connection agreement or failure to meet the conditions results in the execution of the guarantee, thus transferring full responsibility for proper planning to the developer.
- Rules are introduced regarding the extension of connection agreements, which is only possible through addendums, with additional guarantees of 5% of the connection fee for each extended 12-month period.
- Situations in which the validity of the ATR automatically ceases are also clarified, in order to prevent the blocking of grid capacity by unfinished projects.
Through these adjustments, ANRE aims to accelerate the implementation of genuine projects and to avoid bottlenecks caused by speculative requests, while also providing greater predictability for developers.
II. Order no. 27/2025 extends the obligation to purchase green certificates to energy storage operators
Order no. 27/2025 clarifies and harmonizes the regime governing the obligation to purchase green certificates, placing energy storage service operators on the same level of responsibility as other traditional participants in the electricity market.
1. Thus, through the introduced amendments, storage service operators owning independent installations (not added to one or more generation capacities) are assimilated to electricity producers in terms of the obligation to purchase green certificates.
2.Through the amendments introduced by Order no. 27/2025, ANRE expands and clarifies the scope of entities considered electricity suppliers and producers under the regulation governing the green certificate market. Thus, distribution operators and the transmission and system operator are assimilated to suppliers when they supply electricity to their own consumption points, other than those intended for the technological consumption of networks. Furthermore, non-concessionary distribution operators become suppliers from a legal perspective for the energy delivered directly to consumers connected to the networks they operate.
3.At the same time, the order introduces a significant novelty: energy storage service operators whose installations are not added to generation capacities are assimilated to producers for the electricity delivered directly to final consumers through their own lines. In this way, ANRE explicitly integrates the storage sector into the green certificate mechanism, placing these entities among the participants with purchase obligations similar to those applicable to traditional producers and suppliers.
4.Furthermore, clear deadlines and procedures are introduced for the registration of participants in the green certificate market and the submission of annual declarations (by March 31).
5.The process of trading green certificates is strictly regulated:
-If the seller does not confirm receipt of the payment for the certificates within 7 working days from the transaction confirmation, the OPCV automatically cancels the transaction and informs both parties involved;
-The trading session is managed through a validation and deduction system for valid green certificates, ensuring correlation between payment confirmations, CV code blocking requests, and account transfers;
-If the number of requested certificates exceeds the available quantity, only the available ones may be transferred, and the corrected documents must be resubmitted.
6.The order also updates the methodology for determining the annual mandatory quota:
-The formula for the estimated annual purchase quota becomes transparent and explicit, thus accessible to all stakeholders in the sector;
-Exceptions for certain categories of final consumers are managed under Government Emergency Ordinance no. 20/2025, rather than the old government decision, recalibrating the entire logic of consumption exemption from green certificate payment;
-Calculations and reporting are performed quarterly and annually, in electronic format (PDF/Excel), with clear deadlines for data submission and publication.
7. Modern operational flows, control, and transparency
-ANRE publishes quarterly the list of obligated operators and the number of required green certificates, ensuring data flow between institutions;
-Economic operators with a portfolio of exempted consumers must submit monthly invoices and reports, ensuring traceability of exemptions.
-The fundamental methodological changes and the repeal of certain annexes simplify administrative structures, increasing system efficiency.
These clarifications align the green certificate mechanism with the current realities of the market, where energy storage plays an increasingly important role, and contribute to improved traceability of obligations among participants.