Contributed By Berechet Rusu Hirit
According to publicly available data published by the National Energy Regulatory Authority (ANRE), the energy mix in Romania is dominated by renewable energy, which forms 64.56% of the total, of which hydropower forms 34.08%, wind 15.76%, photovoltaic (PV) 14.17% and biomass 0.55%. This domination of renewables in the national energy mix is a result of existing large hydropower plants combined with an accelerating increase in installed capacity for solar and wind projects and a decrease in non-renewable energy. In 2024 alone, Romania installed 1.7 GW of solar energy and increased its installed renewable energy capacity by 14%, raising the share of renewables in electricity generation to 48%, slightly above the EU average of 47%.
Furthermore, based on the National Energy Strategy for 2025–2035 with further perspective for 2050 (NES), Romania aims to ensure that renewable energy will constitute 61% of the gross final consumption of energy by 2035, and 86.1% by 2050. To reach the ambitious target for 2035, an additional capacity of 19.5 GW of renewable energy is needed, with wind and solar energy playing a critical role in this transition.
The most important renewable energy technologies in Romania are hydropower, solar PV and wind. Many years ago, due to major investments made by the state in the communist era in large hydropower plants, hydropower was the sole renewable technology in Romania. However, in recent decades, given the significant natural resources available and the favourable European context, the renewable market has seen significant developments, particularly in the field of solar PV and wind energy.
The last 12 months in Romania’s renewable energy market have been full of developments and challenges, as the renewable energy sector is growing rapidly and the legal framework is constantly changing. The development of projects using renewable energy sources (RES) boomed, supported by various EU funding sources, such as the National Recovery and Resilience Plan and the Modernisation Fund. Renewable energy developers and investors have also been encouraged by the contracts for difference (CfD) support scheme, which in short involves a 15-year mechanism to guarantee a certain level of revenues for the output of RES capacities. The CfD scheme has already seen two successful rounds, covering onshore wind and solar PV projects with a total installed capacity of around 4 GW, and a third one is under preparation, estimated to be launched by the end of the current year.
As the development of new RES projects increases, grid expansion and stability should keep pace to ensure that new projects are feasible. In this context, battery storage becomes key to ensuring grid balance. Therefore, storage projects are also booming, starting from a few megawatts in 2024 to hundreds of megawatts under development in the current year, but still far from the national target of 2 GW. According to the NES, the target is to achieve a total installed capacity of 2 GW by 2030. This objective is to be achieved by installing battery-based electricity storage systems and developing pumped storage hydroelectric power plants.
There have also been steady improvements to the legal framework for the development of new installations, mainly to implement EU regulations and programmes for accelerating the expansion of green energy and achieving the decarbonisation and climate neutrality targets.
Other notable developments relate to the expansion of the legal framework for offshore projects and the first national strategy for renewable hydrogen.
The energy sector in Romania is primarily regulated by Energy Law no. 123/2012 implementing the EU legal framework for the internal market. The rules and principles regulated by the Energy Law are further implemented in secondary regulations covering a wide area of matters, such as licensing, supply, grid connection, operation, market rules, etc.
The renewable energy sector was initially regulated under Renewables Law no. 220/2018, whose main purpose was to implement the green certificate support scheme for renewable energy capacities. Furthermore, the renewable sector is a main topic covered by the National Energy and Climate Plan, with the main purposes of aligning the national objectives with the ambitious REPowerEU targets, setting up the action plan and defining the implementation instruments for the way forward.
Also, the Romanian government is currently finalising the process of implementing the RED III Directive, focused on increasing the share of renewable energy in the EU’s energy consumption.
A significant change in the legal framework applicable to renewable energy, expected to come into force early next year, will substantially impact the process of connecting new installations to the grid. The new connection rules will address congestion and involve an auction mechanism for allocating grid connection capacity, particularly for generation and storage projects of at least 5 MW. There will be annual tenders for awarding grid capacity to the highest bidders, and the revenues that result from such auctions will finance grid reinforcements.
In Romania, the Ministry of Economy sets the general principles and main policies to be followed with the aim of reaching the national targets and objectives agreed at EU level. However, the main local regulatory authority is ANRE, an independent administrative body under the control of the Romanian Parliament. ANRE’s core activity is the regulation of the secondary legal framework by issuing mandatory orders and decisions on various topics, such as licences, regulated distribution and transportation tariffs, approval of technical and commercial regulations for the electricity, heat and natural gas sectors, etc.
The authority also monitors the compliance of the key players in the energy sector with the mandatory regulations and, to this extent, is competent to perform investigations in the market, to perform inspections and to apply sanctions.
Energy production, storage, distribution (transportation of power through the high, medium and low voltage grid having a voltage of up to 110 kV), supply, trading and transportation (energy transmission through the grid infrastructure having a voltage exceeding 110 kV) are regulated activities in the energy sector, without there being specific provisions for renewable energy.
Energy production, as well as storage, trading and supply, can be carried out by legal entities authorised by ANRE through the issuance of a specific licence, while distribution and transportation are restricted monopoly activities carried out by distribution and transportation operators, based on a concession right granted by the Ministry of Economy which enables the operation of the grid (owned by the Romanian state).
Acquisition of control rights and (energy-related) assets is subject to clearance from the Competition Council and to a preliminary notification process to ANRE, which, however, does not represent a request for a specific approval from the authority. In practice, renewable energy assets are often transferred by selling shares in the project company, rather than selling the assets directly. Transfer of assets may also entail administrative procedures for transferring the permits, authorisations and licences.
In Romania, investments in energy assets over EUR2 million, including renewable energy infrastructure, are subject to review by the Foreign Direct Investment Screening Commission (CEISD), part of the Romanian Competition Council. Energy-related transactions considered a possible risk to national security may be either blocked or (subject to certain conditions) approved, based on the CEISD’s recommendation.
In Romania, renewable electricity is generated by both state-owned and private producers. For the last few decades, the leader of renewable electricity production was Hidroelectrica, a partially listed company controlled by the state, with hydro and wind generation units of approx. 6.5 GW still operational. However, during the last few years, private developers have become key players in the market, as the development of RES projects has grown at a fast pace. The accelerated move was encouraged by EU policies to reach carbon neutrality and energy independence, which translated into EU funding programmes and beneficial amendments of the applicable legal framework.
Currently, there is not a significant production sector for gas from renewable sources in Romania.
Currently, there is not a significant production sector for heat from renewable sources in Romania.
Hydrogen production in Romania is still in its early stages, but the first few initiatives related to the legal framework are worth mentioning.
The relevant documents setting out Romania’s objectives are the National Strategy for Hydrogen and the related Action Plan, nearly finalised and approved by the government. The broad goal is to produce green hydrogen by water electrolysis, using electricity from renewable sources through a process that does not generate carbon dioxide emissions and using such product in the transport and industrial sectors. In addition, Hydrogen Law no. 237/2023 was enacted to guarantee that once it is produced, hydrogen is integrated into said sectors, by imposing upon the fuel suppliers specific obligations to provide fuels from renewable sources, in a predetermined quota.
One of the challenges related to hydrogen production is transportation, which, at least in this initial stage, could be achieved through the existing (but further adapted) gas infrastructure. The national gas network operator is conducting an experimental project to assess the suitability of pipelines for transporting renewable hydrogen, as well as the feasibility of mixing hydrogen with natural gas for transport through the same grid. Moreover, ANRE issued a Hydrogen Code, which includes rules for identifying suitable areas for the production, transportation and consumption of hydrogen, with a focus on the conversion of the existing gas infrastructure to be prepared for hydrogen transportation or gas blended with hydrogen.
Domestic renewable production (mostly solar PV) is booming in Romania, driven by favourable policies, declining costs for equipment, available EU subsidies and compensation schemes.
Initially, general terms and conditions applicable to small-scale producers of green energy for own consumption (defined as “prosumers” in local legislation) were briefly included in the Energy Law, and then further detailed in secondary legislation. In a nutshell, prosumers must be certified as such and their facilities must be connected to the grid, in order to benefit from several advantages provided by specific regulations. As such, the prosumers may choose, subject to the capacity of their installations, to sell their excess electricity to the suppliers or to use the surplus when the output does not cover the consumption, limited to 24 months. Furthermore, the prosumers are exempted from paying the regulated tariffs that are usually included in the energy price and from the fiscal obligations related to the income that results from selling the electricity.
The electricity is carried through the distribution and transportation networks, based on specific agreements concluded with the relevant grid operators. As stated under the Energy Law, the distribution and transportation grid operators must give priority in dispatching to production facilities that use renewable energy sources, to the extent that the secure operation of the national electricity grid allows this.
However, given the unpredictability of renewable sources, storage capacity is seen as an optimal solution for assuring the grid’s stability and reliability. Initially, storage facilities were developed next to the RES projects, but the next phase is, according to the NES, the development of independent energy storage units, which will be directly connected to the grid. The operators of such independent storage units will provide essential ancillary system services and energy balancing, and in the future will be able to offer flexible decentralised services.
Moreover, the NES also mentions the objective to promote the installation of energy storage systems in end users’ homes and commercial buildings (so-called “behind-the-meter” storage systems). These systems will optimise users’ consumption profiles and help reduce energy bills by efficiently using stored energy during peak consumption periods and periods when energy is expensive.
Romania does experience curtailment, especially during periods when very high renewable generation coincides with low demand – such as on weekends. This manifests in significant negative prices on the balancing market and volume-based forced reductions for producers. Initially, Romania addressed the grid congestion from intermittent renewables mainly by expanding the transmission infrastructure, a process that proved to be too slow to keep pace with renewables growth. Later, the approach consisted in developing storage facilities and restricted access to the grid to discourage speculative development, as well as accelerated automation of the grids.
Currently, there is not a significant production sector for gas from renewable sources in Romania.
Currently, there is not a significant production sector for heat from renewable sources in Romania.
Transportation and storage infrastructure for hydrogen and biofuels are not developed as the production of these products is still in its early stages.
The retail electricity market is the framework where electricity is purchased by end consumers to meet their own consumption needs. In this market, suppliers sell electricity, including renewable energy, to end consumers through supply contracts at prices negotiated or set by standard offers. The market is fully liberalised, and the suppliers are free to set prices based on the available output supply and the consumption demand. The proportion of renewable electricity in the total consumption is significant, since the largest producer of electricity is a major hydropower plant.
The key parties to the retail electricity market are:
A specific category of end users is the prosumers, which are at the same time consumers and producers of renewable energy, holding small generation capacities, mainly PV panels installed on rooftops for covering household consumption.
Considering the incipient stage of green gas and biogas production in Romania, there is not a specific market for trading such products. Romania’s Electricity and Natural Gas Market Operator (OPCOM) facilitates centralised trading platforms for natural gas (spot, intra-day, bilateral), although there is not yet a dedicated market mechanism specifically for biogas/green gas separate from general gas products.
Currently, there is not a significant market for the supply and trade of heat from renewable sources in Romania.
Currently, there is not a significant market for the supply and trade of hydrogen and other biofuels in Romania.
The Romanian market for renewable energy certificates is evolving, and will consist of a dual system of both “green certificates” (GCs) for the promotion of renewable electricity and the upcoming incorporation of European standard “Guarantees of Origin” (GOs) for full tradability on the European market, including abroad. While standard contracts already exist for bilateral trades, the finalisation of GO-specific legislation is pending, with ANRE expected to join the Association of Issuing Bodies (AIB) to align with EU standards. AIB is a non-profit organisation that promotes the use of a standardised system – the European Energy Certificate System – including GOs, based on structures and procedures to ensure the reliable operation of international energy certificate systems.
A GC support scheme combined with mandatory quotas was opened, in Romania, for projects commissioned before 31 December 2016. The RES projects that qualified were granted, until the end of March 2032, a specific number of GCs per each megawatt of production, which were traded either together with the output volumes or independently. The scheme was subsequently reduced, as the renewable technologies had reached a point of being overcompensated, as emerged from ANRE’s monitoring of the costs and revenues of such projects.
Pursuant to primary legislation, Guarantees of Origin (GOs) are electronic certificates issued by ANRE that prove to end consumers that the energy they receive is generated from renewable sources. For each megawatt, the RES producers receive one GO, which is valid for one year from the production date. The implementation of the GO legislation, specifically the provisions relating to GO transfer between various key players in the electricity chain, triggered practical difficulties in using GOs as valuable commodities. However, the issues might be soon settled as the legislation is currently changing and Romania is scheduled to become a member of AIB by June 2026, with full integration and cross-border trading of GOs expected by January 2027. Joining the AIB will allow Romania to streamline its GO trading system, align with EU standards, and enable cross-border GO transfers.
After a ban lasting nearly a decade and given that many RES projects were developed and built in the last few years, the demand for offtake arrangements became higher, mainly because most financiers requested a long-term power purchase agreement (PPA) as a condition for financing the RES projects. PPAs had a slow start in Romania but are expected to be more frequent starting with the last quarter of the current year, due to the repeal of some price limitations imposed by the government to protect the buyers. The majority of the PPAs publicly announced in the last few years were virtual or financial PPAs, often concluded with foreign buyers.
Onshore renewable energy project development is a complex process that entails two main stages: (a) construction; and (b) operation.
For an RES project to be considered ready to build, the developer must secure both the construction authorisation and the grid connection. As a first step, suitable land for the project must be identified and building rights obtained for this land, either by purchasing the property rights (through a sale and purchase agreement) or by obtaining real rights (ie, through long-term surface rights or concession agreements). Save for the concession right, which is granted following a public tender, the other real rights can be secured privately, by signing notarial deeds. Easement rights may also be ensured for placement of underground cables, access to the project site or the overfly zones covered by turbine blades.
The next step in terms of development is obtaining authorisation for the construction works related to the project, which can be achieved by obtaining a building permit. To this end, the local authorities issue a certificate of urbanism listing any technical conditions or building restrictions, as well as the permits that must be issued by several authorities, depending on the project site’s location and particularities. Once all such permits have been duly issued and technical documentation for construction has been completed, the developer may request a building permit. To fully reach the ready-to-build stage of a project with an installed capacity of more than 1 MW, an additional authorisation must be issued by ANRE.
In parallel with the building authorisation process, the new facility must secure a guaranteed connection to the relevant grid. Generally, the grid connection is enabled either by the regional grid operator (authorised for the area where the project is built) for projects having an installed capacity of up to 50 MW or by the national grid operator for capacities that exceed this threshold. The document that allows connection to the grid is the technical connection permit (ATR), which shall be issued only following a grid connection feasibility study prepared by the investor and endorsed by the relevant grid operator. Subsequent conditions for maintaining the ATR’s validity are, among others, (i) the execution of a grid connection agreement with the relevant grid operator within 12 months as of the ATR’s issuance date and (ii) the issuance of a building permit for the project within 18 months from the same date.
Once the construction of the project and related infrastructure (including cables, transformers, substations, etc) is complete, the facility will be subject to testing and certifications before receiving the ultimate commissioning approval. However, before entering the operational stage, several technical matters should also be managed, such as contracting balancing, dispatching, and operation and maintenance services with authorised suppliers.
Romania is making significant moves to develop offshore wind energy in the Black Sea, with a new general legal framework that was enacted in 2024 and a roadmap targeting 3 to 7 GW by 2035. The government is currently conducting technical studies to identify viable zones for concession, with a strong emphasis on grid development, environmental protection and attracting investment to build a domestic supply chain.
The procedural rules for participating in the competitive auctions for the granting of the concession rights are still pending. In principle, the concessions for offshore wind zones will be awarded following public tenders and will enable the exploration of those zones and the construction and operation of the respective wind turbines for 30 years, with the option to extend the term for another ten years. The legislation also provides for a potential state aid scheme that might be available at a later stage, for the construction and operation of offshore wind projects, subject to commissioning the projects within eight years from the concession agreement date.
When structuring project financing for renewable energy assets in Romania, there are several key legal considerations and specific risks that must be accounted for. These stem from the local regulatory framework, EU obligations, bankability factors and renewable-specific policies, all of which may differ from project-financed assets in general (such as infrastructure or real estate projects).
The main risks that are often evaluated by the financiers are those that relate to permitting challenges, grid access constraints (especially in over-congested areas), real estate issues and regulatory risks. PPAs are essential for bankability – especially in the absence of support schemes.
Currently, Romania offers a mix of EU and state-funded renewable energy incentives, but the most relevant are the green certificate (GC) scheme and contracts for difference (CfD).
The GC support scheme was applicable for projects commissioned before 31 December 2016, which receive a specific number of GCs per megawatt of renewable energy, until 2032. The scheme was repealed and is no longer available for new projects.
In 2024, the CfD support scheme was enacted, initially in two stages and with a third one pending in the following months. The CfD is a state aid mechanism, authorised by the European Commission and financed by the Modernisation Fund, to support low-carbon electricity generation, primarily onshore wind and solar PV projects. The process entails the participation of RES project developers in an auction to set up the ‘‘strike price’’ for their output. The winning bidders will conclude a 15-year agreement with the Electricity and Natural Gas Market Operator (OPCOM) under which they will have a guaranteed revenue stream, receiving payments when the market price falls below their “strike price” and making payments if the market price exceeds it. The main benefit of the CfD scheme is that it will provide a long-term, predictable revenue stream for developers, reducing financial risk and attracting investments.
Following two recent auctions organised under the CfD framework, Romania has awarded a total of 4.2 GW of renewable energy capacity. Recently, the Ministry of Energy launched a call for expressions of interest regarding participation in a third auction dedicated to onshore wind only, to be concluded by the end of 2025. The procedural rules will be the same as for the previous auctions, and the capacity to be auctioned will be determined based on the expressions of interest.
Since the Romanian renewables sector is quite young compared with other EU countries, there are not many projects that have reached the end of the equipment’s lifespan, and there are no specific requirements in terms of the decommissioning process.
Romania aims to significantly increase the share of renewable energy in its gross final energy consumption, with major developments focusing on increasing hydro, wind and solar power, alongside developing energy storage and phasing out coal. Key policies include supporting the development of energy infrastructure, promoting the hydrogen value chain, creating an enabling framework for prosumers and energy communities, and attracting investment in domestic manufacturing of renewable components.
Major policy developments include:
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