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Your AI has three clocks: how Order 15/2026 sets the deadline

The market repeats a two-clock rule for the establishment authorisation. Order 15/2026 carries a third trigger, and it is often the earliest.

Sol Associates, 1 October 20265 min read

Terminology. AI here means autorizație de înființare, the ANRE authorisation to establish a generation or storage plant. It does not mean artificial intelligence. ATR is the technical connection permit (aviz tehnic de racordare) and CR is the connection contract (contract de racordare).

The rule most people quote

The market repeats a two-clock rule: obtain the AI within 18 months of the ATR and within 12 months of the CR, whichever falls first.

AI = MIN( ATR + 18 months , CR + 12 months )

That formula is incomplete.

The third trigger

ANRE Order 15/2026 (Monitorul Oficial, Partea I, 25 May 2026) carries a third trigger at Article 36 alin. (5^2). The AI must be in hand by the date the connection-installation execution contract is concluded. The text reads:

“…până la data încheierii contractului de execuție a instalației de racordare.”

In plain terms, the AI must be in hand by the date you conclude the execution contract for the connection works. You and the grid operator set that date, and it can fall well before either statutory clock. Above 1 MW of approved evacuation power, the deadline is the earliest of three dates.

AI = MIN( execution-contract date , CR + 12 months , ATR + 18 months )

The third date is frequently the earliest, so a contract you are about to sign can set your permitting deadline.

A worked sequence

The months below are illustrative only. Take an ATR at month 0 and a CR concluded at month 4. The execution contract is signed at month 10.

TriggerFalls atResult
Execution contractMonth 10Earliest, so it governs
CR + 12 monthsMonth 16Later
ATR + 18 monthsMonth 18Latest

In this sequence the execution-contract date sits eight months before the ATR clock.

The extensions are narrower than assumed

  • ANRE, plus 60 days. Granted only if ANRE finds the dossier complete before expiry, not merely because it was filed on time (Article 36 alin. (5^4)).
  • Grid operator, plus up to 12 months. Available once, and only for delay not attributable to the applicant. If the operator stays silent the extension is automatic (Article 36 alin. (5^5) and (5^7)).

Taken together that is roughly 30 months from the ATR at the very most, about 32 with the 60 days. Treat it as a ceiling, not an entitlement.

The transitional backstop

Separately, Article V alin. (3) of Order 15/2026 applies to connection contracts above 1 MW that were already in force on 25 May 2026. Those must secure the AI by 25 May 2027. Under Article V alin. (5), missing that date means the ATR lapses and the connection contract terminates by operation of law.

Which of your clocks runs out first is a question about your own file: the date of the ATR, the date of the CR and, above all, the date of the execution contract.