Insights

Regulatory clock

Two guarantees that look alike in a model and are not

Order 15/2026 sets a 20 percent connection guarantee. Order 16/2026 adds 30 EUR/kW at the authorisation stage. Different base, different trigger.

Sol Associates, 1 October 20264 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).

Romanian developers now carry two guarantees that look alike in a financial model and are not. A single line called “regulatory guarantees”, with one number at one date, hides the difference.

The connection guarantee: Order 15/2026

Since 25 May 2026, ANRE Order 15/2026 sets the connection guarantee at 20 percent of the connection tariff, excluding VAT, for projects above 1 MW of approved evacuation power. A transitional rule leaves out cases where the grid operator had already communicated the guarantee value before 25 May 2026.

The authorisation guarantee: Order 16/2026

ANRE Order 16/2026 adds a second guarantee at the authorisation stage: 30 EUR/kW of installed capacity. It is constituted when the AI application is filed and held until the reception protocol.

Side by side

Connection guaranteeAuthorisation guarantee
InstrumentANRE Order 15/2026ANRE Order 16/2026
Level20 percent of the connection tariff, excluding VAT, above 1 MW of approved evacuation power30 EUR/kW of installed capacity
BaseA tariff the grid operator calculatesNameplate power
StageConnectionAuthorisation (AI filing)
Held untilNot addressed in this noteThe reception protocol

One follows a tariff that the grid operator calculates. The other follows nameplate power. One belongs to the connection stage, the other to the authorisation stage. Because their bases differ, they do not move together when the project is resized or the tariff is revised.

A sense of scale

For scale, and only as arithmetic: 30 EUR/kW on an illustrative 100 MW project is EUR 3.0 million. That is a worked example, not a statement about any real project. How such an amount is funded is a financing question, and it needs an answer before the filing, not after.

What to check in your own model

  • Are the two guarantees on separate lines, each with its own base and its own date?
  • Does the connection guarantee use the tariff excluding VAT?
  • Does the authorisation guarantee appear in the cash plan at the date the AI application is filed, not at the date the AI is granted?
  • Does the transitional exception for guarantee values communicated before 25 May 2026 apply to your connection file?

The AI itself carries several deadlines, described in Your AI has three clocks.