applicable starting with 1 June 2025

On 29 May 2025, the ANRE Order no. 20/2025 for amending and supplementing certain ANRE orders regarding the connection of users to the public energy grid (“Order no. 20/2025”) was published in the Official Gazette and entered into force on 1 June 2025.

The Order no. 20/2025 amended the following ANRE orders:

• ANRE Order no. 59/2013 for the approval of the Regulation on the connection of users to energy grids of public interest (the „Connection Regulation”);
• ANRE Order no. 74/2014 for the approval of the framework content of the technical connection approvals;
• ANRE Order no. 105/2022 for the approval of the framework agreements for connection to public energy networks (“Order 105/2022”);
• ANRE Order no. 51/2019 approving the Procedure for notifying the connection of generating units and verifying their compliance with the technical requirements for connection to public energy grids;
• ANRE Order no. 46/2021 approving the Performance Standard for Energy Distribution Service.

We will present below a detailed summary of the main amendments brought to the Connection Regulation.

1. The possibility of updating the ATR by including the operational power limitations (“Grid Curtailments”) is now officially recognized

Grid Connection Approvals (“ATRs”) that were still valid on 1 June 2025[1] may now be updated upon the user’s request. Following such a request, the updated ATR must be issued within 30 days, and, where applicable, an addendum to the Grid Connection Agreement (“GCA”) will be concluded.

This update is particularly relevant for ATRs issued without considering grid curtailments, especially those released before or shortly after the introduction of operational limitations in June 2022. Until now, it was generally understood that ATR updates to reflect curtailments were only possible if the conditions under the transitory provisions of ANRE Order 81/2022 were met. In practice, however, some grid operators allowed such updates, while others did not, leading to inconsistent treatment across projects.

Although this express provision comes with a significant delay, it may still offer positive outcomes for older projects, particularly those facing high reinforcement costs under N-1 scenarios.

2. The Grid Curtailments are now qualified as grid connection works (until now, they were qualified as grid reinforcement works)

This amendment has drawn criticism from the industry during the public consultation phase, as it places the operation and maintenance (“O&M”) responsibilities and the related costs and risks on the investors, even when the Grid Curtailment installations are located within the grid operator’s facilities.

In an attempt to address some of the concerns, ANRE has introduced a provision stating that the exploitation convention (to be signed between the user and the grid operator for the use of Grid Curtailments) must include the user’s right to access the relevant installations for O&M purposes, even if they are situated within the operator’s infrastructure.

3. Upon the calculations under the solution study (“SS”), projects are considered in the chronological order in which the complete documentation is submitted

ANRE considered it useful to specifically regulate a practice that was already in place, but which was not always applied uniformly.

As such, when determining the input data for the SS, the following projects within the same network area are taken into account in order to assure the observance of the chronological order of the grid connection applications:

1. Those with contracts signed for the preparation of the solution study;
2. Those with SSs already prepared and approved by the network operators;
3. Those with valid ATRs;
4. Those with issued connection certificates.

These rules also apply to users who submitted connection requests but had not yet signed contracts for the preparation of the SS until 1 June 2025.

4. User input process prior to the SS approval meeting

ANRE once again considered it necessary to formally regulate a practice that had been applied until now, but inconsistently and without clear procedural guidance.

By introducing specific deadlines, the regulation ensures that users are given adequate time to review the solution study and raise any objections:

• The network operator must notify the user about the date of the approval meeting for the connection solution and send to the user the draft solution study with at least 10 days in advance of such meeting in order to enable the user to formulate comments/ amendments.
• The user has the right to submit comments and/or requests for modifications, with supporting justifications, no later than 5 days before the meeting.
• These user’s requests must be addressed during the approval meeting itself.

This clarification aims to standardize the process across all network operators, enhancing transparency and ensuring that users can participate meaningfully in the evaluation of connection solutions.

5. Financial guarantee submission and ATR issuance deadlines

Since the introduction on 2 August 2024 of the financial guarantee requirement before the issuance of the ATR, its effectiveness in preventing non-committed investors from blocking grid capacity has been limited, mainly due to the lack of clear deadlines for submitting the guarantee and issuing the ATR.

To address this gap, ANRE has now introduced specific deadlines aimed at reinforcing the credibility and efficiency of the connection process:

1. The network operator must provide to the user the value of the guarantee at the same time with the communication of the approved SS; in case several solutions are included in the SS, the network operator must provide the value of the financial guarantee for each solution;
2. The user must submit proof of the setting up of the financial guarantee to the network operator within two months from receiving the approved solution study.
3. If the user fails to meet this deadline, the solution study becomes invalid, and the connection request is closed. The network operator must notify the user in writing within 5 working days from the expiry of the two months deadline.
4. The two months deadline also applies to users who had already received approved SSs from the grid operators prior to 1 June 2025, but who had not yet submitted proof of the financial guarantee. For said users, the deadline to submit the guarantee is no later than 1 August 2025.
5. The network operator must issue the technical connection approval within 10 calendar days from receiving proof of the setting up of the financial guarantee.

6. Grid Connection Agreement (“GCA”) signing process

Aware that, in practice, delays in signing grid connection agreements often occur — caused by both users and network operators — ANRE considered it necessary to introduce a clear and enforceable timeline for initiating and completing the contract signing process. 

This regulatory intervention aims to ensure predictability, reduce procedural bottlenecks, and promote consistent application across all network operators:

• After receiving the technical connection approval (ATR), the user must request in writing[2] the signing of the connection contract at least 45 calendar days (increased from the previous 30 days term) before the ATR expires.
• If the submitted documentation is incomplete, the network operator may request additional documents within 10 calendar days from the registration of the user's request. The user must provide the missing documents at least 15 calendar days before the ATR expires, to ensure the contract is signed within the 12-month validity period of the ATR.
• If the user fails to complete the documentation within said deadline, the ATR automatically expires at the end of the respective deadline, and the network operator is released from the obligation to send the draft grid connection contract and is entitled to enforce the financial guarantee.
• The network operator must send the signed draft connection contract to the user within 10 calendar days from the registration of the complete documentation, in case the GCA contains the standard approved provisions[3].
• If the draft GCA includes additional clauses subject to negotiation, the deadline for sending the signed contract is 5 calendar days from the agreement on those clauses. In this case, both parties are required to agree on the negotiable terms and sign the contract before the expiry of the 12-month ATR validity term.

While the new rules introduce stricter deadlines for users, it remains unclear what happens if the grid operator fails to meet its own deadlines. Notably, there is no express provision allowing the 12-month deadline for signing the GCA to be extended in cases where the delay is caused by the operator’s fault, including in case of lack of cooperation or failure to negotiate the GCA terms.

In such situations, it may be assumed that the user has grounds to file a formal complaint with ANRE. If the complaint is found to be justified, ANRE should require the operator to issue the signed draft agreement even after the expiry of the ATR validity, as the Connection Regulation only exempts the operator from this obligation when the user fails to meet its own deadlines.

Although not explicitly regulated, such complaint mechanism could serve as a practical safeguard, and hopefully, a sufficient incentive for grid operators to comply with their procedural obligations.

7. Amendments of the GCA

The parties to a GCA may amend or extend it by mutual agreement through addenda or, as applicable, by following the below rules:

1. The user may request to extend the GCA with successive 12-month periods if additional time is needed to finalize the energization of the user’s installation. This is allowed only if the user provides a financial guarantee valid for the entire extension period.
2. The guarantee begins at 5% of the connection tariff, with an extra 5% added for every additional year of extension;
3. The extension request must be submitted at least 30 days before the GCA expires and must include proof of the setting up of the financial guarantee;
4. The network operator must issue the signed daft addendum within 15 days from the user’s request, and the user must return the signed addendum before the GCA’s expiration;
5. The above provisions do not apply if the delay is due to the network operator’s own works (e.g., delays in completing the connection or reinforcement works). In such cases, the extension may be initiated by either party through an addendum.

The new provisions also apply to GCA extension requests submitted before 1 June 2025.

For GCAs set to expire within 30 days from the same date, the standard deadlines under letters c) and d) above are reduced accordingly, to ensure that the extension process, including the submission of the financial guarantee, can still be completed in time.

These rules respond to a pressing issue in practice: congested grid capacity is often blocked by projects with low implementation prospects. ANRE’s initiative aims to introduce a uniform and enforceable framework for GCA extensions across all grid operators, helping to clear capacity for viable projects.

Moreover, this clarification is particularly relevant in light of Transelectrica’s salutary but too strict attempt to stop unjustified GCA extension requests, through an internal regulation[4] issued in December 2024. It should be interpreted that said internal rule is no longer applicable starting with 1 June 2025, as the currently applicable Connection Regulation (being a higher-ranking legal instrument) takes precedence since it regulates the same subject matter.

8. Trafo/ Connection Station ≥ 110 kV specific regulations

Annex 5 of the Connection Regulation was amended, in such a way as to include explicit reference that it applies also for single-user connection solutions (not only to shared connection solutions for 2 or more users, as the previous text seemed to suggest).

As such, for the Trafo and/or Connection Stations ≥ 110 kV, irrespective of whether they are single-user or shared connection solutions, the following rules apply:

1. The construction works of the Trafo Station and its connection lines to the grid are classified as network reinforcement works.

While this approach might have seemed more appropriate for connection stations (given their proximity to the grid connection point and potential classification as part of the grid operator’s infrastructure) it ultimately supports long-term project planning, particularly in terms of costs, risks, and liabilities. As such, under this framework, the O&M and associated responsibilities for transformer stations and their connection lines up to the grid point will rest with the grid operator, even when the station is located within or in the immediate vicinity of the PV or wind park.

It remains unclear whether connection stations were intentionally left excluded from this classification or if their omission was unintentional.

1. The delimitation points are set downstream of the low-voltage busbar within the transformer station, while the connection points are established downstream of the facilities resulting from the reinforcement works, qualified as such under the previous point.
2. Multiple sectioning of high-voltage lines (≥220 kV) is not permitted; sectioning is only allowed at intervals of at least 10 km from each other or from the line ends.
3. If a user or group of users finances a transformer station and/or a connection station as part of a shared connection solution, they are required to allow access and connection for other users. In return, they are entitled to financial compensation from those users.
4. The TSO provides electricity transport services to users connected at the low-voltage busbars of the stations.
5. The Trafo and/or Connection station and the connection lines become the property of the network operator, in accordance with legal provisions.