In brief

  • The funding guide for high-efficiency cogeneration gets the form with which beneficiaries actually ask for the money. Order of the Minister of Energy, acting in an interim capacity, no. 1.088/2026 adds a new annex, Annex no. 12, which holds two forms in one: the pre-financing claim and the reimbursement claim, including the claim relating to pre-financing already received.
  • The mechanism had existed since the summer of 2026, the model claim had not. Pre-financing, payment and reimbursement entered the guide through Order of the Minister of Energy, acting in an interim capacity, no. 559/2026, and the preamble of the present order expressly invokes the „necesitatea completării și corelării anexelor”, the need to supplement and align the annexes introduced then. Until 24 September 2026, the guide referred to a mechanism without saying on what paper it is claimed.
  • The guide manages 361,950,000 euro, but the call closed on 31 July 2024. The form is therefore of use to those who already hold a funding contract, not to new applicants. The aid intensity is 100% of the eligible costs, and implementation cannot run beyond 31 December 2030.
Act: Order of the Minister of Energy, acting in an interim capacity, no. 1.088/2026 supplementing the Applicant’s Guide — Specific conditions for accessing funding from the Modernisation Fund — support for investment in high-efficiency cogeneration in the district heating sector, approved by Order of the Minister of Energy no. 633/2024
Published: Official Gazette of Romania, Part I, no. 811 of 24 September 2026, pages 6-9
In force from: 24 September 2026, the date of publication, under Article II of the order

The Ministry of Energy has supplemented the guide that funds high-efficiency cogeneration plants in district heating systems, adding to it the form beneficiaries will use to ask for the money. It is the same administrative operation the ministry carried out on two other funding guides under the Modernisation Fund, published earlier in 2026: the text of the guide promises a mechanism, and the annex that makes it usable comes separately.

The new annex, numbered 12, sits after Annex no. 11 „Payment claim” and has nine points. The first three identify the claim, the reference period and its type, with four boxes to tick: interim claim, final claim, reimbursement claim and reimbursement claim relating to pre-financing. Points 4 and 5 ask for the details of the beneficiary and of the project, point 6 is the table of eligible expenditure, in two parts, point 7 adds up the amounts, point 8 is the declaration on own responsibility with ten letters, from a) to j), and point 9 is the list of annexes. The declaration is signed in the knowledge of Article 326 of the Criminal Code, that is, under the penalty for false statements.

On the same day, with the signature of the same minister, the Ministry of Energy supplemented in identical terms the guide for smart district heating networks, through Order no. 1.089/2026. The two memoranda of the Directorate-General for Investment on which the orders rest are both dated 19 August 2026 and bear consecutive numbers, 201.610 and 201.609, so the ministry treated the missing form as a single problem that had turned up in two guides.

The order was signed on 15 September 2026 by Ilie-Gavril Bolojan, as Minister of Energy acting in an interim capacity, and was published nine days later. Thirty-six days passed between the memorandum that called for the supplement and publication.

What it changes in practice

The order changes no ceiling, no aid intensity and no eligibility criterion. Its effect is strictly procedural, but it conditions payment:

  • Beneficiaries have an official model claim. Until 24 September 2026, the guide referred to the pre-financing and reimbursement mechanisms without publishing the paper on which they are claimed. From now on, the form of the claim no longer depends on a model sent by e-mail or borrowed from another programme.
  • The verification route is written into the form. The last box, „To be completed by the official institutions”, provides for the signature of the unit receiving the claim, the date of verification, the approval of the head of the verification service and, at the end, „bun de plată”, cleared for payment, given within the Directorate-General for Investment. On the same page, the beneficiary sees how many signatures stand between the claim and the transfer.
  • Pre-financing is claimed in tranches. The pre-financing form has a field for the number of the tranche and one for the percentage of the eligible value of the project, and later reimbursement claims deduct the pre-financing received, under the formula „3 = 1 − 2” printed in the table.
  • The supporting documents become explicit. For pre-financing, the financial identification of the dedicated account and the legal commitments for which the money is used are required; for reimbursement, the invoices, the contracts, the payment orders and the bank statements, for each category of expenditure.

What has changed compared with the previous situation

The guide was approved by Order of the Minister of Energy no. 633/2024 and published in Official Gazette of Romania no. 498 and no. 498 bis of 29 May 2024. In the form it then had, the „Annexes” section stopped at Annex no. 11, „Payment claim”, and Chapter 5, the one on payments, referred to no model pre-financing or reimbursement claim, for the simple reason that the guide did not yet provide for those mechanisms.

They were introduced later, by Order of the Minister of Energy, acting in an interim capacity, no. 559/2026, and that is when the gap the present order fills was created: Chapter 5 spoke of pre-financing and reimbursement, while the list of annexes did not contain the corresponding form. Order no. 1.088/2026 does three small and connected things: it adds to Chapter 5 a paragraph saying that the model is in Annex no. 12, it adds the entry to the list of annexes and it actually introduces the annex.

The rest of the guide’s parameters remain those of 2024. The programme budget is 361,950,000 euro from the Modernisation Fund, broken down by year: 8,950,000 in 2024 and 88,250,000 in each of the years 2025, 2026, 2027 and 2028. The State aid intensity is 100% of the eligible costs, and the eligible cost is the net additional cost, that is, the difference between the net present value of the supported project and that of the scenario without aid. Eligible applicants were the companies that produce electricity and heat in cogeneration for district heating and the administrative-territorial units that produce heat for the public supply service. The call opened on 30 May 2024 at 10:00 and closed on 31 July 2024 at 17:00, so it was open for 63 calendar days.

Advantages and disadvantages

What it improves

  • The claim for money has a model published in the Official Gazette of Romania (Monitorul Oficial), not one circulated through internal channels, so the beneficiary can invoke the official form if asked for something else.
  • A single form covers pre-financing, interim reimbursement, final reimbursement and reimbursement relating to pre-financing, with a box to tick for each situation.
  • The calculation formulas are printed in the table, so the amount claimed is checked by both sides against the same rule.
  • The form is identical with the one added the same day to the district heating networks guide, which makes life simpler for a beneficiary present in both programmes.
  • The final box sets out expressly the approval flow inside the ministry, up to „bun de plată”.

What remains a problem

  • The form appears after the call has closed, so the projects were contracted and started without it.
  • The table at point 6 has columns numbered 5a and 5b, while the footnotes refer to „col. 5”, without saying which of the two.
  • The maximum percentage of pre-financing cannot be seen from the form; it stays in the order that introduced the mechanism, so whoever fills in the claim has to open another act.
  • The order provides no measure for claims lodged before 24 September 2026 on a different model, even though the mechanism was already in the guide.
  • The annex is reproduced in the Gazette as a printed form, with tables spread over whole pages, so it is hard to read on a screen.

Practical advice

  1. Check the number of the annex before you fill it in: in the cogeneration guide the form is Annex no. 12, while in the district heating networks guide, introduced on the same day, it is Annex no. 11. A wrong reference in a covering letter is hard to correct once it has been registered.
  2. Fill in the table at point 6 first and only then point 7. Point 7 expressly asks for the amounts from line III column 12 of table A and from line IV column 5 of table B, so they are calculated, not estimated.
  3. In the VAT column, enter a value only if the tax is eligible in the project; the footnote requires zero otherwise, and a value put there without entitlement shifts the amount claimed.
  4. Keep at your institution the originals of the documents in the list of annexes, stamped and signed. The declaration at point 8(j) attests that they exist, and the form says expressly that they are available for audit.
  5. Check the interval between two reimbursement claims. The guide approved in 2024 provides that the period between them cannot exceed two years, and the form does not repeat that rule.
  6. In the pre-financing claim, give the account from the contract form, not a current account of the company; footnote 1 to the annex asks for exactly that.

Frequently asked questions

Will the call for cogeneration projects reopen?
No. Order no. 1.088/2026 touches neither the timetable of the call, nor the budget, nor the eligibility criteria. The submission of funding applications closed on 31 July 2024 at 17:00, and the guide provided for the possibility of extending the deadline by a decision of the Ministry of Energy, not by an order supplementing the annexes.
From when can the new form be used?
From 24 September 2026. Article II of the order says that its provisions enter into force on the date of publication in the Official Gazette of Romania, and publication took place in edition no. 811 of that day.
What percentage of the eligible value can be claimed as pre-financing?
The form leaves the percentage blank, with a field in which the applicant writes it. The limit is not in the annex published now, but in the order that introduced the pre-financing, payment and reimbursement mechanisms into the guide, namely Order of the Minister of Energy, acting in an interim capacity, no. 559/2026.
Who signs the claim?
The legal representative of the beneficiary. Footnote 2 to the annex expressly provides that the pre-financing claim is signed by the legal representative, while at the end of the reimbursement claim signatures are required from both the project manager and the legal representative.
What happens if money is claimed without justification?
The declaration at point 8 provides that the amounts may not be paid, may be corrected or may be recovered. On top of that, the declaration is given in the knowledge of Article 326 of the Criminal Code, on false statements.
Is the form the same in both guides supplemented on 24 September 2026?
The content is practically identical, from the registration header to the „bun de plată” box. What differs is the number of the annex, 12 in the cogeneration guide and 11 in the smart district heating networks guide, because the two guides have a different number of pre-existing annexes.

Editorial analysis

The order solves a real and small administrative problem: a guide that provided for pre-financing and reimbursement without publishing the claim through which they are requested. As long as the model was missing, every beneficiary depended on what the ministry told them, and a claim rejected on a point of form could not be challenged against an official text. The correction is welcome and, judging by the two consecutive memoranda of 19 August 2026, the ministry spotted the gap itself, not after a complaint.

What does not show when you read the order from start to finish is the proportion of what is at stake. The cogeneration guide moves 361,950,000 euro, and the district heating networks guide, supplemented the same day with the same annex, another 590,000,000. Together, the two programmes commit 951,950,000 euro from the Modernisation Fund, that is, almost a billion, and until 24 September 2026 neither of them had published the form through which beneficiaries claim pre-financing. The difference between the two guides makes the gap even more visible: in district heating, where the submission of projects falling outside State aid rules stays open until 1 January 2027, the form arrives in time for new applicants; in cogeneration, where the call closed on 31 July 2024, it arrives 785 days after the closure, to beneficiaries who have meanwhile contracted works and moved ahead with them.

The second observation comes from comparing the two aid regimes. The networks guide caps the aid at 50,000,000 euro per project and per undertaking and limits each undertaking to a single project, invoking Regulation (EU) no. 651/2014. The cogeneration guide has no cap per project and does not invoke the regulation, but the State aid scheme approved by Order of the Minister of Energy no. 542/2024, and an applicant may submit several projects, each with its own feasibility study. The same form therefore serves two different aid architectures, which explains why the annex has neutral fields and why whoever fills it in has to go back to their own guide for the limits.

What should be changed

  • The footnotes to the table should refer to 5a or 5b, not to „col. 5”. The table at point 6(A) numbers the columns 1, 2, 3, 4, 5a, 5b and then 6 to 12, while footnote 3 and the note at the end of the table refer to „col. 5”. Naming the column would spare the beneficiary a choice between two cells and the verification unit a correction on paper.
  • The maximum percentage of pre-financing should be printed on the form. The field is now blank and the limit sits in another act. Written next to the field, it would do away with claims above the ceiling, which go back to the beneficiary and use up a verification cycle.
  • The order should say what happens to claims already lodged on a different model. The mechanism was working in the guide before 24 September 2026, so there may be claims in progress. A one-sentence transitional provision would close the discussion about whether they are valid.
  • The rule on the maximum interval of two years between two reimbursement claims should be repeated in the annex. It sits in the body of the guide and the form does not mention it; a beneficiary who fills in only the annex can miss the deadline without seeing where they went wrong.
  • The two twin annexes should carry the same functional reference number. One is now no. 12 and the other no. 11, in programmes under the same key programme 5, and the correspondence between them is written nowhere. A mention in the list of annexes would prevent wrong cross-references.

Original text of the legal act

The text below is reproduced in Romanian, the official form of publication.

The full text, as published in the Official Gazette of Romania

Official Gazette of Romania no. 811 of 24 September 2026 16 pages PDF, 100 KB the act starts on page 6

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This article is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed attorney or tax advisor.