In brief

  • The 590-million-euro guide for smart district heating networks gets the form with which beneficiaries ask for the money. Order of the Minister of Energy, acting in an interim capacity, no. 1.089/2026 introduces Annex no. 11, which holds the pre-financing claim and the reimbursement claim, including the one relating to pre-financing already received.
  • The form arrives 99 days before the last submission deadline. Projects that fall outside State aid rules, that is, type B projects, can be submitted until 1 January 2027 at 12:00. For type A projects, submission closed on 30 June 2024.
  • The two types of project have different regimes. For type A, the aid is granted under Regulation (EU) no. 651/2014, may reach 100% of the funding gap, cannot exceed 50,000,000 euro per project and per undertaking, and an undertaking may submit only a single project. For type B, the co-financing rate is 100%, and the budget allocated is 390,000,000 euro, that is 66.1% of the total.
Act: Order of the Minister of Energy, acting in an interim capacity, no. 1.089/2026 supplementing the Applicant’s Guide under the State aid scheme for supporting the modernisation/rehabilitation of the smart district heating network from the Modernisation Fund, under key programme 5: High-efficiency cogeneration and modernisation of district heating networks — Support for modernising and building high-efficiency cogeneration plants and for modernising district heating networks — Investment area 5.3: Support for modernising and developing the smart district heating network, approved by Order of the Minister of Energy no. 24/2024
Published: Official Gazette of Romania (Monitorul Oficial), Part I, no. 811 of 24 September 2026, pages 10-13
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 the modernisation and digitalisation of district heating networks, adding to it the form beneficiaries will use to claim pre-financing and reimbursement. The operation resembles the one carried out on other funding guides under the Modernisation Fund: the payment mechanism enters the guide through one order, and the model claim that makes it usable comes through another, later.

The new annex, numbered 11, sits after Annex no. 10 „Payment claim” and comprises two forms. The first is the pre-financing claim: a registration header for the beneficiary and for the Directorate-General for Investment, the number of the tranche claimed, the amount in lei and the percentage of the eligible value of the project, plus two compulsory supporting documents, the financial identification of the account and the legal commitments for which the money is used. The second is the reimbursement claim, with nine points: identification of the claim, the reference period, the type of claim with four boxes to tick, the details of the beneficiary and of the project, the table of eligible expenditure in two parts, the totals, the declaration on own responsibility with ten letters and the list of annexes.

On the same day, with the signature of the same minister, the Ministry of Energy added the same annex to the guide for high-efficiency cogeneration as well, through Order no. 1.088/2026. The memoranda of the Directorate-General for Investment on which the two orders rest are both dated 19 August 2026 and bear consecutive numbers, 201.609 for district heating and 201.610 for cogeneration.

The order was signed on 15 September 2026 by Ilie-Gavril Bolojan, as Minister of Energy acting in an interim capacity, and 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 touches neither the budget, nor the aid intensity, nor the eligibility conditions. It changes only the way the money is claimed, and that matters for any beneficiary who holds a contract or is preparing to submit a type B project:

  • The pre-financing claim has a published model. Until 24 September 2026, Chapter 5, section 5.2 of the guide described the mechanism without indicating the form. From now on, the section refers expressly to Annex no. 11.
  • Pre-financing is deducted automatically on reimbursement. The table at point 6(B) provides a separate line for the pre-financing deducted up to the current claim and for that deducted from the current claim, while point 7 calculates the amount actually claimed under the formula „3 = 1 − 2”.
  • The beneficiary declares ten things on their own responsibility. Among them, that the expenditure was actually paid, that the project is not also funded through other instruments of the European Commission, that the rules on State aid and public procurement were observed, and that the transactions are recorded in separate accounts. The declaration is given in the knowledge of Article 326 of the Criminal Code, on false statements.
  • The approval route is visible. The last box of the annex, „To be completed by the official institutions”, contains space for the date of receipt, the date of verification, the approval of the head of the verification service and the „bun de plată”, cleared for payment, given within the Directorate-General for Investment.

What has changed compared with the previous situation

The guide was approved by Order of the Minister of Energy no. 24/2024 and published in Official Gazette of Romania no. 33 and no. 33 bis of 16 January 2024. In the form it then had, the list of annexes stopped at Annex no. 10, „Payment claim”. The pre-financing, payment and reimbursement mechanisms were introduced later, by Order of the Minister of Energy, acting in an interim capacity, no. 600/2026, and the preamble of the present order expressly invokes the need to supplement and align the annexes introduced then.

The supplement has three steps: Chapter 5, section 5.2 receives a paragraph saying that the model claim is in Annex no. 11, the „Annexes” section receives the corresponding entry after „Annex no. 10 «Payment claim»”, and the annex actually enters the guide.

The substantive parameters remain those of January 2024. The net budget allocated to the call is 590,000,000 euro, split into 200,000,000 for type A projects and 390,000,000 for type B ones. The yearly breakdown for type A runs from 30,000,000 a year, between 2023 and 2027, to 20,000,000 in 2028 and 2029 and 10,000,000 in 2030. Type B starts at 85,000,000 in 2023 and falls to 20,000,000 in 2030. Selection follows the „first come, first assessed” principle, within the limits of the budget. Eligible applicants are the administrative-territorial units and the undertakings that hold CAEN code 3530 and the status of transmission and distribution operator, proved by a valid concession contract. The implementation period of a project cannot exceed five years, nor the date of 31 December 2030.

Advantages and disadvantages

What it improves

  • The form appears in good time for type B projects, which can still be submitted until 1 January 2027, so a new applicant has it from the start.
  • A single document covers pre-financing and every variant of reimbursement, with a box to tick for each situation.
  • The deduction of pre-financing from later reimbursements is written into the table, with a formula, so it does not depend on anyone’s interpretation.
  • The annex repeats almost to the comma the form added the same day to the cogeneration guide, which brings the claims across the whole of key programme 5 into line.
  • The form expressly asks for the supporting documents for each category of expenditure, so the file is built to a list, not to custom.

What remains a problem

  • For type A projects, where submission closed on 30 June 2024, the form comes 816 days after the closure.
  • The maximum percentage of pre-financing does not appear in the annex; it stays in the order that introduced the mechanism, so it has to be looked up in another act.
  • The table at point 6(A) numbers columns 5a and 5b, while the footnotes refer to „col. 5”, without specifying which of them.
  • The order says nothing about claims lodged before 24 September 2026 on a different model, even though the mechanism was already working.
  • The annex is reproduced as a printed form, with tables spread over whole pages, hard to follow on a screen.

Practical advice

  1. First establish whether the project is type A or type B, because the deadline depends on it. Type B can still be submitted until 1 January 2027 at 12:00, while type A closed on 30 June 2024.
  2. Check the number of the annex before citing it in a covering letter: in this guide the form is Annex no. 11, while in the cogeneration guide, supplemented on the same day, it is Annex no. 12.
  3. Fill in the table at point 6 before point 7. Point 7 expressly asks for the amount from line III column 12 of the table at (A) and the one from line IV column 5 of the table at (B).
  4. Enter the VAT value only if the tax is eligible in the project; the footnote requires zero in the other case, and a value put there without entitlement changes the amount claimed.
  5. For a type A project, keep an eye on the ceiling of 50,000,000 euro per undertaking. The exchange rate is taken from the month before the funding application is submitted, so the amount in lei is not recalculated with every reimbursement claim.
  6. The pre-financing claim is signed by the legal representative, under the footnote to the annex, while the reimbursement claim is signed by both the project manager and the legal representative.

Frequently asked questions

Can projects still be submitted under this guide?
Yes, but only type B projects, that is, those whose funding falls outside State aid rules. The deadline is 1 January 2027 at 12:00. The submission of type A projects closed on 30 June 2024 at 12:00.
What does the order change for someone who already holds a funding contract?
It gives them the official model pre-financing and reimbursement claim. The contractual conditions, the approved budget and the categories of eligible expenditure stay unchanged, because the order supplements only the annexes of the guide.
What is the maximum aid per project?
For type A projects, the funding cannot exceed 50,000,000 euro per project, and the aid cannot exceed 50,000,000 euro for a single undertaking, which may submit only one project. For type B projects, the co-financing rate is 100%, and the ineligible expenditure remains the beneficiary’s responsibility.
From when is the new form used?
From 24 September 2026. Article II of the order provides 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.
How long does a beneficiary have to complete the project?
The guide provides for an implementation period of at most five years, which cannot run beyond 31 December 2030. A project submitted in December 2026 therefore has an effective limit of four years, not five.
Is the form the same as in the cogeneration guide?
The content is almost identical, from the registration header to the „bun de plată” box. What differs is the number of the annex, 11 here and 12 in the cogeneration guide, because the two guides had a different number of annexes before the supplement.

Editorial analysis

The order fills a real gap: a guide that described pre-financing and reimbursement without publishing the claim through which they are requested. For district heating networks, where the typical beneficiaries are town halls and municipal operators with thin cash reserves, pre-financing is not a detail of procedure but the condition on which the works can begin. An official form also means a reference point the beneficiary can go back to if a different form is demanded.

The observation that does not show when you read the order, or even the guide, from start to finish is the relation between the payment calendar and the submission calendar. The yearly breakdown of the budget allocates 220,000,000 euro to the years 2027 to 2030, that is, 80,000,000 to type A and 140,000,000 to type B, which is 37.3% of the 590,000,000 of the call. At the same time, the last door into the programme closes on 1 January 2027. In other words, more than a third of the money is programmed for years in which nobody can submit a new project, so it will be spent solely by the beneficiaries who got in by then. Seen in that light, the form published on 24 September 2026 arrives in time for the 99 days left, but everything that follows 1 January 2027 is played out among beneficiaries already under contract.

The second observation comes from comparing the two guides supplemented on the same day. This guide caps the aid at 50,000,000 euro per project and per undertaking and forbids the same undertaking from submitting several projects, because it sits under Regulation (EU) no. 651/2014. The cogeneration guide has no cap per project, does not invoke the regulation but the scheme approved by Order of the Minister of Energy no. 542/2024, and allows several projects from the same applicant, each with its own feasibility study. The form introduced now is, however, a single one, with neutral fields, so the different architecture of the two aid measures does not show in it. A beneficiary present in both programmes fills in the same table under two different legal regimes, and the limits have to be looked for in their own guide.

What should be changed

  • The annex should say which type of project each field addresses. The guide has two types of call, with different ceilings, and the form does not distinguish between them. A „type A / type B” tick box would steer the verification inside the ministry without calling for further documents.
  • The maximum percentage of pre-financing should be printed next to the percentage field. The limit now sits in the order that introduced the mechanism, and a claim above the ceiling uses up a whole verification cycle before it goes back to the beneficiary.
  • The footnotes to the table should refer to columns 5a and 5b, not to „col. 5”. The table numbers the two columns expressly, while the footnote leaves the choice to whoever fills it in.
  • The order should lay down a transitional provision for claims in progress. The mechanism was working before 24 September 2026, so there may be claims lodged on a different model, and one sentence would make clear whether they have to be redone.
  • The real implementation period should be aligned with the submission deadline. The guide promises up to five years, but the absolute limit of 31 December 2030 means that a project submitted in the last days of the window effectively has four. Written expressly, the alignment would spare late applicants a schedule they cannot keep.

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 10

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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.