In brief
- Electricity and natural gas suppliers receive 60% of the amount requested in the reimbursement claim within 10 working days after the funds are secured, and the balance within 10 working days of the transfer made by the Ministry of Finance. The compensation has already been deducted from customers’ bills, and the procedure published on 6 October 2026 sets out how suppliers recover it from the state. For the steps that come before payment, namely the analysis, verification and validation of the claim, the act sets no deadline at all.
- Who is affected. The electricity and natural gas suppliers that applied the compensation on bills, plus the four institutions the money passes through on its way to them: the Ministry of Energy for non-household customers, the National Agency for Payments and Social Inspection for household customers, the National Energy Regulatory Authority (ANRE), which calculates and validates the amounts, and the Ministry of Finance, which funds the accounts. Final customers file nothing and have no step to take.
- Two schemes, two chapters, different deadlines. Chapter II covers the claims under Government Emergency Ordinance no. 6/2025 and sets a deadline of 10 working days for the payment of the 60%. Chapter III, for the claims under Government Emergency Ordinance no. 27/2022 relating to consumption in the period 1 April 2024-31 March 2025, sets no deadline at all for the same payment. The order applies from 6 October 2026.
Published: Official Gazette of Romania, Part I, no. 843 of 6 October 2026, pages 11-13
In force from: 6 October 2026, the date of publication, because the order sets no later date
From 6 October 2026, electricity and natural gas suppliers have a written route for recovering from the state the compensation they have already deducted from their customers’ bills: 60% of the amount claimed is paid within 10 working days after the funds are secured, and the rest within 10 working days of the transfer made by the Ministry of Finance. The procedure was approved by the joint order of the interim minister of energy, no. 1.205 of 1 October 2026, and of the interim minister of labor, family, youth and social solidarity, no. 1.449 of 5 October 2026, published in the Official Gazette of Romania, Part I, no. 843 of 6 October 2026. The order implements Law no. 179/2026, which raised the advance from 40% to 60% and removed the payment deadline from the two ordinances, and it covers both bill compensation schemes still open: the one under Government Emergency Ordinance no. 6/2025, for electricity in the period 1 April 2025-30 June 2025 and for natural gas in the period 1 April 2025-31 March 2026, and the older one, under Government Emergency Ordinance no. 27/2022.
The underlying mechanism is simple. The state capped the price of energy, the supplier issued the bill at the capped price, and the difference between what it collected from the customer and what it would have collected without the cap is called compensation and is borne by the state budget. The supplier advanced the money, and the act published on 6 October 2026 governs how it gets the money back: who analyses the claim, who validates it, who pays it and within what time.
Claims are handled along two routes, depending on the type of customer. For household customers, the claim goes to the National Agency for Payments and Social Inspection, the institution under the Ministry of Labor that also pays social benefits. For non-household customers, that is companies and institutions, the claim goes to the Ministry of Energy. Hence the form of the act: a single order, signed by two ministers, both of them interim, four days apart. For energy it was signed by the prime minister himself, Ilie-Gavril Bolojan, who holds the portfolio ad interim; at labor, the signature is that of a state secretary, for the minister.
The analysis carried out by the two institutions is narrow, and it is written as such. They check only that the reimbursement claim and the self-declaration exist and that the identification details and the amounts in the two documents match each other, „pentru evitarea efectuării unor plăți duble”, in order to avoid double payments. The calculation itself and the validation of the final value of the compensation are not theirs: they stay with the National Energy Regulatory Authority, which looks at the supporting documents uploaded by the supplier. Claims filed on paper are not taken into account, under either of the two chapters.
Payment comes in two instalments. The first is 60% of the value claimed by the supplier, not of the value validated by the regulator, and it is made within 10 working days „după asigurarea fondurilor necesare”, after the necessary funds have been secured. The second is the difference between the value set by the regulator and the 60% already paid, and here the 10 working days run from the transfer of the funds by the Ministry of Finance into the account of the Ministry of Energy or of the payments agency.
If the validated value turns out lower than the advance, things run the other way: the supplier returns the difference within 10 working days of the date on which the value calculated by the regulator is communicated to it. Interest and late-payment penalties are calculated and charged on amounts not returned in time, under the conditions of the Tax Procedure Code. It is the only sanction in the whole act, and it concerns one party only.
For the older scheme, Chapter III repeats the steps of Chapter II almost word for word, with two differences. First: it applies to the reimbursement claims relating to consumption in the period 1 April 2024-31 March 2025, that is the last year of the scheme under Government Emergency Ordinance no. 27/2022, and not to the period 1 April 2022-31 March 2023 from the title of the ordinance. Then, the 10 working days no longer appear for the payment of the 60%. The text says only that the payment is made on the basis of the self-declaration, after the administrative checks and „după asigurarea fondurilor necesare”, after the necessary funds have been secured.
The money side is dealt with in the last two articles of each chapter. The Ministry of Energy and the Ministry of Labor substantiate and consolidate the funding requirement, separately for household and for non-household customers, and send it to the Ministry of Finance „în limita creditelor bugetare aprobate”, within the limits of the approved budget appropriations, and the requests must show separately the amounts corresponding to the 60% advance. Payments are made from the 2026 budget, and if the requirement exceeds the budget appropriations approved for 2026, the difference is covered through a budget revision.
What it changes in practice
The first effect is that the reimbursement chain cannot be calculated end to end. The procedure contains five deadlines, all of them of 10 working days. Three fall on the state, in Article 4(2), Article 5(2) and Article 10(2), and two on the supplier, in Article 5(3) and Article 10(3). The state’s deadlines all start from events that have no deadline of their own: the „securing of the funds” and the transfer made by the Ministry of Finance. The supplier’s deadlines both start from the communication of the value, that is from an act the administration controls. On paper, the two payments add up to 20 working days, which is 28 calendar days if no public holiday falls in between. In practice, a supplier cannot say, when filing the claim, when the money will arrive.
The second effect concerns the three operations named in the title of the procedure. Analysis, verification and validation are named in the title of the act, they are split between three institutions, and they have no deadline. The only step with a deadline is payment, and only in Chapter II.
The third effect is an inequality between the two schemes. A supplier with claims under Emergency Ordinance no. 6/2025 has a deadline of 10 working days for the advance, even if that deadline starts running from an uncertain moment. A supplier with claims under Emergency Ordinance no. 27/2022, that is on consumption in the period 1 April 2024-31 March 2025, has no deadline at all for the same payment.
The fourth effect is that the advance is calculated on the amount claimed, not on the amount validated. A supplier that claims more than it is entitled to receives 60% of its own figure, and the correction comes later, at validation. The state’s risk is covered only by the obligation to return the money within 10 working days and by the interest and penalties that apply once that deadline passes.
The fifth effect is a budget condition written out in the open. The money comes from the budget appropriations approved for 2026, and beyond that limit the amounts are covered through a budget revision. The revision has no date in the act, so the moment when payments are unblocked depends on a future act of government, not on the procedure published now.
The sixth effect has to do with the calendar. The order appeared 86 days before 31 December 2026, the final deadline for entering the data needed for reimbursement and settlement, set by Law no. 179/2026. All the stages the act describes without a deadline have to fit inside that interval.
What has changed compared with the previous situation
Until Law no. 179/2026, the advance was 40% of the value of the claim and it was paid within a deadline written into the ordinance: 10 working days from the transfer of the funds by the Ministry of Finance. The law raised the advance to 60%, but the new wording of Article 9(10)(a) of the two ordinances no longer contains any payment deadline. All that remains is the condition that payment be made on the basis of the supplier’s self-declaration.
The procedure published on 6 October 2026 partly restores that deadline, but it moves it onto a different reference point. For the 2025 scheme it reappears, in Article 4(2), as 10 working days „după asigurarea fondurilor necesare”, after the necessary funds have been secured, and not from the transfer by the Ministry of Finance, as it was before. For the 2022 scheme it does not reappear at all.
The penalty for late return is also new. Letter d) of Article 9(10) of both ordinances was introduced by Law no. 179/2026, and the procedure now applies it: interest and late-payment penalties calculated under Articles 174 and 176 of the Tax Procedure Code, on the amounts the supplier fails to return within 10 working days.
Finally, the way claims are filed has changed too. The order says expressly, in both chapters, that documents filed in hard copy are not taken into account. Under the old scheme, the rule was not written in this way.
Advantages and disadvantages
What it improves
- The steps are listed article by article, and for each one it is clear which institution carries it out: the administrative analysis at the ministries and the payments agency, the calculation and validation at the regulator, the funding of the accounts at the Ministry of Finance.
- The 10 working day deadline for the advance, lost when the ordinances were amended, comes back at least for the 2025 scheme.
- The two routes, household and non-household, are kept explicitly apart, including when the funding requirement is substantiated.
- The ban on filing on paper closes one route by which a claim could sit unprocessed for no clear reason.
- The budget revision clause openly acknowledges that the amounts approved for 2026 may not be enough, instead of leaving the problem unwritten.
What remains a problem
- Analysis, verification and validation, the three operations named in the title of the procedure, have no deadline at all.
- The three deadlines that bind the state start from the „securing of the funds” or from the transfer by the Ministry of Finance, moments that have no deadline of their own.
- For the scheme under Emergency Ordinance no. 27/2022, the payment of the 60% advance remains without any deadline.
- Interest and late-payment penalties apply only to the supplier that fails to return money in time, not to the state that pays late.
- Article 2 of the order says claims „depuse după data intrării în vigoare”, filed after the entry into force of Law no. 179/2026, while the procedure in the annex says „începând cu data intrării în vigoare”, from the date of entry into force, which leaves claims filed on 31 August 2026 itself in two possible regimes.
- The order was published after the 30 day deadline the law had given the two ministers for issuing it.
Practical advice
- If you are a supplier filing claims under both schemes, keep the records separate: Chapter II, the one for Emergency Ordinance no. 6/2025, gives you a 10 working day deadline for the advance, while Chapter III, for Emergency Ordinance no. 27/2022, gives you none.
- Do not file anything on paper. Both chapters state that claims and supporting documents filed in hard copy are not taken into account, so a claim sent that way does not exist for the institution.
- Send the self-declaration together with the reimbursement claim, using the template in Annex no. 3 to the ordinance you are relying on. Without it, the advance cannot be paid, because the law ties payment to precisely that declaration.
- Calculate the advance on the amount you can support with the documents uploaded to the regulator. The advance is paid on the figure claimed, but if validation comes out lower, the difference has to be returned within 10 working days of the communication, and after that deadline interest and penalties are added.
- Put the date on which the validated value is communicated in your calendar, not the date on which you received the money. The 10 working days for returning the money run from the communication.
- Do not leave the data entry to the end of the year: the final deadline for the data needed for reimbursement and settlement is 31 December 2026.
Frequently asked questions
Do I have to do anything if I am a household customer?
How long does it take a supplier to get the money?
Why 60% and not the whole amount?
What happens if the supplier has received more than it was entitled to?
Who decides, in the end, how much is paid?
What happens if there is no money in the budget?
From when does the procedure apply?
Errors and inconsistencies in the published text
- Article 2 of the order against Articles 2, 4 and 9 of the annexed procedure. The order says that the procedure applies to claims „depuse după data intrării în vigoare a Legii nr. 179/2026”, filed after the date of entry into force, while the annex says, in three places, „depuse începând cu data intrării în vigoare a Legii nr. 179/2026”, filed from the date of entry into force. The law itself, in Article IV(1), uses the second wording. For a claim filed on 31 August 2026 itself, the day the law entered into force, the two texts lead to different conclusions: the annex covers it, the body of the order leaves it out.
- Article 2 of the order against Article 7(1) of the procedure. The order refers, without any limitation in time, to claims filed under both ordinances, whereas Chapter III of the procedure applies only to claims „aferente consumurilor realizate în perioada 1 aprilie 2024-31 martie 2025”, that is consumption during that one year. A claim filed now for older consumption under the scheme of Emergency Ordinance no. 27/2022 falls within the procedure according to the body of the order, and is left without an applicable chapter according to the annex.
Editorial analysis
The procedure solves a real problem: Law no. 179/2026 raised the advance to 60% but deleted the payment deadline from the ordinances, and without an implementing act suppliers were left with a higher percentage and no time markers at all. The order brings a deadline back, of 10 working days, but ties it to the „securing of the necessary funds”, a phrase that does not denote a date, and it does so only in Chapter II. In Chapter III, for the same operation, the deadline is missing altogether. So we have a single act, with two almost identical chapters, treating the same payment differently without the text explaining why.
Counting the deadlines tells the rest. The procedure contains five deadlines, all of them of 10 working days. Three bind the state, and all three start from a moment that no provision dates: the „securing of the funds” in Article 4(2), the transfer by the Ministry of Finance in Articles 5(2) and 10(2). Two bind the supplier, and both start from the communication of the validated value, that is from an act the administration issues, at a moment of its own choosing. On top of that, interest and late-payment penalties appear once in the act and only against the supplier. The asymmetry is not a matter of nuance: the private party has a certain deadline that is certain to start, while the state has three deadlines that start when it decides.
The next observation comes out of the act’s own calendar. Article III of Law no. 179/2026 gave the two ministers 30 days from the entry into force of the law to issue the joint order. The law entered into force on 31 August 2026, so the deadline expired on 30 September 2026. The consultation of the National Energy Regulatory Authority, required by the same article, was completed on 29 September 2026, through Letter no. 138.271, that is one day before expiry. The order of the minister of energy was signed on 1 October, that of the minister of labor on 5 October, and publication took place on 6 October 2026, six days past the deadline. The administration that overran a 30 day deadline without consequence imposed, through the same act, a deadline of 10 working days on the supplier, with interest and penalties if it is exceeded.
The third element is the window that is left. Under Law no. 179/2026, the final deadline for entering the data needed for reimbursement and settlement is 31 December 2026, that is 86 days after the procedure was published. Into that interval have to fit the filing of claims, the administrative analysis, the verification and validation at the regulator, the substantiation of the funding requirement, the transfer from the Ministry of Finance and, possibly, a budget revision. Of all of these, the only stages with a deadline are the two payments. An implementing act issued six days late, 86 days from the end of the scheme, leaves little room for the steps nobody is timing.
Finally, the advance is calculated on the amount claimed by the supplier, not on the validated amount, and this is the only figure in the act that works in both directions. If validation comes out lower, the state takes its money back with interest. If it comes out higher, the supplier receives the difference, but only after a transfer that no deadline obliges to happen.
What should be changed
- A deadline for analysis, verification and validation. The three operations give the procedure its name and are the only ones without a clock. A deadline, even a generous one, would turn the chain into a predictable interval for the supplier.
- A dated reference point instead of the „securing of the funds”. Tying the 10 working days to the filing of the claim or to the validation of the value would make the deadline useful; as written, it starts when the administration gets round to it.
- The same deadline in both chapters. Extending the deadline in Article 4(2) to Article 9(2) as well would remove the difference in treatment between claims under the 2022 scheme and those under the 2025 scheme.
- Interest for late payment by the state too. Symmetry in Articles 5 and 10, modelled on letter d) introduced by Law no. 179/2026, would put the two parties in the same position when a deadline is missed.
- Aligning Article 2 of the order with the annex. Replacing „depuse după data intrării în vigoare”, filed after the date of entry into force, with „depuse începând cu data intrării în vigoare”, filed from the date of entry into force, would bring the order into line with its own annex and with Article IV(1) of the law.
- A rule for older claims under the 2022 scheme. Chapter III stops at consumption in the period 1 April 2024-31 March 2025, so claims for earlier periods need an express reference, otherwise they are left without a procedure.
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. 843 of 6 October 2026, pages 11-13 16 pages PDF, 116 KB the act starts on page 11
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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.