In brief
- The deadline for completing investments under the renewable self-consumption programme financed by the Modernisation Fund is now set at 31 December 2028. The date covers installation, commissioning and grid connection, not merely the signing of the contract.
- The guide no longer ties completion to a single deadline for the whole programme: each competitive bidding procedure launched by Romania’s Ministry of Energy will set its own completion date, which nevertheless cannot go beyond 31 December 2028.
- The amendment touches nine places in the guide, including the annexes with the funding application, the beneficiary’s declarations and the annual expenditure plan. Among other things, the beneficiary signs an undertaking to finance completion from its own resources if the project is not ready in time.
Published: Official Gazette of Romania (Monitorul Oficial) No. 633 of 31 July 2026
In force from: 31 July 2026
The programme that lets companies and institutions build their own renewable electricity capacity for their own consumption now has a clear cut-off date, repeated throughout the document: 31 December 2028. Through Order No. 765/2026, Romania’s Ministry of Energy amended the specific guide for the Modernisation Fund financing line dedicated to self-consumption, approved in 2024. It is the state’s second move in the same direction within a short period, after the law allowed quantitative offsetting of electricity produced with solar panels for household consumers, a sign that self-consumption policy is settling on two distinct layers: direct support for large investments and billing mechanisms for small ones.
The Modernisation Fund is a European instrument for financing the energy transition, and the self-consumption line operates under a state aid scheme approved by Order No. 355/2024 of the Minister of Energy. The specific guide, approved by Order No. 356/2024 and published in Official Gazette of Romania No. 387 and 387 bis of 25 April 2024, is the document that states concretely who may apply, which costs are reimbursed and how long the investment may take. It is precisely this last element that has now been rewritten.
The new wording in chapter 1 point 1.1 is the key mechanism: completion of the investments, meaning installation, commissioning and grid connection, must take place by the date set out in each competitive bidding procedure launched and published on the ministry’s website, and may not exceed 31 December 2028. In other words, the real deadline becomes variable from one call to another, but it has an absolute ceiling.
The order was signed on 24 July 2026 by the interim Minister of Energy, Ilie-Gavril Bolojan, and entered into force on publication, on 31 July 2026. Implementation falls to the General Investment Directorate within the Ministry of Energy.
What it changes in practice
The first effect concerns the calendar. An applicant filing a funding application now knows that the whole project timeline, from design to the commissioning acceptance report, must fit before 31 December 2028. The date does not refer to the end of construction works but to the moment when the installation is commissioned and connected to the grid, which also covers the waiting time for the distribution operator’s approvals.
The second effect is financial and concerns the eligibility period for expenditure. The amended guide states that only costs incurred and paid between the date the funding application is filed with the ministry and the completion date set in the bidding procedure, at the latest 31 December 2028, will be reimbursed. Design costs, meaning the pre-feasibility study, the feasibility study or the technical design, and the purchase of land may be incurred earlier, but they are not reimbursed from the Modernisation Fund. This follows from the “start of works” principle in Article 2 of Regulation (EU) No 651/2014, which makes state aid conditional on a genuine incentive effect.
The third effect concerns assumed risk. Annex No. 3 has been amended so that the beneficiary declares it will secure, from other lawfully constituted sources of financing, the money needed to complete the project if it is not fully implemented by 31 December 2028. Missing the deadline is therefore not only a reporting issue but a financial commitment the applicant signs at the filing stage.
The fourth effect is administrative. The annual expenditure plan in Annex No. 7 is now drawn up for an implementation period that closes in 2028, with columns from 2023 to 2028. Anyone whose financing schedule stretched beyond that horizon has to compress it.
What has changed compared with the previous situation
In the nine places now amended, the guide approved in 2024 contained references to a completion deadline that no longer matched the programme’s real calendar. Order No. 765/2026 aligns them all to the same reference point, 31 December 2028, and additionally introduces the notion of a deadline set per call for projects.
The change of logic matters. Previously an applicant looked at a date written in the guide. From now on it must look at two things at once: the date in the documentation of the competitive bidding procedure it enters, and the general ceiling in the guide. If the call says 30 June 2028, that is the date that counts for that applicant, even though the guide allows until the end of the year.
The place where the information is found has changed too. Specific completion dates are published on the Ministry of Energy’s website together with each procedure, not in the Official Gazette of Romania. For a potential beneficiary, that means monitoring the ministry’s page becomes part of preparing the file.
Nothing has changed regarding the eligibility of applicants, the aid intensity or the types of investment accepted. The order is strictly about the calendar, the eligibility period for expenditure and the forms that reflect them.
Advantages and disadvantages
What it improves
- It removes inconsistencies between the body of the guide and its annexes: the same date now appears in all nine places, which lowers the risk of a file being rejected over a contradictory deadline.
- It gives the ministry real flexibility: a call launched late can carry a tighter deadline and one launched early a more relaxed one, without amending the guide each time.
- It clarifies what completion means: installation, commissioning and grid connection, not merely acceptance of the works.
- It expressly settles the treatment of design costs and land purchase, an area where applicants frequently erred by assuming retroactive reimbursement.
What remains a problem
- The 31 December 2028 ceiling gets tighter with every month that passes. An industrial-scale self-consumption project needs permits, a grid connection approval and equipment deliveries, and upstream delays are not under the beneficiary’s control.
- The risk of overshooting falls entirely on the beneficiary, who signs an undertaking to finish the project from its own resources. For a small company or a local authority with a rigid budget, that commitment can be discouraging.
- A deadline that varies per call adds a source of uncertainty: until the documentation is published, the applicant does not know which date it is actually working towards.
- The order provides no extension procedure for objective causes, so an external administrative blockage translates directly into loss of funding.
Practical advice
- If you are preparing a funding application: build the activity schedule backwards from the end, not from the start. Set the commissioning acceptance at least three months before 31 December 2028 and only then arrange the upstream stages.
- If you already have a project under implementation: check whether your schedule extends beyond 2028 in any document, including the annual expenditure plan in Annex No. 7. The columns now run to 2028, so a plan with expenditure in 2029 is no longer compliant.
- If you have already commissioned feasibility studies or bought land: do not include those amounts in the costs claimed for reimbursement if they were paid before the application was filed with the ministry. They are permitted but not eligible.
- If you are waiting for a call to open: watch the Ministry of Energy’s website, not only the Official Gazette of Romania. The completion date applicable to your call is published in the documentation of the competitive bidding procedure.
- If you are a municipality, a hospital or another public institution: prepare in good time the decision to cover any shortfall from your own budget, required by the declaration in Annex No. 3. Approving such a budget commitment takes time, and the declaration is filed together with the application.
- If you are negotiating with an equipment supplier: write delivery deadlines and penalties into the contract, aligned with the project completion date. In your relationship with the funder, the delay risk stays with you.
Frequently asked questions
Which funding programme does this order affect?
What is the completion deadline now?
Which costs are eligible for reimbursement?
May I start the design work before filing the application?
What happens if I do not finish the project by 31 December 2028?
Why is the deadline not the same for every project?
From when do the amendments apply?
What is the “start of works” principle invoked in the order?
How many provisions of the guide were amended?
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. 633 of 31 July 2026 16 pages PDF, 338 KB the act starts on page 5
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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.
