In brief

  • The investment that funds contracts for difference loses 2,675,000 euro. The line „I8. Allocation of contracts for difference”, in component C16 RePowerEU, drops from 62,037,880 to 59,362,880 euro in the loan part of the National Recovery and Resilience Plan (NRRP). That is a cut of 4.31% from what the line held up to and including 18 October 2026.
  • Exactly the same amount lands on a reform that stood at zero euro. The reform „R6. Decarbonisation of the heating and cooling sector”, in component C6 Energy, moves from 0 to 2,675,000 euro. Both lines are the responsibility of the Ministry of Energy, so the money does not leave the ministry that loses it.
  • Not one extra euro is spent. The amount the annex gives the Ministry of Energy out of the loan stays at 149,312,923 euro, and the total repayable financial support across the whole plan stays at 6,540,805,186 euro. We added the column up line by line: the two changes cancel each other out to the last euro.
  • The move comes 11 days before the date by which the coordinators must have paid everything. Law no. 183/2026 on the operational and financial closure of the National Recovery and Resilience Plan gives them until 30 October 2026 to verify, authorise and pay the final transfer requests, and until 31 October 2026 to classify every reform as completed, not completed or removed from the plan.
Act: Government Decision no. 837/2026 amending the annex to Government Decision no. 1.235/2022 on the approval of the distribution of the budget for the reforms and investments financed through Romania’s National Recovery and Resilience Plan for each reform and/or investment coordinator
Published: Official Gazette of Romania (Monitorul Oficial), Part I, no. 871 of 19 October 2026, pages 12-13
Who it affects: the Ministry of Energy, the only coordinator touched by the two rewritten rows; the beneficiaries of projects under component C6 Energy, reform R6, and under component C16 RePowerEU, investment I8, among them district heating operators and the producers holding contracts for difference; the Ministry of Investments and European Projects, the national coordinator of the plan, and the Ministry of Finance, which countersigns the decision
Takes effect: 19 October 2026, the date of publication, because the decision does not set a later date anywhere in its text, and Article 12 paragraph (3) of Law no. 24/2000 on the rules of legislative technique for drafting normative acts places into force on the date of publication those normative acts that do not fix a deadline of their own

The table that says which institution answers for each slice of the money in the National Recovery and Resilience Plan has been given two new rows, both of them at the Ministry of Energy, and a single figure that travels from one to the other: 2,675,000 euro. Government Decision no. 837 of 16 October 2026, published in the Official Gazette of Romania, Part I, no. 871 of 19 October 2026, amends two entries in the annex that the Government rewrote in full on 21 August 2026. Nothing else in the annex is touched.

The two entries are rows 32 and 36 of section B of the annex, that is, of the repayable financial support part, the loan component of the plan. Row 32 is the reform „R6. Decarbonisation of the heating and cooling sector”, in component C6 Energy. Row 36 is the investment „I8. Allocation of contracts for difference”, in component C16 RePowerEU. The first moves from 0 to 2,675,000 euro, the second drops from 62,037,880 to 59,362,880 euro. The decrease and the increase are equal to the last euro, and both lines belong to the same coordinator, the Ministry of Energy.

What a „reform and/or investment coordinator” is deserves saying plainly, because it is the word the whole annex is built around. The Recovery and Resilience Plan is not a single programme with a single cash desk, but a list of reforms, marked with R, and of investments, marked with I, grouped into components running from C1, water management, to C16, RePowerEU. For every line on the list there is an institution that answers for it: it signs the contracts with the beneficiaries, verifies and authorises payments, and reports the achievement of targets and milestones to the Ministry of Investments and European Projects, which is the national coordinator of the plan. That institution is the coordinator of the line. The amended annex shows 21 such coordinator entries, from ministries through to the National Agency of Civil Servants and the National Authority for Research, and three of them are shared between two institutions.

This is also where the answer lies to the question any reader asks on seeing a decision that changes amounts: no, this is not extra money. The annex does not approve expenditure and does not open budget appropriations. It divides up, by coordinator and by line, a sum already negotiated with the European Commission and already written into the implementing decision of the Council of the European Union. Moving 2,675,000 euro from one line to another changes who is entitled to commit and settle that money, not how much Romania receives.

On 20 October 2026 Parliament gave its confidence to the Niculescu Government and approved the Governing Programme 2026-2028 and its 370 measures.

What it changes in practice

A reform with no money gets money. Up to and including 18 October 2026, reform R6, the decarbonisation of heating and cooling, appeared in the annex with a zero allocation and did not appear at all in section A, the non-repayable financial support part. In table terms it was an undertaking assumed without a funding line of its own. From 19 October 2026 it holds 2,675,000 euro out of the loan.

The investment for contracts for difference falls by 4.31%. The line drops from 62,037,880 to 59,362,880 euro. Measured against everything the Ministry of Energy holds in the loan component, this line falls from 41.55% to 39.76%, losing 1.79 percentage points of its share.

The Ministry of Energy’s total does not change. The seven lines the ministry holds in section B added up, before the amendment, to 149,312,923 euro: 897,300 for the hydrogen reform, 86,377,743 for gas-fired combined heat and power, 62,037,880 for contracts for difference and zero for the other four. After the amendment, the same seven lines still give 149,312,923. That is why the decision does not touch the total row either: it had nothing to change there.

The plan’s total does not change either. The sum of all the lines in section B remains 6,540,805,186 euro, and the distribution as a whole remains 20,106,860,700 euro, of which 13,566,055,514 is non-repayable support and 6,540,805,186 repayable support. We checked by adding the column up before and after the amendment.

No other coordinator is touched. The act does not take money from Transport, from Development or from the Environment, and it gives money to no one outside the Ministry of Energy. Rows 32 and 36 are the only ones rewritten, and the rest of the annex, with its 124 lines in section A and 68 in section B, stays exactly as it was published on 21 August 2026.

The figures are net of VAT. The column is headed „Financial allocation (euro) excluding VAT”, so the national budgets of the projects, which include the tax, are larger than the amounts in the annex. The wording is not changed by this decision, but it holds for the two new rows as well.

What has changed compared with the previous situation

The replaced version lasted 59 days. Rows 32 and 36 in the form that applied until 19 October 2026 came from Government Decision no. 637/2026, published in the Official Gazette of Romania, Part I, no. 693 of 21 August 2026, which had replaced the annex in full. There were 59 days between the two interventions. The underlying annex, the one approved by Government Decision no. 1.235/2022, is published in the Official Gazette of Romania, Part I, no. 990 of 12 October 2022 and has been amended several times since, among others by Government Decision no. 1.010/2025, which removed a number of investments from funding.

The method is not the one used in August 2026. The August decision replaced the annex outright, so the previous version could no longer be relied on even in part. Decision no. 837/2026 does the opposite: it leaves the annex in place and rewrites exactly two rows, identified by their position in section B. That is the difference between a general reshuffle and a pinpoint correction.

There is one fewer line at zero euro. In section B, out of 68 content lines, 23 were entered with a zero allocation, close to a third. At the Ministry of Energy, four of the seven lines stood at zero: the reform for energy efficiency in industry, the decarbonisation of heating and cooling, green hydrogen capacities and energy efficiency in the industrial sector. Three remain as of 19 October 2026.

The context has changed more than the figures. Between the August 2026 annex and the October 2026 decision came Law no. 183/2026 on the operational and financial closure of the National Recovery and Resilience Plan, published in the Official Gazette of Romania, Part I, no. 721 of 28 August 2026. Article 8 paragraph (1) of the law requires beneficiaries to have completed all activities by 31 August 2026 at the latest, and paragraph (2) forbids coordinators from authorising for payment any expenditure on activities carried out after that date. Decision no. 837/2026 therefore reshapes a distribution whose implementation period had already ended.

Advantages and disadvantages

What it improves

  • The correction is made with the exact amount and with no effect on anyone else. The rows offset each other to the last euro, the ministry’s total is unchanged, and no other coordinator has to redo its planning because of this decision.
  • A reform that stood at zero receives a funding line before the deadline by which it has to be classified. Article 21 paragraph (1) of Law no. 183/2026 requires coordinators to place every reform, by 31 October 2026, in one of the categories „completed”, „not completed” or „removed from the plan”. One with real expenditure and no allocation would have been hard to close off in the accounts.
  • The method chosen, rewriting two rows, is easier to follow than replacing the annex in full. The reader sees at once what has changed, instead of comparing two tables of more than 200 rows.
  • The money stays within the same funding component, the repayable one, so no question arises about turning a loan into a grant or the other way round, which would have required a different procedure.

What remains a problem

  • The decision does not say why. It has no explanatory preamble, it refers to no European decision, and it names neither the project nor the expenditure that called for the 2,675,000 euro. The only legal basis invoked is Article 108 of the Constitution, that is, the Government’s general power to issue decisions.
  • The rows are identified by numbers the annex does not display. The published table has no numbering column, so anyone wanting to check that row 32 really is reform R6 has to count the entries in section B by hand, total rows included. We did the counting: it matches for both entries, but the fact that it had to be done is a drafting problem.
  • Investment I8 is the only one of those touched that has beneficiaries outside the administration. Contracts for difference are a mechanism through which the state guarantees a producer a fixed price for the energy it delivers, and a cut in the funding line, however small, is a signal to anyone building a business plan on that mechanism. The decision does not say whether the cut is final or is an end-of-plan reconciliation.
  • The timing is late measured against the administration’s own deadlines. Beneficiaries had to submit their final transfer requests by 30 September 2026, and the national coordinator had to send payment request no. 6 to the European Commission by 30 September 2026 as well. The internal distribution is being corrected 19 days after both of those deadlines.

Practical advice

  1. If you hold a funding contract under investment I8 in component C16 RePowerEU, ask the Ministry of Energy in writing to confirm that the amount in your contract fits within the new ceiling of 59,362,880 euro. The cut applies at line level, not at contract level, but it is the line that limits what can be committed.
  2. If you have a project reported under reform R6, the decarbonisation of heating and cooling, check whether your expenditure has so far been settled from another line. The new allocation of 2,675,000 euro may mean that the project’s funding source changes in the ministry’s records, even if the subject of the contract stays the same.
  3. Watch the 30 October 2026 deadline closely. Article 15 paragraph (4) of Law no. 183/2026 requires coordinators to verify, authorise and pay by that date the transfer requests already submitted, and a change of budget line in the third week of October 2026 leaves little room for administrative corrections.
  4. If you are a district heating operator with a gas-fired cogeneration investment, read Article 15 paragraph (5) of the same law before assuming that the new money covers your commissioning tests. The law allows the contract to be extended for tests that depend on the start of the heating season, but it says explicitly that such expenditure is borne by the budget of the beneficiary authority and is not settled from the plan’s funds.
  5. For the finance departments of public institutions: update the annex in your records with the version of 19 October 2026 before entering into any new legal commitment on the two lines. The annex in force is no longer the one published on 21 August 2026.
  6. If you want to check the figures yourself, count the entries in section B of the annex starting with the first row after the heading „B. Repayable financial support” and include the total rows in the count. Row 32 should be reform R6 of the Ministry of Energy, and row 36 investment I8 in component C16.
  7. Do not read the figure „0” in the annex as an abolition. A line with a zero allocation remains a reform or an investment assumed in the plan, with targets and milestones of its own, merely without an amount distributed under that funding component. Reform R6 was in exactly that position and received money without ever having been taken out of the plan.

Frequently asked questions

Does Romania receive more money under this decision?
No. The total amount distributed remains 20,106,860,700 euro excluding VAT, and the loan part remains 6,540,805,186 euro. The decision moves 2,675,000 euro from one line to another, inside the same ministry. The annex does not approve expenditure; it says who answers for each amount already negotiated.
What is a reform and/or investment coordinator?
It is the institution that answers for a line in the plan: it signs the contracts with the beneficiaries, verifies and authorises payments, and reports the achievement of targets and milestones to the national coordinator, which is the Ministry of Investments and European Projects. The amended annex shows 21 coordinator entries, three of them shared between two institutions.
Does this mean contracts for difference have been abandoned?
No. The line that funds them from the loan component falls by 4.31%, from 62,037,880 to 59,362,880 euro, but it stays in the annex, with the same coordinator and the same component. The decision leaves the investment in place and says nothing about the scheme itself.
Why is the money being moved right now?
The decision does not explain. The only legal basis invoked is Article 108 of the Constitution of Romania, republished, that is, the Government’s general power to issue decisions. The date of publication, 19 October 2026, falls 11 days before the deadline by which coordinators must have paid the final transfer requests and 12 days before the deadline by which every reform has to be classified.
How do I find rows 32 and 36 if the annex is not numbered?
Count the entries in section B in the order in which they appear, starting from the first row after the section heading and including each coordinator’s total rows. The thirty-second row is reform R6 of the Ministry of Energy, and the thirty-sixth is investment I8 in component C16 RePowerEU.
Why does reform R6 appear only in the loan section?
Because in section A, the non-repayable financial support part, there is no entry under that name. The Ministry of Energy has six lines there, adding up to 690,500,000 euro, and none of them is the decarbonisation of heating and cooling. The decarbonisation of heating and cooling appears once in the whole annex, in section B.
Does anything change for beneficiaries under other ministries?
No. The decision rewrites two rows, both of them belonging to the Ministry of Energy. The rest of the annex stays in the form published on 21 August 2026, including all the other coordinators’ totals.
From when do the new amounts apply?
From 19 October 2026, the date of publication in the Official Gazette of Romania. The act does not set a later date, and Article 12 paragraph (3) of Law no. 24/2000 places into force on the date of publication those normative acts that do not fix a deadline of their own.
Do the amounts in the annex include VAT?
No. The column is headed „Financial allocation (euro) excluding VAT”, so a project’s national budget, which includes the tax, is larger than the figure in the table.

Editorial analysis

The decision settles something real and does so with a single figure, which is a rare quality in an annex of more than 200 rows. Reform R6, the decarbonisation of heating and cooling, sat in the table with a zero allocation, and Law no. 183/2026 requires every reform to be classified, by 31 October 2026, as completed, not completed or removed from the plan. A reform with real expenditure and no funding line of its own does not fit cleanly into any of those three boxes. The 2,675,000 euro give it one.

What does not show when you read the act from start to finish is that the amount is neither round nor drawn from some general budget: it is taken, to the last euro, from the one line of the Ministry of Energy that had anything to give. Of the seven entries the ministry holds in the loan part, four stood at zero, one is the hydrogen reform with 897,300 euro, another is gas-fired combined heat and power, with 86,377,743. That left contracts for difference, with 62,037,880. We added the column up before and after: 149,312,923 euro in both cases. This is not an energy policy decision, it is an accounting adjustment made with the money that was within reach, and the fact that the decision does not say so makes it look larger than it is.

The second observation shows up only when you set the decision against the administration’s own calendar. The projects’ implementation period ended on 31 August 2026, beneficiaries had to submit their final transfer requests by 30 September 2026, and the national coordinator had to send payment request no. 6 to the European Commission by 30 September 2026 as well. The internal budget distribution is being corrected only on 19 October 2026, that is, 49 days after spending stopped and 19 days after the amounts were already known and reported. The administration set firm deadlines for the beneficiaries and ran three weeks past them for its own records.

The third point concerns the way the act is written. The rows are identified by the numbers 32 and 36, yet the published annex has no numbering column, so anyone wanting to check has to count the entries by hand, total rows included, which look different from the rest and which it is natural to skip. We did the counting and it matches for both rows, which means the drafting is correct, not that it is easy to verify. In an annex where 23 of the 68 lines in section B are entered at zero euro, a numbering column would cost a day’s work and would spare every future amendment this counting exercise.

What should be changed

  • Number the rows of the annex. A column showing the entry number, added at the first republication of the annex, would make any pinpoint amendment verifiable at first sight and would remove the risk that a reader who counts differently from the drafter concludes that some other line has changed. It is the only step on this list that calls for no substantive decision.
  • State in the decision where the money comes from and what it is for. A paragraph saying that the amount is reallocated from investment I8 to reform R6 would turn an act that looks like a cut to contracts for difference into what it actually is, an internal offset with a zero balance. Without it, the only way to find this out is to add the column up.
  • Publish the consolidated version of the section concerned together with the amendment. For a beneficiary, a two-row table torn out of context says nothing about how much is left under the component. An annex with section B up to date, even in a separate file, would spare every finance department the job of reconstructing the table by hand from three successive decisions.
  • Align the dates of amendments with the deadlines in Law no. 183/2026. A decision that changes the budget line 11 days before the coordinators’ final payment deadline leaves too little room for any correction. Distribution changes made during the closure period should be adopted before the deadline for submitting final transfer requests, not after it.
  • Mark explicitly in the annex the difference between a line with a zero allocation and one removed from the plan. Law no. 183/2026 has the category „measures removed from the NRRP”, and the annex does not reflect it in any way: both the reform taken out of funding and the one waiting for money look the same, carrying the figure zero. A status column would answer the question every reader asks when faced with the 23 zeros in section B.

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. 871 of 19 October 2026, pages 12-13 16 pages PDF, 156 KB the act starts on page 12

Open the official PDFDownload the PDF

The viewer is not shown on small screens. Use the buttons above to open or download the file.

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