In brief
- The Ministry of Transport published on the same day five orders, no. 817-821/2026, amending the annexes of five State aid schemes financed from the Modernisation Fund. All five receive the same clause on the expiry of the European regulation they rest on, at 31 December 2026, that is 120 days after publication.
- The heaviest intervention concerns the recharging station schemes: at „e-Mobility RO” and at „e-MOVE RO” Article 11 is rewritten in full. A power exception of 2,800 kW and 1,400 kW appears for the national roads due to be replaced by motorways, and the ban on siting „e-MOVE RO” stations less than 3 kilometres from a motorway exit disappears from the text.
- At the scheme for maritime and air transport only the calculation reference changes: the budget stays at 299,000,000 euro and the ceiling at 30,000,000 euro per company, but the lei equivalent is worked out at the InforEuro exchange rate for June 2026, not the one for July 2025.
Published: Official Gazette of Romania (Monitorul Oficial) no. 739 of 2 September 2026
In force from: 2 September 2026
Five schemes through which transport companies can take European money for electric vehicles and recharging stations were amended on the same day, by five orders published one after another. Orders of the acting Minister of Transport and Infrastructure no. 817, 818, 819, 820 and 821 of 1 September 2026 appeared in Official Gazette of Romania no. 739 of 2 September 2026. Four of them touch schemes we have already written about, among them the 299 million euro scheme for recharging stations on motorways and national roads, relaunched on 7 August 2026. The present orders do not replace anything in full, they rewrite articles.
The five schemes share the same wallet. The money comes from the Modernisation Fund, a European instrument set up by Article 10d of Directive 2003/87/EC, the directive that created the greenhouse gas emission allowance trading system. European companies that pollute have to buy allowances for every tonne of carbon dioxide emitted. Part of the money raised from selling those allowances is set aside for ten member states with lower incomes, Romania among them, so that they can modernise their energy systems and cut emissions. The Fund operates over 2021-2030, and in Romania the framework for managing it is set by Government Emergency Ordinance no. 60/2022. This is not state budget money and it is not money from the National Recovery and Resilience Plan.
The second thing the five orders have in common is the reason they appear now. All five rewrite paragraph (2) of Article 12 of their schemes, and the new text says the same thing in all of them: Regulation (EU) no. 651/2014, the European act that allows a state to grant aid without asking the European Commission for approval every time, expires on 31 December 2026. After that date the ministry undertakes to align the scheme with the regulation that will take its place and to seek a fresh opinion from the Competition Council. If it does not, no further contracts can be concluded after the expiry of the transitional period provided by the regulation, and if the alignment is late, contracting is blocked until the harmonised text is adopted.
The rest of the amendments differ from one scheme to another. Two orders change a single sentence. One changes three exchange rate figures. Two rewrite whole articles on who is eligible, what power a station has to have and where it may be sited. For a company preparing its application, the difference between these categories is the difference between a footnote and a redesign of the project.
In the same week the transport sector received another measure: compensation of 43 bani a litre for hauliers, for as long as the diesel excise duty stays cut by 25%.
For the sister scheme, financed from the same Modernisation Fund, the full applicant guide was published through MTI Order no. 824/2026.
What it changes in practice
Each order works on its own scheme. We take them one at a time, in the order of the Official Gazette of Romania.
Order no. 817/2026: the „e-DRIVE” scheme, for company fleets and passenger transport
The „e-DRIVE” scheme was approved by MTI Order no. 2.291/2025, published in Official Gazette of Romania no. 14 of 13 January 2026, and finances the replacement of company vehicle fleets, as well as vehicles for road passenger transport. It is the only one of the five that combines State aid with de minimis aid, that is small amounts of aid, below the threshold at which the European rules consider competition to be distorted.
Order no. 817/2026 amends a single paragraph, Article 12(2), and gives it the clause on the expiry of the European regulation. The detail that matters is that the text does not speak about the scheme as a whole, but about „measure 2 of the present scheme”. The alignment undertaking and the ban on signing contracts after the transitional period concern only that measure. The explanation lies in the structure of the scheme: the de minimis part rests on Regulation (EU) no. 2.831/2023, which does not expire at the end of 2026, so it does not need the same safety clause. For an applicant, the practical conclusion is that the contracting blockage in 2027 threatens only the State aid component, not the de minimis one.
Nothing else changes at „e-DRIVE”. The eligibility conditions, the ceilings and the calendar remain those of the previous version.
Order no. 818/2026: the „e-Mobility RO” scheme, stations on motorways and national roads
This is the second largest of the five interventions, with six amendments. The scheme was approved by MTI Order no. 1.319/2025, published in Official Gazette of Romania no. 766 of 18 August 2025, and its annex was replaced in full by MTI Order no. 746/2026 of 7 August 2026. The text amended now is the one that is three weeks old.
The first amendment touches two definitions in Article 6(1). Letter (t) now defines a recharging point as one „with an output power equal to or greater than 22 kW”. Below that threshold, a point does not count. Letter (v) redefines the „site”: on motorways and express roads these are the public service areas, the fuel stations and the filling stations, while on national roads it is the place for which the beneficiary proves a right of use. It is a distinction with a direct effect on the application, because on a motorway you cannot pick any piece of land you like.
The second amendment rewrites Article 8 and limits submissions: in each competitive procedure, a potential beneficiary may submit a single project for each sub-measure, and the project may include one or more sites. Anyone who planned several separate applications in the same call has to merge them.
The third amendment, at Article 10(1)(g), ties the condition of not being an undertaking in difficulty to the definition in Article 6(1)(r), instead of repeating it.
The fourth amendment is the heavy one: Article 11 is rewritten in full, with ten paragraphs. Paragraph (1) lists thirteen eligibility conditions, from letter (a) to letter (m). The implementation period has to fall between the date of submission and a completion date that cannot go beyond 30 June 2030, a deadline repeated at letter (l) as well. The project has to be on Romanian territory, to contain an opportunity analysis, to observe the DNSH principle, that is the European „do no significant harm” rule on the environment, and the equipment has to be new and of the latest generation at the time of application. Letter (j) limits siting to the network of motorways, express roads and main national roads administered by the National Company for Road Infrastructure Administration, with the map of eligible roads annexed to the applicant’s guide. Letter (m) requires proof of a prior access agreement from the road administrator, obtained before submission.
Paragraphs (4) to (7) set the power thresholds, and that is where the real novelty appears. For heavy vehicles, a site has to have at least two points of 350 kW each and a total installed and drawn power of at least 3,600 kW on the TEN-T core road network or 1,500 kW on the comprehensive network. Paragraph (5) introduces an exception that did not exist before: on the sections of national road within the TEN-T network that are due to be replaced by motorways or express roads, with a works contract signed or a procurement procedure under way, the threshold falls to 2,800 kW with two points of 350 kW on the core network and to 1,400 kW with a single point of 350 kW on the comprehensive network. For light vehicles, paragraph (6) requires two points of 150 kW and at least 600 kW installed. Each point has to have at least one CCS Combo 2 connector, the standard that ensures any electric car can charge there.
Paragraph (2) keeps the two sub-measures: sub-measure 1 for plain recharging infrastructure, sub-measure 2 for the integrated project that adds on site renewable energy production and storage. Under sub-measure 2 only projects including all the components are eligible, and the battery has to absorb annually at least 75% of the energy produced by the directly connected installation. Paragraph (8) requires permanent and non-discriminatory access, 24 hours a day, 7 days a week, including on tariffs, and prices for users other than the beneficiary have to be market prices. Paragraph (10) adds a recurring obligation: an annual energy audit, drawn up by staff authorised by the National Energy Regulatory Authority, throughout the durability period of the project.
The sixth amendment, at Article 22(4), is the one that can stop a signature. The beneficiary has to make available to the ministry, before the financing contract is signed, the solution study, the solution sheet or the technical connection approval, updated as the case may be. The text is categorical: „In the absence of these documents, the financing contract cannot be signed.” The technical connection approval is obtained from the electricity distribution operator and is not issued overnight.
Order no. 819/2026: zero emission vehicles for freight, rail, sea and inland waterways
The scheme approved by MTI Order no. 756/2025, published in Official Gazette of Romania no. 723 of 4 August 2025, finances the purchase of zero emission vehicles for road and rail freight transport and for maritime and inland waterway transport. It is the 299 million euro scheme for lorries, locomotives, ships and barges, with a ceiling of 18 million euro per undertaking.
Order no. 819/2026 makes a single amendment, at Article 12(2), giving it the same clause on the expiry of Regulation (EU) no. 651/2014. It touches neither the budget, nor the sub-measures, nor the eligibility conditions. It is the second intervention on this scheme in less than two weeks, after Order no. 794/2026 of 25 August 2026, which had changed the conversion rate.
Order no. 820/2026: underperforming equipment in maritime and air transport
The scheme approved by MTI Order no. 755/2025, published in Official Gazette of Romania no. 716 of 1 August 2025, finances the replacement of machinery and equipment that consume too much energy in maritime and air transport with zero emission equipment, plus the vehicles providing services ancillary to rail and maritime transport. This means port cranes, forklifts, airport tugs, everything that moves cargo in a port or on an airport apron.
Order no. 820/2026 brings four amendments, three of which are the same thing repeated: a change in the reference month of the InforEuro exchange rate, from July 2025 to June 2026. The InforEuro rate is the monthly rate published by the European Commission for converting sums from euro into national currencies in European funded programmes.
- Article 11(1)(l): the value of the aid applied for does not exceed 30 million euro per undertaking, the lei equivalent being calculated at the June 2026 rate. The sum in euro stays the same.
- Article 13(1): the budget of the scheme remains 299,000,000 euro, non-repayable amounts from the Modernisation Fund, allocated in several successive competitive procedures until exhausted, but the lei equivalent is calculated at the June 2026 rate.
- Article 16(1): the value of the aid cannot exceed 30,000,000 euro per beneficiary, the lei equivalent being calculated at the June 2026 rate.
The fourth amendment is the clause on Regulation (EU) no. 651/2014, at Article 12(2).
The practical effect is limited, but it is not nil. Any project budget calculated in lei on the July 2025 rate has to be redone. The order does not give the value of the June 2026 rate, so the applicant has to look it up on the European Commission website.
Order no. 821/2026: the „e-MOVE RO” scheme, stations off the CNAIR network
This is the most substantial intervention. The scheme was approved by MTI Order no. 1.318/2025, published in Official Gazette of Romania no. 789 of 25 August 2025, and its annex was replaced in full by MTI Order no. 755/2026 of 10 August 2026, with a budget of 262 million euro. „e-MOVE RO” finances stations off the network administered by CNAIR: in towns, in logistics parks, at company premises, in airports. Order no. 821 does not merely amend, it also supplements, with six interventions.
The first rewrites Article 2(3) and redefines the playing field: the scheme addresses infrastructure installed „on roads in Romania other than those on the national network of motorways, express roads and TEN-T national roads administered by the National Company for Road Infrastructure Administration”.
The second adds two new definitions to Article 6. Letter (ț) takes over the 22 kW threshold for the recharging point, as at „e-Mobility RO”. Letter (u) defines for the first time infrastructure that is not accessible to the public: infrastructure used mainly by the beneficiary and, as the case may be, by its employees, its external contractors or its suppliers, without being made available to the general public. The definition matters because the scheme also finances fleet stations, not only public ones.
The third rewrites Article 11 in full, with six paragraphs. Paragraph (1) lists sixteen conditions, from (a) to (p). The completion deadline is again 30 June 2030, at letters (e) and (n). Letter (o) sets the ceiling: the value of the aid applied for does not exceed 25 million euro per undertaking across all competitive bidding sessions, that is cumulatively, not per session. Letter (k) states that the infrastructure must not be on the network of motorways, express roads and TEN-T national roads administered by CNAIR. Letter (l) declares eligible the infrastructure inside airport perimeters, regardless of siting on the CNAIR network or of distance from the nearest exit of a TEN-T road.
Paragraph (2) rearranges the three sub-measures. Sub-measure 1 finances recharging infrastructure, for the applicant’s own fleet, for the public or for both, including the connection works and the user installation. Sub-measure 2 adds on site renewable energy production and storage, for fleet infrastructure, with a limit: the capacity of the production installation must not exceed the maximum nominal useful power of the recharging infrastructure it is connected to. Sub-measure 3 does the same for publicly accessible infrastructure, but with a wider limit: the production capacity may exceed by at most 40% the maximum nominal useful power of the infrastructure. In both cases, the storage component has to absorb annually at least 75% of the energy produced.
Also under paragraph (2), letter (d) keeps the rule for airports: sub-measures 1 and 2 also cover the purchase of electric ground power units for aircraft, known as GPUs, and for each electric unit purchased the applicant is obliged to scrap one with a combustion engine, within 60 days of the new one being put into service.
Paragraph (3) sets the minimum requirements for public stations: at least two direct current points of 150 kW and at least one high power point of 350 kW, where the opportunity analysis justifies it, with support for smart recharging and with acceptance of the payment instruments widely used in the Union, including electronic payment at the terminal. Paragraph (4) requires 24 hour access and market tariffs. Paragraph (5) requires that, at mixed stations, the points reserved exclusively for the applicant’s own fleet be shown separately in the opportunity analysis and carry no payment instruments. Paragraph (6) adds the annual energy audit throughout the durability period.
The fourth intervention is the clause on Regulation (EU) no. 651/2014, at Article 12(2). The fifth rewrites Article 18(2)(c), the list of eligible expenditure under sub-measure 3, and specifies that it includes the cost of the works that remain the property of the beneficiary for the connection installation and the user installation. The wording has a budget consequence: connection works that pass into the ownership of the distribution operator do not count as eligible expenditure.
The sixth amends the scoring formula in the annex to the scheme, in the section „For sub-measure 3”, point 1. The new text states that the recharging infrastructure installation component represents 100% of the total selection criteria, and that ranking is done on the aid applied for relative to the installed power, in euro per kilowatt. Whoever asks for least receives 100 points, whoever asks for most receives zero, and the rest are interpolated linearly. Under the published formula, with A the lowest aid applied for per kW, B the highest and X the bid being assessed, the score is 100 multiplied by the ratio of X minus B to A minus B. At X equal to A the result is 100, at X equal to B the result is zero. The formula closes correctly. A second pair of guides from the Modernisation Fund followed in September 2026, for public entities rather than transport: 650 million euro for panels and storage at town halls, schools and hospitals.
What has changed compared with the previous situation
The conversion rate at the maritime and air scheme. In the version of 1 August 2025, Article 13(1) of the scheme approved by Order no. 755/2025 fixed the conversion of the 299,000,000 euro budget at the InforEuro rate for July 2025, and Article 16(1) used the same reference for the ceiling of 30,000,000 euro per beneficiary. The sums in euro remain unchanged. Only the reference month changes, becoming June 2026. It is the same operation the ministry had carried out on 25 August 2026 at the sister scheme for lorries and ships, by Order no. 794/2026.
The 3 kilometre exclusion zone disappears from „e-MOVE RO”. In the version that entered into force on 10 August 2026, the scheme banned siting stations not only on the roads administered by CNAIR, but also less than 3 kilometres by road from the nearest motorway or express road exit, with airports as an exception. The Article 11 rewritten now no longer contains this distance. Letter (k) is confined to the ban on siting on the TEN-T network administered by CNAIR. For an operator, that opens up precisely the commercial locations at road junctions, which were previously off limits.
Who falls under the ban changes too. The previous version excluded main national roads administered by CNAIR. The new version excludes TEN-T national roads administered by CNAIR. That is not the same thing: a main national road that is not on the TEN-T network now falls outside the ban.
The weight of the renewable energy component in the score. In the version of 10 August 2026, under sub-measure 3 the final score was calculated as the average of the scores obtained on the two components of the project, the recharging infrastructure and the renewable energy. Point 1 as amended now states that the infrastructure installation component represents 100% of the selection criteria. The order does not say what happens to the renewable energy component in the new weighting.
A power exception appears for roads under construction. The thresholds at „e-Mobility RO” were 3,600 kW on the TEN-T core network and 1,500 kW on the comprehensive one, with no nuance. The new paragraph (5) introduces an intermediate category: sections of national road due to be replaced by motorways or express roads, where a works contract has already been signed or a procurement procedure is under way. There the thresholds fall to 2,800 kW and 1,400 kW.
The number of applications per call is capped at „e-Mobility RO”. The rewritten Article 8 allows a single project per sub-measure in each competitive procedure, with one or more sites within the same project.
Nothing changes for applications already submitted. None of the five orders contains transitional provisions. There is no article saying what happens to applications under assessment, to signed contracts or to projects being implemented. All five end with the standard formula, „the present order is published in the Official Gazette of Romania, Part I”, with no deferred date, so they apply from 2 September 2026. The usual rule in competitive procedures is that assessment follows the conditions in force at the date of submission, but the schemes say so through the applicant’s guide, not through these orders.
Advantages and disadvantages
What it improves
- The 2,800 kW and 1,400 kW exception opens up financing on sections of national road where nobody would have invested in 3,600 kW knowing that the road is due to be replaced by a motorway.
- Lifting the 3 kilometre exclusion zone at „e-MOVE RO” frees up the commercial locations near road junctions, exactly where traffic justifies a station.
- The definition of infrastructure that is not accessible to the public, new at „e-MOVE RO”, removes the ambiguity around fleet stations and gives them a clear basis for financing.
- The one project per sub-measure rule at „e-Mobility RO” simplifies assessment and stops a company from clogging a session with ten parallel applications.
- The sums in euro change nowhere. No scheme loses budget and no ceiling is lowered, so an application already built on the substance remains valid.
- The obligation to produce the technical connection approval before the contract is signed weeds out projects that cannot be connected to the grid, a frequent cause of failure in implementation.
What remains a problem
- All five schemes tie their future to a European regulation that expires 120 days after publication, and no order says how long the transitional period it refers to lasts.
- The annual energy audit, now required at both station schemes throughout the durability period, is a recurring cost that does not appear in the project budget.
- No transitional provisions. A company with an application under assessment cannot tell from the text whether it is being judged by the old rules or the new ones.
- The June 2026 InforEuro rate is written nowhere in Order no. 820/2026, so every applicant has to look it up themselves and carries the risk of a conversion error.
- The technical connection approval required before signature depends on the distribution operator, not on the applicant, and the order sets no deadline for obtaining it.
- At „e-MOVE RO”, the change to the sub-measure 3 score leaves the renewable energy component with no stated weight, even though it remains mandatory in the project.
Practical advice
- If you are preparing a project under „e-Mobility RO”, ask the distribution operator for the technical connection approval from the moment you have the site, not after winning the call. Article 22(4) blocks signature of the contract without it, and the connection procedure has deadlines of its own that do not depend on you.
- Recalculate in lei any budget built on the July 2025 InforEuro rate, if you are working on the maritime and air transport scheme. The sum in euro has not changed, but the lei equivalent has, and it decides whether you fit within the 30 million ceiling.
- Check whether the site you have in mind for an „e-MOVE RO” station was excluded only by the 3 kilometre rule. If so, it became eligible again on 2 September 2026 and is worth putting back into the analysis.
- Count the recharging points against the 22 kW threshold. Below that power, a point does not count under any scheme, so a station with many slow sockets gets you no closer to the required power thresholds.
- If you are targeting a section of national road on the TEN-T network, check with CNAIR whether it is due to be replaced by a motorway or express road, with a contract signed or a tender under way. If so, your threshold falls to 2,800 or 1,400 kW.
- Merge your applications before submitting them under „e-Mobility RO”. One project per sub-measure in a procedure, but the project can cover several sites, so the right strategy is one portfolio application, not several small ones.
- Budget for the annual energy audit throughout the durability period, at both station schemes. It is an operating cost you carry alone, year after year once the investment is completed.
- Size the photovoltaic installation according to the sub-measure you choose at „e-MOVE RO”. Under sub-measure 2 you cannot exceed the maximum nominal useful power of the station, under sub-measure 3 you may exceed it by at most 40%.
- If you buy electric ground power units for aircraft, plan the scrapping of the combustion engine ones within the 60 days from the commissioning of each new unit. The period runs from commissioning, not from completion of the project.
Frequently asked questions
What is the Modernisation Fund and where does the money come from?
Why do five orders appear on the same day?
Does anything change for financing applications already submitted?
By when does a project have to be completed?
How much can a company receive from each scheme?
What does it mean that a recharging point has to have at least 22 kW?
What is the InforEuro rate and why does the change of month matter?
Does the ban on installing „e-MOVE RO” stations near motorway exits still exist?
What happens if the schemes are not aligned with the new European regulation?
Can I submit the same project under both station schemes?
Errors and inconsistencies in the published text
- Order no. 821/2026, Article 11(1)(l): an exception to a rule that no longer exists. Letter (l) declares eligible the infrastructure inside airport perimeters „indiferent de amplasarea pe rețeaua Companiei Naționale de Administrare a Infrastructurii Rutiere sau de distanța față de cea mai apropiată ieșire a unui drum TEN-T”, that is regardless of siting on the network of the National Company for Road Infrastructure Administration or of distance from the nearest exit of a TEN-T road. The exception makes sense only if somewhere in the article there is a condition on distance from TEN-T exits. Letter (k), which lays down the siting ban, no longer contains any distance, and neither does Article 2(3), amended by the same order. Two readings follow. The first: the distance condition was removed, and letter (l) is an uncut remnant, so the airport exception adds nothing. The second: the distance condition survives somewhere in the scheme and continues to apply to all other sites, with airports exempted from it. An operator considering a location two kilometres from a motorway exit cannot establish from the published text whether they are eligible or not, and the difference decides whether they apply at all.
- Order no. 820/2026, Article 11(1)(l) against Article 16(1): the same ceiling, two different units of reference. Both texts are rewritten by the same order, on the same day, and both set 30 million euro. Letter (l) says „pe întreprindere”, per undertaking, Article 16 says „pe beneficiar”, per beneficiary. In State aid law, the undertaking is the single economic unit, so it includes companies linked to one another, whereas the beneficiary is the signatory of the financing contract. For a group of three linked companies applying separately, the first reading gives a shared ceiling of 30 million, the second gives 30 million each, that is 90. Since letter (l) is an eligibility condition checked at submission, while Article 16 is the rule for calculating the aid, the same three applications can pass one test and fail the other.
Editorial analysis
The most instructive thing in this package is not what changed, but the ratio between two deadlines that the orders place side by side without comparing them. Projects financed under these schemes have an implementation deadline of 30 June 2030, that is 1,397 days from publication. The European basis that permits contracts to be signed, Regulation (EU) no. 651/2014, expires on 31 December 2026, that is 120 days from publication. The ratio is close to twelve to one. The ministry asks the beneficiary to plan four years of execution on a legal basis with four months of life left, and the clause inserted into all five schemes does not solve this, it merely describes it: if the alignment is not carried out, contracting stops. None of the five orders says how long the transitional period on which everything depends lasts, even though it is mentioned three times in each text.
The second thing that does not show when the acts are read end to end is how unevenly the power exception in Order no. 818/2026 cuts. On the TEN-T core network, the threshold falls from 3,600 to 2,800 kW, a reduction of 22.2%, but the requirement of two points of 350 kW each stays. On the comprehensive network, the threshold falls from 1,500 to 1,400 kW, that is only 6.7%, yet the number of mandatory 350 kW points drops from two to one. In other words, on the core network the total power is relaxed and the equipment is kept, on the comprehensive network almost all the power is kept and the equipment is halved. An investor on the comprehensive network can reach 1,400 kW with a single fast point and a bundle of slower ones, provided each is above 22 kW, which is a qualitatively different station from the one paragraph (4) had in mind. The order does not explain why the two networks receive relaxations built on opposing logics.
The third point: the two station schemes no longer separate cleanly. Order no. 818/2026 leaves „e-Mobility RO” with siting on „main national roads administered by” CNAIR, while Order no. 821/2026 excludes from „e-MOVE RO” only „TEN-T national roads administered by” CNAIR. A main national road administered by CNAIR that is not on the TEN-T network falls, under the texts published on the same day, within the scope of both schemes. Until 2 September 2026 the delimitation was stricter, because „e-MOVE RO” excluded CNAIR’s main national roads and, on top of that, a 3 kilometre radius around motorway exits. This is not a drafting error within one act, but an effect of combining two acts, and it is the kind of overlap that gets resolved only in the applicant’s guides, that is too late for anyone choosing a site now.
It is worth saying what is clean, too. The scoring formula in the „e-MOVE RO” annex is a correct linear interpolation, verifiable with a pencil, and its rewriting introduces no mathematical ambiguity. Order no. 820/2026 is a technically impeccable maintenance operation: it changes three exchange rate references and touches no sum. And Order no. 817/2026 draws exactly the right distinction, limiting the harmonisation clause to measure 2, that is to the State aid part, because the de minimis part rests on another regulation that does not expire in 2026. These are signs that the texts were read, not merely copied.
One observation on continuity remains. On 7 August 2026, when we wrote about the relaunch of the „e-Mobility RO” scheme, we flagged that Article 12(3) of the annex refers to a condition precedent that paragraph (2) does not establish, which makes it impossible to determine what has to happen for the ministry to be able to open a session in 2027. Order no. 818/2026 rewrites precisely paragraph (2), three weeks later. The new text contains an undertaking and a ban, but no condition precedent. The reference in paragraph (3) therefore remains without an object.
Alongside the five schemes amended here comes a sixth, also for transport: Order 822/2026, with 150 million euro for the energy efficiency of ports, under the Transport Programme 2021-2027.
What should be changed
- Write the length of the transitional period into the scheme. All five texts make contracting conditional on a period they do not quantify. A single sentence with the duration and the resulting deadline would turn an uncertainty into a calendar and would let a company know whether it is worth starting to prepare an application in 2027.
- Align the unit of the ceiling in Order no. 820/2026. Use „per undertaking” in both places, with a reference to the definition in the scheme, and say explicitly whether the ceiling is cumulative across all competitive procedures, as „e-MOVE RO” does at letter (o). Without that, a group of linked companies does not know whether it has one ceiling or three, and the assessor has nothing to reject on.
- Clean up letter (l) in Article 11 of the „e-MOVE RO” scheme, or reinstate the distance rule. If the 3 kilometre zone was removed deliberately, the airport exception has to be rewritten without the reference to distance. If it was removed by mistake, the rule has to be put back at letter (k). Either option is better than the current text, which suggests both.
- Fix the reference in Article 12(3) of the „e-Mobility RO” scheme. Either the condition precedent is expressly established in paragraph (2), or paragraph (3) has to refer to something else. Otherwise, the launch of the 2027 and 2028 sessions hangs on a rule that does not exist.
- Delimit the two station schemes by a single criterion. Either both speak about main national roads, or both about TEN-T national roads. The crossed wording as it stands leaves one category of roads inside both schemes, and no text says what happens if the same site is submitted under both procedures.
- Publish the InforEuro rate used, once, in an act of the ministry. Order no. 820/2026 requires a conversion that it does not supply. An annex with the June 2026 rate and with the ceilings already converted into lei would take a whole category of application errors off the table.
- Say what weight the renewable energy component carries under sub-measure 3 of „e-MOVE RO”. Point 1 as amended gives 100% to the recharging component, while the project remains obliged to include production and storage as well. If those components are not scored, that has to be said, otherwise an applicant has no way of optimising its bid.
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. 739 of 2 September 2026 16 pages PDF, 119 KB the act starts on page 5
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