Energy law & ANRE regulation in Romania (licensing, grid, REMIT, contracts)
Energy law is an area where a seemingly technical issue can quickly become a legal and commercial problem: ANRE licences, regulatory reporting duties, grid-connection deadlines, permits, PPAs, guarantees, imbalance invoices, netting mechanisms, REMIT investigations, disputes with network operators or settlement mechanisms in the market. In these matters, the order of steps matters: which documents you review, which deadline is running, what you answer, what you acknowledge and what you do not, how you preserve evidence and when you escalate toward the regulator, negotiation or court.
I work with energy companies, including suppliers, generators, traders, aggregators, project investors, renewable-energy developers, wholesale-market participants and commercial clients affected by ANRE decisions, network-operator processes or market settlement mechanisms. The approach starts with a focused review of facts and documents, then we map the steps, deadlines and strategy: regulatory, contractual or litigation-based, depending on the file.
In energy, reading one clause or one authority letter in isolation is rarely enough. The operating model, market role, licences, contracts, ANRE procedures, market rules, operational data, communications with operators, invoices, guarantees and EU obligations must be read together. A poorly calibrated answer to an authority or a commercial notice drafted without strategy can have consequences beyond the immediate file: regulatory exposure, project blockage, contractual default, balancing costs, loss of a financing window or multiple connected disputes.
The information below is general and does not replace legal advice on a specific matter. In energy law and ANRE regulation, details in licences, ANRE decisions, contracts, permits, operational data, platforms, invoices, regulations and chronology can change the strategy. For a first review, send the relevant documents, correspondence, contracts, calculation data and a short timeline.
In 30 seconds: how I can help
Useful legal support in energy is not only “writing a letter to ANRE” or “reviewing a contract”. It means understanding your market role, applicable obligations, documents, deadlines, sanction risks, commercial effects and the realistic outcome: licence, licence amendment, grid-connection progress, invoice correction, contractual position, investigation response, negotiation, challenge or litigation.
Licensing, authorisation, ANRE
- analysis of whether the activity falls within licensing, authorisation or reporting duties
- electricity and natural gas supply licences
- power generation licensing, including renewable projects
- amending or extending the authorised activity
- responses to ANRE requests, inspections, notifications or clarification letters
- strategy for energy sanctions, measures and challenges
Projects, grid connection, market
- grid connection: refusal, deadlines, unclear costs, technical conditions and correspondence
- regulatory due diligence for projects: land, permits, ATR, connection agreement and authorisations
- prosumers: contracts, netting, invoicing, settlement adjustments and disputes
- Guarantees of Origin, certificates, support schemes and corrections
- imbalances, balancing, allocations, metering, nominations and settlement invoices
- relations with operators, suppliers, aggregators, traders and commercial counterparties
Contracts, REMIT, disputes
- PPAs: price, indexation, volume, availability, guarantees, force majeure and default
- supply, trading, balancing, aggregation and related service contracts
- REMIT compliance: inside information, reporting, policies, training and internal audit
- responses to ANRE, ACER or data-request investigations
- energy commercial disputes: non-performance, penalties, guarantees, termination and settlement
- administrative litigation or contractual litigation, including evidence preparation
For the main English service page in this area, see Energy law & ANRE regulation in Romania: licensing, grid, REMIT and contracts. For the related sanctions page, see ANRE energy sanctions: defence, investigation response and appeal.
Subpages in this section
Energy law is a technical area, and the main page should work as a map. If your situation matches one of the dedicated topics below, use the relevant link. Each subpage addresses the steps, useful documents, risks and frequently asked questions for that topic.
| Subservice | When it is relevant | Link |
|---|---|---|
| ANRE electricity and gas supply licensing | You need a supply licence, extension, amendment or obligation review | Open |
| ANRE power generation licensing, including renewables | Generation project, licensing, commercial operation or post-licence obligations | Open |
| Grid connection and disputes with network operators | Refusal, missed deadlines, unclear costs, technical conditions or project blockage | Open |
| Prosumers: contracts, netting, invoicing, disputes | Netting, settlement, invoices, contract documents and supplier or DSO disputes | Open |
| Energy PPAs: contract risk allocation | Price, indexation, volume, profile, availability, guarantees, force majeure and default | Open |
| Energy imbalances and balancing invoices | Disputed invoices, corrections, metering, allocations, schedules and guarantees | Open |
| REMIT compliance and investigations | Wholesale trading, inside information, reporting, procedures, training and investigations | Open |
| Guarantees of Origin, certificates and support schemes | Audits, corrections, disputes, trading, reporting and support-scheme questions | Open |
| Regulatory due diligence for energy projects | You check land, permits, ATR, grid connection, licences and project-blockage risk | Open |
| Energy trading and supply disputes | Trading, supply, default, guarantees, penalties, non-performance and termination | Open |
Practical working principles
- We start with your market role. Supplier, generator, trader, aggregator, prosumer, investor, commercial consumer or project developer: each role has different obligations, risks and documents.
- We separate legal and technical issues, but connect them. In energy, a legal answer without technical data may be weak, while a technical table without procedural position may miss the deadline or legal route.
- Deadlines are checked before any position is taken. An ANRE request, grid-connection refusal, disputed invoice or default notice may have different deadlines and immediate effects.
- Documents decide the file. Contracts, annexes, metering data, nominations, platform exports, invoices, reports and correspondence must be placed in a verifiable chronology.
- Negotiation is not a waiver of rights. Many energy disputes are solved commercially, but notices and proposals must preserve the legal position.
- Compliance is part of defence. In REMIT, licensing, reporting and investigations, a minimal compliance programme can reduce future risks and support good-faith explanations.
- The result must be practical. The goal is to unblock the project, correct the invoice, obtain the licence, limit the sanction, close the negotiation or prepare litigation with solid evidence.
ANRE licensing: supply, generation, amendments and post-licence obligations
ANRE licensing should not be treated as a simple administrative file. For companies, the licence is connected to the business model, group structure, operational resources, market contracts, internal responsibilities, guarantees, IT platforms, reporting and post-licence obligations. An incomplete application may lead to repeated clarification requests, delays, launch blockages or later compliance risks.
For supply, the analysis starts from the proposed activity: electricity, natural gas, targeted clients, B2B or B2C segment, acquisition sources, contracts, invoicing flows, relations with operators, information and reporting duties. For generation, the project path matters: land, permits, grid connection, commissioning, commercial operation, support schemes and post-licence obligations. In both cases, it is useful to have an internal compliance file, not only a licence certificate.
- analysis of whether the activity requires a licence or only reporting and compliance duties
- preparing applications, annexes and responses to clarification requests
- checking consistency between the business model and requested licence scope
- strategy for amendments, extensions, reorganisations or changes of title holder
- minimal audit of post-licence obligations: reporting, procedures, resources and communications
- coordination with commercial contracts and launch or financing calendar
For supply licensing, see ANRE electricity and gas supply licensing in Romania. For generation, including renewable projects, see ANRE power generation licensing, including renewables.
Grid connection and disputes with network operators
Grid connection is often the point where an energy project becomes blocked. Issues arise through refusals, delays, disputed costs, questionable technical conditions, capacity constraints, solution changes, inconsistencies between ATR, connection agreement, permits, land documents and financing calendar. A good strategy does not start with a generic complaint, but with reconstruction of the path: application, responses, deadlines, technical documents, operator obligations and concrete effect on the project.
Grid-connection files require technical documentation. What was requested, what was offered, what technical conditions were imposed, which costs are disputed, whether alternatives exist and whether delay creates chain effects all matter: loss of financing, delay of a PPA, inability to commission or contractual penalties.
- analysis of ATR, connection agreement, correspondence and technical approvals
- identification of deadlines and operator obligations
- review of costs, technical conditions and solution changes
- preparing a written position: request, complaint, negotiation or escalation
- strategy for renewable projects, large consumers or portfolios of consumption points
- evidence preparation if the dispute escalates to administrative or contractual litigation
See the dedicated page Grid connection in Romania: disputes with network operators.
Prosumers: contracts, netting, invoicing and settlement
Prosumer files usually have a mixed structure: contract, regulation, technical data and invoicing. Differences may arise between readings, energy injected, energy consumed, netting, settlement, supplier change, incorrectly carried balances or delayed documents. For legal entities or portfolios of prosumers, those differences can become financially significant and affect cashflow.
The approach is document-based. We review the contract, annexes, invoices, readings, consumption and generation history, communications with the supplier and distribution operator, complaints filed and responses received. Then we determine whether the issue is metering, data transfer, application of the netting mechanism or contractual interpretation.
- reconstructing the chronology of readings, invoices and settlements
- checking netting, invoicing, balance and supplier-change clauses
- preparing correction requests with verifiable tables and annexes
- negotiation for reversal, recalculation, instalment plan or settlement
- complaints to authorities where justified
- litigation strategy if the dispute cannot be solved amicably
See the dedicated page Prosumers in Romania: contracts, netting, invoicing and disputes.
Energy PPAs and risk allocation
A PPA is not only an energy sale agreement. It is a medium- or long-term risk-allocation instrument: price, volume, profile, availability, production, curtailment, balancing, guarantees, credit risk, force majeure, change in law, indexation, termination, step-in, default and remedies. If those clauses are unclear, the dispute appears at the most expensive moment: when the market changes, generation differs from assumptions or one party can no longer support its obligations.
In PPAs, legal and commercial logic must be aligned. A good price clause must be consistent with metering, delivery, invoicing, guarantees and termination. A force-majeure clause must connect with outages, regulatory changes, grid capacity, curtailment and mitigation duties. A guarantee clause must be enforceable, not decorative.
- PPA review and negotiation: price, indexation, volume, profile, delivery, imbalances
- guarantees, default, credit support, penalties and remedies
- force majeure, change in law, curtailment and unavailability
- invoicing, notice, dispute and reconciliation mechanisms
- coordination with project financing and grid-connection obligations
- strategy if the PPA is already in conflict or a party invokes default
See the dedicated page Energy PPAs in Romania: contract drafting and risk allocation.
Imbalances, balancing and settlement invoices
Imbalance and balancing invoices are difficult to analyse without operational reconstruction. We need to identify the source of the obligation: market rules, contract, commercial annexes, BRP position, schedules, nominations, metering, allocations, corrections, settlements and platform data. A disputed invoice without data can be rejected quickly. A prepared position shows concretely where the difference appears and what recalculation is requested.
In these files, we usually do not start from the conclusion. We start from data: intervals, quantities, sources, communications, file versions, exports, reports, invoices, debit notes, guarantees and default notices. Then we determine whether the dispute is technical, contractual, interpretative or settlement-based.
- reconstructing operational chronology: schedules, nominations, metering, allocations, corrections
- checking BRP, supply, trading, aggregation or related-service contracts
- analysis of calculation basis and data traceability
- preparing a written position for recalculation, negotiation or formal objection
- strategy where additional guarantees, default or penalties are invoked
- evidence preparation for litigation or expert analysis
See the dedicated page Energy imbalances and balancing invoices: dispute, negotiate and document.
REMIT compliance and response to investigations
REMIT should not be treated only as a reporting obligation. For companies trading electricity or gas, REMIT means identifying relevant products, reporting flows, inside information, internal procedures, training, responsibilities, monitoring and the ability to explain commercial decisions if an investigation appears. Without a coherent internal file, responses to authorities may become fragmented or contradictory.
A minimum compliance programme does not need to be bureaucratic. It must answer practical questions: who identifies inside information, who decides publication, what is reported, through which RRM, how evidence is preserved, who communicates in investigations, what training trading teams receive and how sensitive commercial decisions are documented.
- REMIT audit adapted to your market role: generator, trader, supplier, aggregator
- procedures for inside information, reporting, escalation and evidence retention
- training for relevant teams and clear internal responsibilities
- responses to ANRE, ACER or other competent-authority requests
- preparing chronology of commercial decisions and supporting documents
- strategy for investigations, sanctions and corrective measures
See the dedicated page Energy REMIT compliance and response to investigations.
Guarantees of Origin, certificates and support schemes
Guarantees of Origin, certificates and support schemes can create value, but also disputes. Problems appear when there are inconsistencies between generation, data, reporting, trading, supporting documents, corrections or different interpretations of obligations. For generators, suppliers or corporate consumers, documentation errors may affect settlement and commercial reputation.
- document audit for Guarantees of Origin, certificates and support schemes
- checking generation data, reporting, trading and recordkeeping
- responses to requests, corrections or authority decisions
- strategy for commercial or administrative disputes
- coordination with supply contracts, PPAs and ESG or corporate-procurement obligations
- preparing a verifiable position for negotiation or litigation
See the dedicated page Guarantees of Origin and support schemes: audits, corrections and disputes.
Regulatory due diligence for energy projects
An energy project may look financially attractive but be vulnerable from a regulatory perspective. In due diligence, we do not check only the sale agreement or land documents. We review the project path: land rights, urban planning, permits, environmental steps, grid connection, ATR, connection agreements, licences, ANRE obligations, support schemes, litigation, easements, technical conditions, deadlines and the risk that the project cannot advance according to the commercial calendar.
A good due diligence does not produce only a list of problems. It produces a risk map: what is blocking, what can be remedied, what must be covered by contractual warranties, which condition precedent is necessary, what cost may appear and which document is missing. For investors, project lenders or buyers of portfolios, that clarity can decide price, transaction structure and calendar.
- checking land, permits, authorisations and grid-connection documents
- analysis of ANRE obligations and licensing status
- identifying blockage risks, additional costs and critical deadlines
- reviewing project contracts: PPA, EPC, O&M, connection, financing and guarantees
- risk matrix: blocking, remediable, negotiable, monitorable
- SPA clauses, conditions precedent, warranties, indemnities and post-closing obligations
See the dedicated page Regulatory due diligence for energy projects: land, permits and grid.
Energy commercial disputes: supply, trading, default and guarantees
Commercial disputes in energy have particular features: volatile market, technical contracts, guarantee mechanisms, delivery obligations, market invoices, default clauses, penalties, force majeure, change in law, balancing and chain effects on other contracts. In these files, simply invoking non-performance is not enough. The contractual relationship, operational flow and market context must be reconstructed.
Before litigation, we check whether a commercial solution exists: recalculation, set-off, partial performance, use of guarantees, payment calendar, temporary amendment or controlled termination. If litigation is unavoidable, we prepare evidence: contracts, annexes, notices, invoices, data, platform exports, reports, communications, guarantees and expert reports.
- analysis of supply, trading, aggregation, balancing and related-service contracts
- default notices, termination, guarantee calls and penalties
- strategy for negotiation, standstill, settlement or litigation
- evidence preparation for court or arbitration
- coordination with urgent measures, freezing orders or enforcement steps
- commercial risk assessment of litigation compared with negotiated resolution
See the dedicated page Energy trading and supply disputes: default, collateral and settlement.
ANRE requests, inspections, sanctions and appeals
An ANRE request or inspection should be handled in an organised way from day one. We check the scope of the request, deadline, legal basis, documents requested, technical people who can answer and the risk that the response may later be used in a sanction procedure. A company must send a complete but controlled response: with the right annexes, without speculation and without contradictions with contracts, reporting or internal data.
If a sanction act exists, the analysis has two levels: contravention defence and regulatory exposure. The facts recorded, legal rule allegedly breached, sanction, additional measures, individualisation, evidence, service and consequences for the licence or activity all matter. In some situations, the defence must be coordinated with a compliance plan, especially if the authority identified a system issue.
- analysis of requests, deadlines and inspection scope
- organising documents and technical responses
- preparing objections, supplements and written positions
- challenging sanctions and measures where there is a basis
- coordination with licence obligations, REMIT, reporting and internal procedures
- remediation plan to reduce repeat-sanction risk
For energy sanctions, see ANRE energy sanctions: defence, investigation response and appeal. For regulator decisions generally, see Challenging decisions of Romanian regulators as a foreign company.
Communication with ANRE and operators: preserving your legal position
In energy files, written communication is often the main evidence. A letter sent to ANRE, a response to a network operator or a notice to a contractual counterparty may later be used in an inspection, negotiation, appeal or litigation. Communication must therefore be complete, verifiable and prudent. It is not useful to send speculative explanations, unvalidated calculations or informal acknowledgements only to answer quickly.
A good position identifies the act, deadline, legal or contractual basis, attached documents, what is specifically requested and which rights are reserved. If the situation has a technical component, we include tables, extracts, reports, readings, platform exports or technical notes, but we connect them to a legal conclusion. If uncertainties exist, we formulate them as verification points, not as acceptance of the other party’s position.
In relations with operators, suppliers or market partners, communication must also preserve the possibility of a commercial solution. A notice that is too aggressive may block negotiation. A notice that is too weak may be read as waiver. The balance comes from precise requests, reasonable deadlines, clear annexes and reservation of rights for the next step.
- define what must be answered, what must be attached and what must be avoided
- check consistency between response, contracts, reporting and operational data
- prepare letters with specific requests, not general statements
- reserve rights expressly where litigation risk exists
- preserve proof of transmission and exact version of annexes
- avoid contradictions between legal, technical and commercial communication
Risk matrix: blocking, negotiable, remediable or monitorable
In energy, a list of problems is not enough. For projects, contracts or inspections, a risk matrix is more useful: what blocks the project, what can be remediated, what can be negotiated, what can be monitored and what must be escalated. This logic is especially useful in due diligence, PPAs, grid connection, licensing and commercial disputes. Not all issues carry the same weight, and some can be solved by additional documents or contractual clauses.
For example, a missing clarification in a contract may be fixed by an addendum, while the absence of a critical permit may block the project. An invoicing error may be corrected by recalculation, while an unclear default clause may generate expensive litigation. An incomplete REMIT procedure may be remediated by training and internal rules, while an investigation already opened requires documented defence and a strict calendar.
- Blocking risk: prevents licensing, grid connection, financing, operation or transaction closing.
- Remediable risk: can be corrected through documents, clarifications, addenda, procedures or filings.
- Negotiable risk: can be allocated through warranties, conditions precedent, indemnities, price or post-closing duties.
- Monitorable risk: does not block immediately, but must be tracked through reporting, deadlines or periodic audit.
- Litigation risk: requires notice, evidence, interim measures, challenge or court action.
Energy data room: organising documents before analysis
For energy projects, portfolios, transactions or complex disputes, documents should be organised in a minimal data room. The objective is not volume, but finding the relevant document quickly. The structure depends on the file, but usually includes: corporate, land, urban planning, environment, grid connection, ANRE, commercial contracts, financing, technical, operational, disputes, correspondence and reporting.
In imbalance or settlement-invoice disputes, the data room should include calculation versions, platform exports, metering data, schedules, nominations, allocations, notices and invoices. In PPA matters, it should include the contract, annexes, term sheet, guarantees, notices, invoices, generation data and discussions about amendments. In licensing, it should include applications, responses, decisions, reports and proof of transmission.
- organise documents by functional folders, not only by date
- preserve final versions and relevant negotiation versions
- mark missing documents and the person able to obtain them
- separate technical documents from legal conclusions
- build a main chronology and open-issues list
- use the data room as basis for responses, negotiations or evidence
Negotiation or litigation: choosing the next step
Many energy disputes can be solved through negotiation, but only if the position is prepared. Efficient negotiation starts from data: what amount is disputed, which clause is invoked, what deadline is running, which guarantee may be called, what effect default produces and what commercial solution is acceptable. If those points are unclear, negotiation becomes a long discussion without result.
Litigation becomes necessary when the other party refuses recalculation, calls guarantees without basis, blocks the project, applies unjustified penalties, refuses to recognise data or interprets the contract in a way that produces significant losses. Before court, we prepare notices, evidence, possible expert input and cost-benefit analysis. Sometimes interim measures or freezing orders may be relevant; in other cases, the realistic objective is a well-documented settlement.
- check whether the dispute is technical, contractual, administrative or mixed
- define what commercial outcome would be acceptable
- prepare the written position before discussions
- assess guarantee-call, default and penalty risk
- decide whether a technical or accounting expert is needed
- choose between negotiation, challenge, commercial mediation, litigation or urgent measures
Renewable projects: legal risks before commercial operation
In renewable projects, many risks appear before commercial operation: land, urban planning, environment, grid connection, licensing, financing, EPC, O&M, PPA, commissioning deadlines, easements, access, guarantees and network-operator conditions. If those elements are not aligned, a project that looks advanced may be vulnerable in due diligence or financing.
A frequent issue is dependence on documents at different stages: land is secured, but grid connection is unclear; the PPA is being negotiated, but permits are delayed; financing has conditions, but licensing is not prepared; the operator changes technical conditions, and commercial contracts do not cover the delay. The project must be read as a chain, not as a pile of separate documents.
- identify documents critical for bankability and operation
- check dependencies between land, permits, grid connection, licence and commercial contracts
- prepare clauses for delays, conditions precedent and network risks
- align the PPA with the technical and regulatory calendar
- check post-licence obligations and necessary reporting
- prepare risks for investor, lender or buyer review
When it makes sense to contact me
- you need an ANRE licence, authorisation or certificate for electricity or natural gas activities
- you want to amend, extend or reorganise an authorised activity
- you received ANRE requests, clarification letters, inspection notices or a sanction act
- you face grid-connection problems: refusal, missed deadlines, unclear costs or disputed technical conditions
- you are a generator and want to check the path from authorisation to commercial operation
- you are a prosumer or manage prosumer portfolios and face netting or invoicing issues
- you received imbalance, balancing or settlement invoices and need to verify the calculation basis
- you trade wholesale energy products and need REMIT compliance or investigation response
- you have disputes regarding Guarantees of Origin, certificates, support schemes or corrections
- you are doing regulatory due diligence on a project and need to check land, permits, grid and ANRE risks
- you have energy commercial disputes: supply, trading, default, guarantees, non-performance or force majeure
- you want to negotiate a PPA or review an existing contract before signing or financing
How we work, step by step
- Clarify the objective. Licensing, compliance, ANRE response, negotiation, challenge, litigation, PPA, grid connection, invoices or due diligence.
- Define the applicable framework. Law, ANRE regulations, market rules, contracts, internal procedures, decisions, communications and deadlines.
- Set the minimum document list. We do not request everything at once. We request what is useful for the first review and complete later.
- Reconstruct the chronology. Who requested, who answered, when, on which platform, with what annex, what data were sent and what effect followed.
- Build the action plan. Steps, deadlines, responsibilities, technical and legal position, communication and remaining risk.
- Draft or negotiate documents. ANRE filings, responses, notices, contracts, PPAs, objections, recalculation positions or agreements.
- Prepare evidence. Contracts, reports, operational data, platform exports, invoices, witnesses, expert reports and correspondence.
- Represent in procedures. Regulatory, contractual or court procedures, including administrative litigation and commercial disputes.
- Track implementation. Invoice correction, authority response, licence obtained, contract signed, project unblocked or litigation file prepared.
Documents and information useful for the first review
| Document or information | Why it matters | Notes |
|---|---|---|
| Business model and activity description | Shows whether licensing, reporting or market obligations may apply | Include group structure, roles, outsourcing, IT, EMS, partners and flows |
| ANRE correspondence, requests or decisions | Set the deadline, procedural framework and response scope | Send the complete file, including annexes, not only the main letter |
| Relevant contracts | Show rights, obligations, price clauses, guarantees, force majeure and remedies | Supply, trading, PPA, BRP, aggregation, DSO, TSO, EPC, O&M |
| Operational data | Needed for imbalances, balancing, invoices, metering and settlements | Platform exports, reports, schedules, allocations, readings and notices |
| Project file | Reveals blockage risks, stage obligations and technical conditions | Land, urban planning, permits, ATR, connection agreement, financing |
| Licences, authorisations, certificates and reports | Show regulatory status and post-licence obligations | Include amendments, decisions, communications, reports and proof of filing |
| Compliance policies and procedures | Useful for REMIT, internal audit and investigation response | We can propose a minimal set adapted to your market role |
| Short chronology | Makes the file understandable and supports quick selection of next steps | One or two pages: dates, people, events, documents, deadlines and effects |
Risks and common mistakes
- responses to ANRE sent quickly but without the right annexes or explanations
- confusing licensing obligations with reporting duties and contractual obligations
- treating grid connection as simple correspondence, without chronology and technical evidence
- signing a PPA without clear price, volume, indexation, guarantee and default mechanisms
- challenging imbalance invoices without reconstructing operational data
- missing REMIT procedures and rules for inside information
- artificially separating legal and technical issues, although the dispute depends on both
- not preserving platform exports, reports, notices and calculation versions
- negotiating a commercial solution without reservation of rights or clear clauses
- doing due diligence only on land and contracts, without checking ANRE and grid obligations
- ignoring chain effects: financing, guarantees, default, penalties, reputation and sanctions
Useful blog resources
Challenging decisions of Romanian regulators as a foreign company
Read the article
Abusive clauses in credit and service contracts, including energy
Read the article
Costs in administrative or tax litigation
Read the article
State aid, grants and tax incentives in Romania
Read the article
FDI screening in Romania and the EU: checklist for foreign investors
Read the article
Debt recovery in Romania for foreign companies
Read the article
Brussels vs Bucharest: deficit procedure, gas caps and EU funds
Read the article
Annulment of abusive administrative acts in Romania
Read the article
Cross-border disputes connected to Romania
Read the article
Frequently asked questions
Do I need an ANRE licence for my activity?
It depends on your role in the energy chain: supply, generation, distribution, trading, aggregation, services, prosumer activity or commercial consumption with special obligations. The analysis is based on your business model, contracts, flows, platforms and the concrete way you deliver energy or services. Sometimes a licence is needed; in other cases, reporting or compliance duties may be sufficient.
What should I do if I receive an ANRE request or inspection notice?
Check the deadline, scope, legal basis and documents requested. Then organise the chronology and annexes. A coherent response, with the right documents and without speculative statements, reduces the risk of misinterpretation and keeps options open for later challenges where needed.
Can imbalance or balancing invoices be challenged?
Yes, but the approach depends on the source of the obligation: market rules, contracts, settlement mechanisms and operational data. Usually, we review the calculation basis, data traceability, schedules, metering, notices, contractual clauses and correction mechanisms.
What does minimum REMIT compliance mean for a company?
In practice: identifying relevant products and activities, internal responsibilities, inside-information procedures, reporting rules, training for involved teams and evidence retention. The exact level depends on market profile and how the company trades or handles sensitive information.
How do we approach a grid-connection blockage?
We start from the connection file: application, ATR, connection agreement, correspondence, technical conditions, costs and deadlines. We separate what can be solved technically or contractually from what requires procedural escalation. The goal is a viable path for the project or a solid basis for a challenge.
Why do indexation, force majeure and guarantee clauses matter in a PPA?
In energy, price variations, outages, credit risks and regulatory changes can generate major costs if contract mechanisms are unclear. Careful drafting reduces disputes and gives predictable remedies when unplanned events occur.
What should I check in regulatory due diligence for a renewable project?
Check land, urban planning, permits, ATR, connection agreement, authorisations, licences, ANRE obligations, calendar, litigation, easements, environment, support scheme, PPA and blockage risks. The result should be a risk matrix, not only a document list.
What legal fee should I expect?
After the initial review, I propose a fee model: fixed, hourly, staged or complementary success fee where permitted. I explain what it includes and which collateral costs may appear: fees, translations, expert reports, technical consultancy, travel, regulatory procedures or litigation.
Let’s define the next steps quickly and clearly
Tell me your role in the market and what document or blockage exists: ANRE licence, grid connection, imbalance invoice, PPA, REMIT, prosumer file, due diligence, sanction, contract or dispute. Send the key documents and a short chronology. I will respond with concrete next steps, the deadline that must be checked and the short list of documents that matter.
E-mail: alexandru@maglas.ro | WhatsApp: message on WhatsApp
Useful internal links
- Law office services in Bucharest and Romania
- Administrative law and urban planning law services
- Commercial law and business disputes
- Contravention matters: challenging fines and urgent measures
- Legal fees
- Lawyer’s fee guide
- Contact lawyer
Official legal and regulatory sources
The sources below are useful for checking the general framework. For a specific file, the updated legal text, applicable ANRE regulations, contracts, decisions, platforms, data and chronology must be checked.
- Law no. 123/2012 on electricity and natural gas, Romanian legislative portal
- Government Emergency Ordinance no. 33/2007 on ANRE organisation and operation, Romanian legislative portal
- ANRE public lists: licences and authorisations
- ANRE: primary legislation on electricity
- ANRE: primary legislation on natural gas
- Regulation (EU) No 1227/2011 on wholesale energy market integrity and transparency, REMIT, EUR-Lex
- Commission Implementing Regulation (EU) No 1348/2014 on REMIT reporting, EUR-Lex
- Regulation (EU) 2024/1106 amending REMIT, EUR-Lex
- Regulation (EU) 2019/943 on the internal market for electricity, EUR-Lex
- Directive (EU) 2019/944 on common rules for the internal market for electricity, EUR-Lex
- ACER: About REMIT
- ACER REMIT Portal
Note: the information on this page is general. In energy law and ANRE regulation, facts, documents, operational data, contracts and chronology can change the solution.
