This service is for companies entering the Romanian energy market, expanding scope, or dealing with ANRE requirements for supply licensing. We clarify your licensing path, build the application file, and manage regulator communication. To start, we review your corporate set-up and operating model, then map the required documents and a realistic compliance plan.
Informațiile sunt generale și nu înlocuiesc consultanța juridică. Contează faptele, actele și cronologia. The information is general and does not replace legal advice; facts, documents, and chronology matter.
When you need this
- You plan to apply for an ANRE supply licence (electricity and/or natural gas) for the first time.
- You need to change the scope of an existing licence (activities, customers, territory, corporate changes).
- You received an ANRE request for clarifications, additional documents, or remediation measures.
- You are preparing an acquisition, restructuring, or group set-up that impacts licensing and compliance.
- You need to align supply contracts, customer communications, and internal procedures with ANRE rules.
- You suspect a compliance gap that could lead to sanctions, suspension, or withdrawal risks.
- You need support for interactions with other market entities (e.g., market operators, balancing arrangements) alongside licensing.
- You need a structured compliance roadmap for ongoing reporting and audits after licensing.
What we do, step by step
- Initial scoping: confirm the regulated activity, licence type, and eligibility path for your business model.
- Gap analysis: map what you already have vs. what ANRE typically requires for a complete file.
- Application file build: draft, review, and assemble the application, statements, and annexes.
- Corporate and governance alignment: review decision-making, representation, and group structure topics that affect the file.
- Compliance architecture: build a practical set of policies and internal controls aligned with your operations.
- Regulator communication: prepare submissions and responses to clarifications in a consistent, traceable format.
- Contract alignment: review key supply contract clauses and customer-facing documents for regulatory consistency.
- Post-licensing support: compliance calendar, reporting support, and change management for future amendments.
Documents and information helpful for a first review
| Document | Why it matters | Notes |
|---|---|---|
| Corporate documents (registration, shareholders, directors, powers of representation) | Clarifies who can apply, sign, and assume regulated obligations | Include group chart if relevant |
| Business model summary (target customers, products, operations) | Determines licence scope and the compliance set-up needed | Keep it consistent with commercial materials |
| Financial information (accounts, funding plan, guarantees if relevant) | Supports the credibility of the operating plan and risk management | We identify what needs to be evidenced vs. described |
| Operational capability (staffing, outsourcing, IT, customer service) | Shows the ability to perform supply obligations in practice | Document responsibilities and controls |
| Draft supply terms and customer documents | Helps align templates with regulated requirements | We flag common pitfalls early |
| Any existing ANRE correspondence or decisions | Sets the baseline for how ANRE views your case | Include timelines and proof of submission |
Risks and common mistakes
- Submitting inconsistent information across annexes, declarations, and corporate documents.
- Underestimating internal governance and compliance responsibilities after licensing.
- Using contract templates not aligned with regulated consumer and business customer rules.
- Failing to document operational capability (who does what, how controls work, how records are kept).
- Missing a change-notification duty when corporate structure or activities evolve.
- Responding late or informally to ANRE clarifications, without a structured file trail.
- Assuming market participation arrangements are “separate” from licensing and compliance obligations.
FAQ
Do we need separate licences for electricity supply and natural gas supply?
Electricity and natural gas are regulated under distinct frameworks and ANRE documentation often differs by sector. We confirm the correct licence(s) based on your planned activities and set-up the file accordingly.
Can a foreign company apply, or do we need a Romanian establishment?
The answer depends on the licensing rules, your corporate structure, and how you will operate in Romania. We assess the compliant structure and the evidence needed before you commit to organisational changes.
What if ANRE asks for clarifications after we submit the file?
Clarifications are common. We prepare a structured response pack that ties each answer to the relevant document and keeps the file consistent, so the review can move forward without rework.
Do we have to change the licence if the group restructures or the business model changes?
Changes in governance, ownership, scope of activity, or operations can trigger notification or amendment duties. We review the change and recommend a compliant route (notification, amendment, or other steps) based on the applicable rules.
Can you help with compliance after licensing (reporting, audits, change management)?
Yes. We can build a compliance calendar, support internal procedures, and assist with regulator-facing communications when changes or inspections occur.
Internal links
Sources
- Legea nr. 123/2012 privind energia electrică și gazele naturale (Portal Legislativ)
- Ordinul ANRE nr. 6/2025 – Regulamentul pentru acordarea licențelor și autorizațiilor în sectorul energiei electrice (Portal Legislativ)
- Ordin ANRE nr. 6/2025 (fișier pe portal.anre.ro)
- Ordinul ANRE nr. 199/2020 – Regulamentul pentru acordarea autorizațiilor de înființare și a licențelor în sectorul gazelor naturale (Portal Legislativ)
- Ordin ANRE nr. 199/2020 (fișier pe portal.anre.ro)
- ANRE – Liste publice licențe și autorizații (portal.anre.ro)
- ANRE – Liste publice licențe și autorizații gaze naturale (portal.anre.ro)
- Directive (EU) 2019/944 on the internal market for electricity (EUR-Lex)