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The Ministry of Energy brings essential answers, but a few critical issues remain unresolved and could make all the difference ahead of the July 11 submission deadline.
The Ministry has published a comprehensive set of 132 official Questions & Answers (Q&A) designed to clarify the participation rules for the second round of the Contracts for Difference (CfD) scheme. This release comes at a crucial time, addressing some of the most pressing concerns raised by stakeholders.
We acknowledge this important step in improving clarity and transparency, however, we will formally submit a set of technical observations. While many answers are well-intentioned, some remain impractical in real-world scenarios and could lead to confusion or unintended risk if left unaddressed.
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CRITICAL ISSUES THAT REQUIRE IMMEDIATE CLARIFICATION
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1. Question 103 – The ATR (Technical Connection Approval) must reflect the monitoring of CfD-designated capacity only if metering occurs on the public network. For partially connected capacities measured on the internal network of the producer, this requirement cannot be fulfilled via the ATR.
2. Question 102 – Metering data is attributed to OMEPA only when metering is on the operator’s public grid. OMEPA has no authority to read or validate data from meters installed on a producer’s internal network.
3. Question 58 – The requirement to maintain all eligibility conditions throughout the 16–18 year duration of the CfD exposes the producer to excessive and unrealistic legal and financial risks, which cannot be reasonably controlled over such a long period.
4. Questions 1, 40, and 71 – A major contradiction emerges. While Question 1 allows the applicant to acquire the producer after submission, Questions 40 and 71 state the producer must already be owned at the time of submission. These positions must be reconciled urgently.
5. Question 100 – Although the response clarifies that losses between the CfD meter and the grid connection point are not eligible for settlement, there is no accepted methodology provided for how to allocate losses in systems with multiple internal meters or physical metering points at the grid entry.
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ESSENTIAL CONCLUSIONS FROM THE NEW CFD Q&A
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- The previous 221 Q&As from CfD Round 1 are now considered obsolete by the Ministry. While no legal document officially revokes them, the current stance implies that only the new set applies. TDP believes many of the original answers remain relevant, but legal uncertainty has increased for applicants.
- No further clarification round is planned before the submission deadline. The current calendar is fixed and final.
- The submission of 132 new questions reflects the exceptionally high market interest in the 3,472 MW capacity being auctioned.
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HIGH-IMPACT OPERATIONAL CLARIFICATIONS
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- Q16 – The bid bond must be issued by a bank authorized to operate in Romania. Other financial institutions are not accepted.
- Q21 – The guarantee can only be returned to ineligible applicants. Eligible but unsuccessful bidders will have their bond retained until expiration.
- Q32 & Q39 – Positive imbalances are eligible for CfD settlement. However, volumes sold directly to the balancing market operator are not.
- Q40 & Q41 – Changes in shareholder control are not allowed between submission and contract signing. After signing, such changes do not require notification.
- Q43 – The project location cannot be changed after submission.
- Q58 – The producer must meet the same eligibility conditions as the applicant, contradicting QA1 from the first round (Q72).
- Q60 – Curtailment is allowed during negative price intervals, without penalty.
- Q68 – Energy under CfD cannot be used for storage, a decision that may limit system flexibility and optimization.
- Q104 – Grid reinforcement works are not considered Force Majeure events.
- Q105 – Projects that applied for Modernization Fund support may apply for CfD, provided they are not receiving state aid at the time of signing.
- Q109 – Multiple bids can be submitted for the same project, as long as metering is clearly separated.
TDP PARTNERS – TURNING PROJECTS INTO SIGNED CfD CONTRACTS
With proven experience in the first CfD round and a multidisciplinary team behind every bid, TDP Partners goes beyond consultancy: we deliver a complete strategic pathway, built on rigour, timing, and measurable outcomes. Whether you’re in the early stages or preparing a mature project, this is the moment for fast, informed decisions. CfD Round 2 has a clear, fixed, and highly competitive window of opportunity.
What’s at stake? A 15-year CfD contract, a strengthened position in the Romanian energy market, and access to a robust support mechanism with long-term price stability.
What could be lost? Access to one of the most valuable renewable energy support schemes ever launched in Romania.
Ready to move forward with confidence? Let’s build today your winning strategy.
If you're aiming to secure a CfD contract in this round, there’s no room for assumptions or guesswork. Partner with a team that understands the rules, the risks and how to deliver results.
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