# RALS Jurisdiction Package — Romania (RO)
URL: https://www.rals.energy/jurisdictions/ro/
Version: 0.1 | Status: active | Last reviewed: 2026-05

## Focus
ATR auction system (2026). Readiness inflation. Cartea Funciară land title. CfD in development.

## Readiness Levels (L0–L4) in Romania

## Risk Taxonomy

### Land Rights Not Secured [HIGH]
Buyer impact: No enforceable right to build. Landowner can withdraw.
Lender impact: Construction financing requires long-term arenda for all key parcels.

### Land Not Registered in Cartea Funciara (CF) [HIGH]
Buyer impact: Unregistered land creates title uncertainty. Construction permit cannot be issued without CF registration. Buyer may be unable to complete acquisition.
Lender impact: No mortgage can be registered on unregistered land. Security is void.

### ATR Not Valid or Not Backed by Financial Guarantee [HIGH]
Buyer impact: ATR without 5% financial guarantee (ANRE Order 20/2025) is at risk of lapsing. Expired ATR has no connection right.
Lender impact: No construction financing without a valid, guaranteed ATR and connection contract.

### Grid Capacity Constraints (Dobrogea) [HIGH]
Buyer impact: Transelectrica's Dobrogea grid is severely saturated. Over 60 GW of projects hold ATRs; actual connection capacity is a fraction of this. New connections require major grid reinforcement (2–6 year timelines and significant costs).
Lender impact: ATR in Dobrogea should be independently verified with Transelectrica. Even valid ATRs may not result in timely physical connection.

### ATR Auction Queue Status Unconfirmed (Post-2026 Rules) [MEDIUM]
Buyer impact: From 1 January 2026, new grid capacity is allocated via ANRE auction. Projects without confirmed auction participation may lose grid access rights.
Lender impact: Auction status must be confirmed before assuming connection is available.

### Permitting Not Started [HIGH]
Buyer impact: Permitting in Romania can take 12–36 months. Start date is unknown.
Lender impact: No debt appetite without at least environmental permit application submitted.

### Permit Under Administrative Contestation [CRITICAL]
Buyer impact: Contestatie can suspend or annul environmental or building permit.
Lender impact: Hard blocker for construction financing.

### Unresolved Environmental or Natura 2000 Constraint [MEDIUM]
Buyer impact: Romania has extensive Natura 2000 designations, particularly in Dobrogea (Delta Dunarii). Projects in or near these areas face heightened scrutiny and potential design constraints or prohibition.

### Revenue Route Not Confirmed [HIGH]
Buyer impact: Without confirmed PPA or GC entitlement, revenue is fully merchant-exposed. Romanian merchant prices (OPCOM) are volatile and below Western European levels.
Lender impact: No construction financing without committed revenue.

### CfD Revenue Assumed but Not Awarded [HIGH]
Buyer impact: Romania's CfD scheme is under development as of 2026 but no awards have been made. Modelling CfD revenue without an official award notification inflates projected returns.

### Readiness Level Claim Inflation [MEDIUM]
Buyer impact: Romanian market has a pattern of projects marketed as "RTB" or "shovel-ready" without meeting the evidence requirements of L2+. Buyers should verify all readiness claims with documentary evidence before pricing.

### Capex Not Independently Validated [MEDIUM]
Buyer impact: Grid connection cost variability and logistics premiums for Dobrogea wind are material.

### Energy Yield Not Independently Assessed [MEDIUM]
Buyer impact: Desktop estimates carry ±15% uncertainty. Curtailment in Dobrogea must be modelled.

### Curtailment Risk (Dobrogea) [MEDIUM]
Buyer impact: Transelectrica imposes balancing curtailment in the Dobrogea zone. Curtailment can reduce actual generation by 5–15% annually for wind assets.
Lender impact: DSCR base case must include curtailment-adjusted P90.

### No Accessible Data Room [MEDIUM]
Buyer impact: Cannot verify ATR, permit, land, or revenue claims.

### Seller or SPV Identity Unclear [MEDIUM]
Buyer impact: AML/KYC and foreign ownership screening required.

### SPV Ownership or Title Unclear [HIGH]
Buyer impact: Encumbered SPV shares prevent acquisition.

### Romanian Regulatory Risk [MEDIUM]
Buyer impact: Romania has a history of retroactive policy changes (2014 GC cuts, subsequent moratoria). The new 2026 ATR auction system creates transition risk for existing ATR holders. CfD scheme development is uncertain in timing and terms.

## Supported Technologies
Solar PV, Onshore Wind, Battery Storage, Hybrid, Hydro, Biomass

## Regulatory Authorities
energy_regulator: ANRE (Autoritatea Nationala de Reglementare in domeniul Energiei)
energy_regulator_url: https://www.anre.ro
ministry: Ministerul Energiei (Ministry of Energy)
ministry_url: https://energie.gov.ro
permitting_authority: County Council (Consiliu Judetean) for environmental permit; local municipality for building permit (autorizatie de construire); Ministry of Environment for environmental assessment (evaluare impact mediu)

support_scheme_administrator: ANRE / Ministerul Energiei (for future CfD/tender schemes)

## Example Listings
- Project Arges Storage | Battery Storage | 100 MW | L2 Investment Memo Ready
- Project Câmpia | Solar PV | 48 MW | L1 Screenable

Source YAML: https://github.com/mahlerhutter/rals/tree/main/jurisdictions/ro/
Not legal advice. Verify with qualified local counsel.