Amendment to Ministerial Order No. 433-A/2026/1 and Frequently Asked Questions (FAQs) on Decree-Law No. 100/2026

(i) Ministerial Order No. 433-A/2026/1, of 21 September

Ministerial Order No. 433-A/2026/1, of 21 September, which lays down the procedural rules, supporting documentation requirements and procedural workflows applicable to the procedures established under Decree-Law No. 100/2026, of 22 May, was recently amended by Ministerial Order No. 499-A/2026/1.

The amendment consists of the repeal of Article 20(1)(e), which required applications for hybridisation to specify the “intended charging capacity through the RESP” whenever the additional technology to be installed consisted of an energy storage system.

According to the preamble to Ministerial Order No. 499-A/2026/1, this amendment seeks to ensure that the procedural framework is consistent with the concept of hybridisation set out in Article 28(1) of Decree-Law No. 100/2026, which, as stated in the Ministerial Order, does not encompass energy storage systems, since these do not constitute additional power generation technologies.

The aforementioned Ministerial Order enters into force on 13 November 2026.

For further information, you may consult the full text of Ministerial Order No. 499-A/2026/1 here.

(ii) Frequently Asked Questions (FAQs) on Decree-Law No. 100/2026

The Directorate General for Energy and Geology (DGEG) has published a document containing 28 Frequently Asked Questions (FAQs) on the application of Decree-Law No. 100/2026.

Prepared on the basis of questions submitted by project developers, the document provides clarification on the principal mechanisms and procedures established under Decree-Law No. 100/2026, with a view to facilitating their understanding and contributing to the consistent application of the new framework.

The document is available here.