Amendments to the UPAC and Electricity Aggregation Regimes | Law No. 29/2026 of 23 June

Law No. 29/2026 of 23 June (Law No. 29/2026) has been published, introducing significant amendments to the legal regime applicable to self-consumption production units (UPACs), as well as to the activity of electricity aggregation.

The key changes introduced by Law No. 29/2026 include the following:
 

1. Creation of the Renewable Energy Use Agreement (CAER)

Law No. 29/2026 introduces the regime of CAERs, under which property owners may assign energy use rights over their properties - including rooftops, terraces, undeveloped urban land and areas without relevant agricultural, livestock or forestry use - for the installation of UPACs with an installed capacity of up to 1 MW, using renewable primary energy sources (see Article 2(1) and (2) of Law No. 29/2026).

CAERs must be executed in writing and may have a maximum term of 15 years, renewable once for an equal period (see Article 4(1) and (3) of Law No. 29/2026).

The CAER regime is to be regulated by Government ministerial order within six months of the entry into force of this law, including the approval of a standard-form contract.
 

2. Deemed approval of applications for UPAC production and operation licences

Law No. 29/2026 also amends Decree-Law No. 15/2022 of 14 January (Decree-Law No. 15/2022), in particular as regards the licensing of UPACs.

In this context, the production licence for self-consumption must now be issued within a maximum period of 90 days, failing which the application will be deemed approved (see Article 14(2) of Decree-Law No. 15/2022).

The same deadline now applies to the operation licence, which must also be issued within a maximum period of 90 days, failing which the application will likewise be deemed approved (see Article 14(3)(c) of Decree-Law No. 15/2022).
 

3. Amendments to the electricity aggregation activity

Law No. 29/2026 also amends Article 148 of Decree-Law No. 15/2022, with particular focus on the activity of last resort aggregation.

Among the approved amendments, of particular note is the provision that the remuneration for electricity supplied to the Public Service Electricity Grid (RESP) under this activity shall be defined by ministerial order issued by the member of Government responsible for energy (see Article 148(4) of Decree-Law No. 15/2022).

In addition, the free comparison tool made available by the ERSE for the comparison of suppliers’ offers will also cover aggregators’ offers, including, on a mandatory basis, the offer of the last resort aggregator (see Article 184(2) of Decree-Law No. 15/2022).

Law No. 29/2026 applies to all proceedings pending before the Directorate-General for Energy and Geology (DGEG), without prejudice to any acts already carried out, and enters into force on 1 July 2026.

For further information on Law No. 29/2026 of 23 June, please consult the full text here.