A. Energy Storage Auctions
Following the publication of Orders no. 12924-B/2026 and no. 12924-C/2026, which launched the competitive procedures for the award of injection capacity reservation titles in the Public Service Electricity Network (“RESP”) for (i) standalone electricity storage facilities and (ii) co-located storage facilities, the tender documents for both procedures have now been published on the official website of the Directorate-General for Energy and Geology (“DGEG”).
The procedure programme and tender specifications for standalone storage facilities are available here, while the tender documents for co-located storage facilities are available here.
B. Order no. 12991-A/2026: Prior Control Procedures Applicable to Storage Facilities
Order no. 12991-A/2026, dated 23 October 2026 (“Order no. 12991-A/2026”), has been published, establishing the procedures for obtaining the prior control titles required for the development and operation of electricity storage facilities, namely a production licence and an operating licence or, depending on the installed capacity, prior registration and an operating certificate, pursuant to Article 11 of Decree-Law no. 15/2022, of 14 January.
The new Order, which repeals Order no. 1859/2025, establishes, among other matters:
- the documentation and information required to support applications for the licensing of standalone storage facilities and co-located storage facilities (see Articles 3 and 4 of Order no. 12991-A/2026);
- the documentation and information required for the prior registration of storage facilities (see Article 5 of the same Order); and
- the procedure applicable to the relevant applications (see Article 8).
As a general rule, procedures pending on the date on which the new Order entered into force will continue to be governed by the rules applicable on the date on which the relevant applications were submitted (see Article 10(1) of Order no. 12991-A/2026).
However, a specific transitional regime applies to pending procedures concerning applications to convert solar photovoltaic power plants into standalone storage facilities, submitted pursuant to Article 4 of Order no. 1859/2025. In these cases, DGEG must notify the applicants within 30 days of the entry into force of Order no. 12991-A/2026, allowing them to choose between (i) adapting their applications to the new regime or (ii) withdrawing them.
Order no. 12991-A/2026 entered into force on 24 October 2026.
For further information, Order no. 12991-A/2026 is available here.
