Joint Order no. 1/2026, issued by DGEG and APA, was published on 9 January, dealing with the licensing procedure for biomethane production units.
Decree-Law no. 62/2020 of 28 August establishes the requirement for prior registration with the Directorate-General for Energy and Geology (DGEG) to produce gases from renewable sources, including biomethane. The purpose of this Order is to clarify the relationship between the prior registration and mandatory sectoral licensing, namely environmental and urban licencing.
The following aspects are particularly noteworthy:
- Application of the Prior Registration Regime: Prior registration follows the regime established for the production of renewable gases:
(i) The promoter initiates the procedure by submitting a prior registration application to the DGEG electronically (via the email address combustiveis@dgeg.gov.pt), attaching the elements referred to in Annex VI of Decree-Law no. 62/2020;
(ii) The DGEG analyses the application and consults the network operator and may reject the application in the event of legal or regulatory non-compliance, lack of technical conditions or incomplete documentation.
- Mandatory Sectoral Licensing: As clarified by the Order, after approval of the prior registration, the promoter must prepare and complete the necessary licences:
(i) Environmental licensing through the SILiAmb platform, for which purpose the APA integrates CAE 35210 into the SILiAmb platform and associates the DGEG as the coordinating entity for licensing;
(ii) Urban planning licensing in the territorially competent municipality.
- Registration and entry into operation: The Order also clarifies that the commencement of operations depends on the submission to the DGEG of the environmental and municipal licences and the declaration of conformity of the installation's execution, which are registered. In turn, the declaration of compliance with the execution must be signed by the person responsible for the execution and by the installation entity.
- Supervening Inspection: According to the Order, the DGEG has technical and regulatory inspection powers and may cancel the registration in case of non-compliance.
Joint Order no. 1/2026 came into force on 9 January and can be consulted here.
