News from the Energy Sector

1. Remuneration Regime Applicable to the Hybridisation of Electricity Generation Centres resulting from the 2019 Tender Auction – Explanatory Note No. 6/DG/2025

On 7 November, DGEG published Explanatory Note No. 6/DG/2025, which clarifies that the remuneration regime for electricity generation centres licensed on the basis of Capacity Reserve Titles (‘TRC’) awarded in the 2019 and 2020 tender auctions, which have been hybridised with storage systems, depends on the conditions set out in the respective competitive procedures and applicable legislation, distinguishing the treatment of energy from storage, particularly in terms of remuneration and contribution to the National Electricity System (SEN), in the case of those resulting from the 2019 tender auction.

The 2019 Tender Procedure, opened under Order No. 5532-B/2016 of 6 June, determined the allocation of injection capacity reserves at connection points to the Public Service Electricity Network for photovoltaic solar energy and the respective applicable remuneration regimes, without considering the possibility of hybridisation of the power plant through a storage system. In the case of the 2020 Tender Procedure, however, the option was different, with the possibility of integrating a storage system being included, provided that the requirements set out in the Tender Specifications were met.

Thus, with regard to the 2019 tender procedure, as it did not provide for the possibility of storage, it is understood that the remuneration scheme awarded only applies to energy corresponding to the TRC, and energy from the storage system is not subject to payment of the contribution to the SEN. Energy from the storage system is remunerated at a price freely determined on organised markets or through bilateral contracts, as established in Article 17 of Decree-Law 15/2022 of 14 January.

Explanatory Note No. 6/DG/2025 can be consulted here.

2. Public consultation on the draft decree-law transposing the European Directive on Energy Efficiency

The Decree-Law transposing Directive 2023/1791 (EED) of the European Parliament and of the Council of 13 September on energy efficiency has been submitted for public consultation.

Under this Directive, it is necessary to amend the regulatory and legislative framework on energy efficiency, involving, among other things, changes to the legal regime applicable to contracts to be concluded between the State and Energy Service Companies, under the terms of Decree-Law No. 50/2021, of 15 June, and partially repealing Decree-Law No. 68-A/2015 of 30 April.

The Directive to be transposed sets a collective target for Member States to ensure an additional 11.7% reduction in energy consumption by 2030, compared to the target set for 2020. To this end, Member States must set and comply with indicative national contributions, defined according to a set of objective criteria and subject to their suitability to their respective internal realities. In addition, the Directive establishes common measures to meet the targets set for 2030.

The main measures to be transposed are as follows:

• National energy saving plan: definition of rules and criteria for allocating the estimated savings to be achieved.
• Inventory of public buildings: reference base with specific information to identify and prioritise renovations targeting nearly zero-energy or zero-emission buildings.
• Energy Efficiency Management Contracts (EEMCs): review of terms, including the possibility of conclusion by private entities subject to defined requirements.
• Energy management and audits in companies: rules for energy management systems, audits, registration and self-assessment of consumption, duties and procedures.
• Heating and cooling: criteria for assessing and exploiting production and distribution potential at national and local levels.

The public consultation ends on 5 December and can be viewed here.