Procedures for licensing applications for electricity storage facilities and general conditions of the restricted network access agreement

1) New Procedures for Licensing Applications for Electricity Storage Facilities

The increasing integration of renewable energy sources into the National Electricity System (Sistema Elétrico Nacional – SEN) has driven the need to construct electricity storage facilities.

In response to the need for clarification of the applicable procedures for the licensing of these facilities, the Directorate-General for Energy and Geology (Direção-Geral de Energia e Geologia – DGEG) has issued Order No. 1859/2025, dated 10 February, which sets forth a series of rules to be followed when submitting such applications.

a) Scope of Application and Applicable Procedures

The scope of this Order encompasses all applications for the licensing of electricity storage facilities submitted under subparagraphs (c) and (e) of Decree-Law No. 15/2022, dated 14 January (DL 15/2022), where injection capacity into the Public Electricity Network (Rede Elétrica de Serviço Público – RESP) has already been allocated, and where such applications fall under one of the situations exhaustively defined by the DGEG, namely:

1. Modification of technology within an unbuilt solar photovoltaic power generation center that holds a valid capacity reservation title (Título de Reserva de Capacidade – TRC), provided that the conditions regarding the provision of financial guarantees and the TRC requirements under the general access regime, as stipulated in DL 15/2022, are met; or
    
2. Autonomous or co-located storage, utilizing:
   1. Power generation center(s) using renewable energy sources, with a capacity reservation in the RESP already allocated under a TRC issued in the general access regime;
   2. Small production units (Unidades de Pequena Produção – UPP) with a registered permit; or
   3. Self-consumption production units (Unidades de Produção para Autoconsumo – UPAC) with an installed capacity exceeding 1 MW and an injection capacity into the RESP greater than 1 MVA.

The applicable procedures for cases (i) and (ii) are detailed in Articles 4 and 5 of the Order, respectively. These provisions establish the rules and requirements for the licensing of electricity storage facilities, including the necessary documentation and the procedural steps for submission to DGEG.

b) Technical Conditions

This Order also establishes a set of technical and operational requirements aimed at ensuring that storage facilities contribute to the stability, efficiency, and security of the SEN, in alignment with both national and European standards.

Among the key requirements are the following:

• Real-time communication with the Global System Operator;
• Mandatory participation in network balancing mechanisms, such as frequency reserves and energy restoration;
• Provision of network services, including voltage control and primary reserves.

c) Digital Submission of Applications

Applications for licensing covered by this Order must be submitted via the electronic platform provided for in Article 15 of DL 15/2022.

Until the platform becomes operational or in the event of temporary unavailability, applications must be submitted digitally to DGEG via the email address provided on its official website (licenciamento.producao@dgeg.gov.pt). The subject line of the email should be formatted as follows:

"Despacho n.º 1859/2025: Pedido de instalação de armazenamento — […nome…]".

("Order No. 1859/2025: Application for Electricity Storage Installation – [Applicant Name]")

Order No. 1859/2025, dated 10 February, enters into force on 11 February and can be accessed here (only available in Portuguese).

2) General Conditions of the Restricted Network Access Agreements for Production or Storage Facilities

On 6 February, the Energy Services Regulatory Authority (Entidade Reguladora dos Serviços Energéticos – ERSE) published Directive No. 3/2025, which entered into force on 7 February.

This Directive establishes the general conditions for Network Access Agreements with restrictions for production or autonomous storage facilities, under the framework of the Network Access and Interconnection Regulation (RARI), approved by Regulation No. 818/2023, dated 27 July.

Pursuant to the Directive, the Network Access Agreement is to be executed between the holder of the power generation center or storage facility and the operator of the RESP. The agreement's objective is to regulate restricted access to the network and to define the functions, responsibilities, requirements, rights, and obligations of both the facility owners and the network operator to which the facility is connected.

Directive No. 3/2025, dated 6 February, and the approved general conditions can be accessed here (only available in Portuguese).