Source review: 1 November 2026. Final procedural status remains to be confirmed before reliance.
The May 2026 grid and licensing changes must be analysed as adopted rules, not as a consultation still awaiting enactment. Orders 15/2026 and 16/2026 affect different parts of the same project file. The earlier draft-stage commentary is replaced here by a focused current-law orientation checked on 1 November 2026.
Two instruments, different obligations
Order 15/2026 amends the connection framework and related documents. Order 16/2026 changes the licensing and authorisation regulation. A project review should identify each obligation’s trigger and beneficiary rather than combine the instruments into one generic “new guarantee”.
Grid security and project history
The new 20% principal grid-security rule has its own scope and transition. Retrieve the operator’s original guarantee-amount communication: a historical instrument must not automatically be repriced simply because today’s general rule differs. Separate original security, extension security and any auction instrument in the cash-flow model.
Filing, obtaining and extending are different decisions
The establishment-authorisation filing period, the date by which authorisation must be obtained, and an extension request are separate tests. Assemble the ATR, signed connection agreement, filing receipts, completeness correspondence and expiry dates. The applicable route depends on the project’s history and statutory transitions.
A project guarantee is not a licence to operate
The EUR 30/kW security addresses the authorisation workstream; it does not establish compliance with the commercial-operation licensing, grid or technical rules. The statutory completion and release milestones need to be checked independently from COD assumptions.
Bankability and transaction controls
For buyers and lenders, document unresolved authorisation, land, grid and guarantee conditions in one issue register. Translate material risks into completion conditions, price retention, funding commitments or specific protections. Legal readiness does not guarantee technical performance, financing approval or projected returns.
Drafts remain a separate evidence category
The August 2026 guarantee-procedure consultation must not be used to convert proposed duration rules or BESS exemptions into enacted requirements. This review has not verified final adoption of that procedure. Confirm the published instrument before an instrument is issued or a transaction relies on an exemption.
Questions and answers
Are the May 2026 reforms still only proposals?
No. Orders 15/2026 and 16/2026 were published in May 2026. Distinguish their adopted provisions from later consultation documents.
Does the 20% rule automatically replace every historical guarantee?
No. Its scope and transitional treatment must be checked against the operator correspondence and the applicable project documents.
Official sources
For project-specific review, discuss the documents with our team.