August 18, 2026 • By Vasilii Smirnov
Two neighbouring markets, two different procedures, and the same underlying question: what does it cost to hold a place in the queue, and what does the asset earn once it is connected. This is the practical version of grid access in Romania and Bulgaria as the rules stand in August 2026, with the money named at each step.
Until recently a connection request in South-Eastern Europe was cheap to make and expensive to abandon only for the network operator. Both countries have now inverted that. Romania raised its guarantees in May 2026 and put deadlines on the authorisation stage. Bulgaria attached a deposit to the operator's connection opinion. The direction is identical: a request for capacity you do not intend to build now costs real money on the day you make it.
That matters more than the tariff itself. The technology is settled and equipment prices fell 45 percent in a single year. What decides whether a project exists is whether it can hold a viable connection point long enough to be built, and whether the developer can carry the deposits while it does.
The framework is ANRE Order 59/2013 with subsequent amendments, most recently Order 15/2026. The sequence is fixed and worth knowing precisely, because the deadlines now run against you.
The extension on the authorisation stage exists but is narrow: once, for a maximum of 12 months, and only for reasons that are documented and not attributable to the applicant. Losing the deadline means losing the position.
Two costs are routinely confused, and the difference between them is three orders of magnitude.
On top of that sit the guarantees introduced in May 2026:
For a 50 MW project that is one million euro to enter the auction and 1.5 million for the authorisation, before the connection tariff and before any equipment. The regulator was explicit that this is a selection instrument rather than a penalty: the 5 percent guarantee introduced in 2024 had failed to filter out projects reserving capacity with no intention to build.
Bulgaria rebuilt its connection rules with Ordinance No. 6 of the Energy and Water Regulatory Commission, adopted on 28 March 2024 and in force from 2 April 2024. It set out, for the first time, a dedicated procedure for storage facilities rather than treating them as generation.
The storage route has three stages, and each is a separate document rather than a milestone inside one contract:
Which operator you deal with depends on size. Projects up to and including 1 MW go to the territorially competent distribution operator; above 1 MW the applicant chooses an operator in the relevant territory. For renewable generation the threshold for connecting to the transmission operator ESO moved from 5 MW to above 10 MW, with everything up to 10 MW on the distribution grids.
One provision saves a great deal of time and is easy to miss: no connection procedure is required at all where a storage facility is built at an existing or new site without changing the connected capacity of the production or consumption point. Co-locating storage inside an existing connection is procedurally a different animal from asking for new capacity.
Bulgaria also moved the starting gate earlier for renewables. A developer can now open the procedure on the basis of in rem rights over the land, where previously a design visa or an approved detailed development plan was required. That lets the preliminary agreement be secured while zoning runs — though in practice the two-year validity of that agreement is often not enough to finish zoning and environmental procedures for wind.
The financial filter sits at a different point in the process than in Romania. Storage investors must provide a deposit or bank guarantee of BGN 50,000 per MWh of capacity to be connected, roughly 25,600 euro per MWh at the fixed lev rate. It is due upon receipt of the operator's opinion on the connection request, with a three-month deadline from the date the opinion is issued. If the investor never applies for a preliminary connection contract, the operator deducts from the guarantee the costs it incurred securing system access for the site.
Note the unit. Romania charges against power and against the connection tariff; Bulgaria charges against energy. For a 50 MW two-hour system, 100 MWh, the Bulgarian deposit is on the order of 2.5 million euro. For a four-hour system of the same power it doubles. Duration is not only an engineering choice in Bulgaria — it is a cash flow decision at the connection stage.
The reason capital tolerates these deposits is that South-Eastern Europe currently pays more for storage than anywhere else on the continent. An ENTSO-E study put average daily earnings at 800 euro per MW of installed capacity in Hungary, 798 in Bulgaria, 797 in Greece and 792 in Romania — the four highest in Europe.
The cause is structural rather than clever market design. Interconnection between South-Eastern Europe and the cheaper markets of Central Europe is weak. Solar output depresses wholesale prices through the middle of the day; in the evening peak, limited local flexibility and reliance on imports set a much higher price. The spread between those two states of the same day is the revenue, and weak interconnection is what stops it from being arbitraged away by neighbours.
That is a real advantage and it is also a warning label. The number exists because storage is scarce and the borders are thin. Both conditions are being actively removed.
Romania ended 2025 with close to 600 MW of installed storage. As of 1 June 2026 ANRE data showed 143 projects totalling 9,147 MW in advanced development, of which 36 projects and 2,050 MW were scheduled to enter operation during 2026. That is more than a tripling of the installed base inside one year, from a pipeline fifteen times its size.
Bulgaria reached roughly 2,500 MWh by the end of 2025 and is among the top five EU markets by new capacity, on the back of the EU-funded RESTORE programmes: 13.7 GWh allocated across 113 projects worth over 1.3 billion dollars, with contracts reported for around 6,000 MWh under the tender programme.
Germany shows what happens next. The arbitrage spread for a two-hour system there averaged 140 euro per MWh in summer 2025 and fell to 79 euro per MWh by the fourth quarter, a 44 percent compression inside two quarters, driven by storage capacity itself arriving on the system. There is no mechanism that exempts Bucharest or Sofia from the same arithmetic.
The practical consequence for a financial model: a spread observed in 2026 and held flat for fifteen years is not a forecast. It is an assumption, and it belongs in the assumptions register where a lender's reviewer can argue with it, not buried in a revenue line.
Romania has 1,530 renewable projects with a combined approved evacuation capacity of 91,118 MW in the connection process, while operators expect 647 projects totalling 30,366 MW to actually be commissioned between 2026 and 2035. The queue is roughly three times what the network expects to connect. A position in that queue is not the same thing as a project.
This is exactly what the new guarantees are designed to thin out, and it is why the choice of connection point matters more than the choice of supplier. A node that clears with modest reinforcement and a node that requires a new line can differ by 20 percent of total capex — and that difference is decided before a single container is ordered.
None of this replaces a local attested designer, and we do not sign Romanian design documentation. What we do is the engineering reasoning behind the request, before the money is committed against it.