In this brief, D’ORNANO PARTNERS’ legal expert in Romania in renewable energy is pleased to provide an analysis of the “New Procedure for Invoicing Green Certificates”.

New Procedure for Invoicing Green Certificates


The Romanian Energy Regulatory Authority (“ANRE”) issued on 12 November 2018 a new Procedure for Invoicing Green Certificates (the “GC Invoicing Procedure”), approved by ANRE Order No. 187/2018 and published in the Romanian Official Gazette No. 953 dated 12 November 2018.

The GC Invoicing Procedure is applicable to:

electricity suppliers, in respect of invoicing/regularization of the green certificates to end consumers;
electricity producers providing electricity to consumers connected through direct lines to their power plants, in respect of the invoicing/regularization of
the green certificates to end consumers;
distribution operators, others than the concessionary distribution operations, which resell electricity acquired from one or more electricity suppliers to end
consumers connected to their electricity distribution network,

and determines how invoicing is done, how regularisation shall be made as well as the reporting obligations regarding invoicing/regularization of green certificates for the electricity invoiced/supplied to end consumers.

Electricity suppliers are the ones that will invoice the counterpart of green certificates to end consumers for the electricity invoiced within the invoicing period; the counterpart of green certificates shall be evidenced separately on the invoice. Yearly regularization of the counterpart of the green certificates used for the quota of green certificates for the previous year is made by electricity suppliers after the end of the invoicing process for the electricity supplied to end consumers during the previous year and is evidenced separately in the invoices issued.

Invoicing in accordance with the GC Invoicing Procedure shall being 1 March 2019 and the yearly regularisation in accordance with such procedure shall begin on 1 April 2019.

Electricity suppliers, electricity producers providing electricity to consumers connected through direct lines to their power plants and distribution operators, others than the concessionary distribution operations, which resell electricity acquired from one or more electricity suppliers to end consumers connected to their electricity distribution network shall prepare their own operational procedures for invoicing green certificates. Such operational procedures shall be sent to ANRE, for information, as follows: (a) 45 days after obtaining the relevant licence, in case of the economic operators authorised after the entrance into force of the GC Invoicing Procedure; or, as the case may be, (b) 45 days as of the entrance into force of the GC Invoicing Procedure, in case of economic operators that sell electricity to end consumers at the date of entrance into force of the GC Invoicing Procedure.


For further information, please contact Cristina Gavrilă, Partner in our law firm’s office in Bucharest, Romania.

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