Energy #2 Legislative focus

Executive overview

HIGH IMPACT

AFIR Implementation: Enforcement Framework Established

The Government adopted the national enforcement framework for Regulation (EU) 2023/1804, introducing binding operator obligations and a sanctions regime.

MEDIUM IMPACT

Registered Exporter of Energy Products: Procedure Published

Customs published the procedure implementing GEO 89/2025, making registered status a formal precondition for export.

MEDIUM IMPACT

National Strategy on the Resilience of Critical Entities

A draft Government Decision establishes a coordinated monitoring and reporting framework for critical entities until 2031

MEDIUM IMPACT

Cybersecurity Governance Reform (B53/2026)

A parliamentary proposal strengthens DNSC-led coordination and defines legal protection for good-faith vulnerability reporting.

Legislative Updates

AFIR Implementation: Enforcement Framework Established

What is changing

The Government adopted the Emergency Ordinance establishing Romania’s institutional framework for implementing Regulation (EU) 2023/1804 on alternative fuels infrastructure.

The act designates the Ministry of Energy as coordinating authority and sets national objectives for EV charging, hydrogen refuelling, LNG for heavy-duty transport, shore-side electricity in ports and electricity supply for stationary aircraft, with emphasis on TEN-T corridors and urban nodes.

It introduces:

  • Ad-hoc access obligations
  • Widely accepted payment methods
  • Data transparency and digital connectivity requirements
  • A National Access Point for infrastructure data
  • A contraventional regime triggered 30 days after the national policy framework is approved
  • Repeal of Law 34/2017

Why this matters

The Regulation is directly applicable. The Ordinance activates national enforcement.

Charging operators, hydrogen developers, LNG suppliers and port authorities now operate under a defined compliance and sanctions framework. Data reporting and access rules move from policy alignment to operational obligation.

Next steps (internal)

Operators should assess compliance readiness and monitor adoption of the national policy framework that activates the sanctions regime.

Registered Exporter of Energy Products: Procedure Published

What is changing

The Romanian Customs Authority published a draft Order detailing the registration procedure for the status of registered exporter of energy products under Article 435 (3) of the Fiscal Code.

The measure implements GEO 89/2025 and applies to exporters of gasoline, diesel, kerosene, LPG and biofuels.

Registration will be handled by regional customs directorates, with large taxpayers under Bucharest competence. The Order must enter into force by 1 March 2026.

Why this matters

The measure does not change excise levels but formalises export monitoring.

Exporters must obtain registered status to continue compliant operations. The timeline is short and procedural scrutiny is expected to remain high.

Next steps (internal)

Affected operators should prepare documentation and ensure registration before 1 March 2026.

National Strategy on the Resilience of Critical Entities

What is changing

The Ministry of Internal Affairs published a draft Government Decision approving the National Strategy on the Resilience of Critical Entities and its Action Plan.

The Strategy applies until 2031 and covers energy, transport, financial infrastructure, health, water, digital infrastructure, public administration, space and food sectors.

It formalises a governance model involving CNCPIC coordination, sectoral competent authorities and resilience obligations for designated entities.

The draft is entering interministerial endorsement.

Why this matters

The initiative consolidates resilience oversight under a unified national framework aligned with EU security policy.

Energy and digital infrastructure operators may face increased coordination, monitoring and structured reporting expectations over time.

Next steps (internal)

Operators in covered sectors should assess alignment between existing resilience systems and the Strategy’s reporting and planning model.

Cybersecurity Governance Reform (B53/2026)

What is changing

A parliamentary proposal seeks to amend GEO 155/2024 on cybersecurity and supplement the Criminal Code.

The initiative establishes a DNSC-coordinated interinstitutional committee and clarifies that good-faith vulnerability research conducted without damage does not constitute a criminal offence, subject to strict safeguards and 48-hour reporting.

Why this matters

The proposal refines governance and liability boundaries for vulnerability disclosure.

Energy operators and other regulated entities may need to adjust internal vulnerability management and researcher engagement procedures.

Next steps (internal)

Companies covered by GEO 155/2024 should review vulnerability reporting protocols and monitor parliamentary developments.

Next procedural steps

AFIR Implementation: Enforcement Framework Established

Decision landscape

Government
Ministry of Energy (coordinating authority)

Next legislative step

Adoption of the national policy framework and issuance of implementing acts

Registered Exporter of Energy Products: Procedure Published

Decision landscape

Romanian Customs Authority
Ministry of Finance

Next legislative step

Adoption and publication of the Order before 1 March 2026

National Strategy on the Resilience of Critical Entities

Decision landscape

Ministry of Internal Affairs
Interministerial endorsement process

Next legislative step

Government approval of the Strategy and Action Plan

Cybersecurity Governance Reform (B53/2026)

Decision landscape

Parliament
DNSC (institutional lead)

Next legislative step

Committee reports and plenary debate