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The 36-Month CfD Clock Is Ticking: How Many of Romania’s 4.2 GW of CfD-Awarded Projects Will Actually Hit COD on Time?

CfD

Romania has spent the past eighteen months building one of Central and Eastern Europe’s most credible renewable energy support frameworks. Across two Contracts for Difference (CfD) auctions, the country awarded a record 4.2 GW of wind and solar capacity, comfortably overshooting the 3.5 GW target set under its Recovery and Resilience Plan. A third, wind-only round added roughly 316 MW more at the end of 2025.

The headlines wrote themselves. Solar bids cleared as low as €35.50/MWh. Europe’s largest planned solar park, the 1 GW-plus Dama Solar project, secured support. International developers backed by serious capital lined up to participate.

But awarding capacity and delivering capacity are two very different things. Every one of those CfD contracts carries a clause that will define whether Romania’s auction success becomes a genuine buildout: a 36-month commercial operation date (COD) deadline. The clock is already running. The real question for 2026 and beyond is not how much was awarded, but how much will actually reach the grid on time.

What the 4.2 GW Actually Represents

The numbers are worth restating clearly, because they frame everything that follows.

Romania’s first CfD auction, concluded in December 2024, allocated roughly 1.5 GW, split between about 1,096 MW of onshore wind and 432 MW of solar. The second auction in August 2025 was the larger of the two, awarding 2,751 MW: 1,488 MW of solar across 26 bids from eight companies, and 1,260 MW of wind across 23 projects. Combined, the two rounds delivered the 4.2 GW figure that has become Romania’s renewable energy calling card.

The pricing told its own story. In the second round, winning solar bids averaged around €40/MWh against a ceiling of €73/MWh, while wind cleared at an average near €74/MWh. The whole programme is underpinned by roughly €3 billion from the EU Modernisation Fund, structured as a 15-year, two-way CfD. When market prices fall below the strike price, the state tops developers up; when prices run higher, developers pay the difference back. It is a clean, bankable structure, and the low solar prices show developers believe in it.

The Clause That Changes Everything: 36 Months to COD

Here is where the celebration meets reality. Under the scheme rules, the target commercial operation date must not exceed 36 months from the signing of the CfD contract. Projects that miss it face consequences: performance bonds of €75,000/MW are at stake, and the rules allow for proportional reductions in contract duration, penalties for delay, and termination in default cases, with relief only for genuine force majeure. There is a longstop allowance of up to 24 additional months in defined circumstances, but the headline commitment developers signed up to is three years.

According to project disclosures, most second-auction projects are due online by 16 September 2028. First-round winners such as European Energy’s 126 MW Berești wind farm and Econergy’s Parău 2 solar project targeted construction starts in 2025 and grid connection by the end of 2027. In other words, the deadlines are no longer abstract. The earliest projects are now well inside their delivery windows, and the largest cohort has a hard 2028 horizon.

For solar, that timeline is demanding but achievable. For wind, it is genuinely tight, and the market has already said so.

The Warning Signs Are Already Visible

The clearest signal came from the second auction itself. The wind segment was undersubscribed: only 1,260 MW was awarded against a 2,000 MW target. A subsequent third round, launched specifically to mop up the unallocated wind quota, cleared just 316 MW.

Why would developers walk away from guaranteed 15-year revenue support? Aurora Energy Research offered a pointed diagnosis. Filippos Falieros, a project leader at the firm, noted that applying the same commercial operation date to both solar and wind has disincentivised wind participation, because wind projects are far more complex. Their permitting, grid connection, and EPC timelines run significantly longer than solar’s, which makes a uniform 36-month deadline misaligned with how wind projects actually get built. Aurora also observed that with increased costs and stricter eligibility rules, some developers may simply see more value outside the CfD framework, in power purchase agreements and merchant structures that avoid the capped strike price and the rigid deadline altogether.

This is the central tension. The 36-month clock is exactly what makes the scheme disciplined and credible. It is also exactly what makes the wind portion of the 4.2 GW hardest to deliver.

The Grid Is the Real Bottleneck

Even a perfectly managed project cannot reach COD if it cannot connect. And grid access is where Romania’s delivery risk concentrates most heavily.

The scale of the queue is staggering. As of mid-2025, ANRE reported that over 1,200 projects holding valid connection permits represented around 60 GW of capacity, far beyond what the network can physically absorb. Transelectrica, the transmission system operator, has acknowledged that lines and substations in several regions can no longer handle additional flows without modernisation or expansion. The operator’s 2024 to 2033 development plan envisions roughly €1.9 billion in investment, but infrastructure is not keeping pace with investor appetite.

The data on conversion rates is sobering. According to ANRE statistics cited during recent grid reform consultations, of the projects that posted connection guarantees, only around 12% went on to sign connection agreements, just 3% obtained building permits, and a mere 1% reached full readiness. Those figures describe the broader pipeline rather than CfD winners specifically, but CfD projects draw from the same congested grid and the same overstretched operator.

Romania is overhauling the system in response. From January 2026, the old first-come, first-served connection regime is being replaced by a competitive, auction-based capacity allocation mechanism, with financial guarantees rising sharply to deter speculative applications. The intent is sound: filter out the phantom pipeline and prioritise shovel-ready assets. But the transition itself introduces uncertainty. The first capacity auction has already slipped from January to an expected October 2026 date, and law firms tracking the reform warn that further delays cannot be ruled out while grid studies are completed. For a CfD project racing a 36-month clock, a connection process that is largely outside the developer’s control and prone to delay is the single biggest threat to hitting COD.

So How Many Will Make It?

No one can put a precise percentage on it yet, and anyone who claims to is guessing. But the evidence points to a clear, differentiated picture.

The solar share looks relatively secure. Romania installed roughly 2.2 GW of solar in 2025 alone, pushing cumulative capacity past 7 GW, and utility-scale buildout nearly doubled year on year. The country has demonstrated it can move solar from permit to grid in 1.5 to 2 years when land and connection are in place. The solar-heavy first auction and the 1,488 MW of second-round solar sit in the more deliverable category, with the notable caveat that giant projects like Dama Solar carry execution complexity simply by virtue of scale.

The wind share is where the risk lives. Longer permitting, environmental assessment, aviation and defence constraints, turbine logistics, and harder grid integration all compress against a deadline built around solar timelines. The undersubscribed wind auctions are arguably an early, honest market verdict: a meaningful slice of the wind capacity Romania wanted simply did not bid, and some of what did win will struggle against the calendar.

The likely outcome is not a clean success or a failure. It is a split: strong solar realisation, more fragile wind delivery, and an overall total that lands below the full 4.2 GW unless grid reform delivers faster than its own track record suggests. The projects most likely to hit COD on time share a common profile that legal analysts now describe as the 2026 standard for value in the market: a mature permitting package, a strong and real grid position, and a credible COD timeline. Pipeline inflation is over. Discipline has begun.

Momentum Energy’s View

We see Romania’s 36-month clock not as a flaw in the scheme but as the feature that makes it worth taking seriously. Markets that hand out support without delivery obligations end up with inflated pipelines and stranded promises. Romania has chosen the harder, healthier path: real deadlines, real bonds, and a grid reform that forces speculative capacity out of the queue. That discipline is precisely why we believe Romania remains one of the most attractive renewable energy destinations in Central and Eastern Europe.

The fundamentals behind that conviction are strong. Record solar deployment two years running. Strike prices among the most competitive in Europe. A maturing PPA market, a battery storage sector scaling from megawatts to gigawatts, and a 38% renewables target for 2030 that guarantees sustained policy momentum. The capital is there; what the market now rewards is credibility.

For developers and investors, the lesson of the 36-month clock is straightforward. The era of winning capacity on a spreadsheet is closing. The era of delivering it is here. The projects that thrive in Romania from 2026 onward will be the ones that treated grid connection, permitting maturity, and a realistic build schedule as the core of the investment case rather than an afterthought. That is not a reason to be cautious about Romania. It is a reason to be serious about it. The opportunity is real, the framework is credible, and the country has shown it can build. The winners will simply be those who respect the clock.

What is your read on the wind versus solar delivery gap? We would be interested to hear how others are pricing COD risk into their Romanian pipelines.

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