Ministerial Order No. 433-A/2026/1, of 21 September, has been published, implementing the regime for the dynamic management of injection capacity in the public electricity grid (RESP) established by Decree-Law No. 100/2026, of 22 May. The Ministerial Order sets out the procedural rules, required information, forms, deadlines and workflows applicable to applications for greater flexibility in relation to injection capacity reserve titles (TRCs), including splitting, aggregation, waiver, exchange and transfer, changes to generation technology, hybridisation, partial capacity reductions and changes to the interconnection point. The deadlines for submitting these applications commenced on 22 September 2026 and are counted in working days.
Ministerial Order No. 433-A/2026/1, of 21 September, has been published, setting out the procedural rules, required information, forms, operational deadlines and processing workflows applicable to procedures for the dynamic management of injection capacity in the public electricity grid (RESP), as well as the rules on the provision of information on injection capacity per interconnection point by network operators.
This Order implements Decree-Law No. 100/2026, of 22 May, which established a supplementary regime to Decree-Law No. 15/2022, of 14 January, governing the dynamic management of injection capacity in the RESP following the allocation of the injection capacity reserve title in the RESP (TRC).
This regime addresses limitations identified in the existing legal framework by introducing mechanisms for more flexible, efficient and transparent management of TRCs already allocated and of pending applications for TRC allocation, through procedures for the splitting, aggregation, waiver, exchange and transfer of TRCs, as well as for changes to generation technology, hybridisation, partial reduction of capacity and changes to the interconnection point. The procedures available vary depending on the method of allocation of the TRC in question.
The Ministerial Order now published stipulates that the deadlines for submitting the various applications for TRC flexibility under Decree-Law No. 100/2026, of 22 May, commence on 22 September 2026, the date on which the Ministerial Order enters into force. Furthermore, it clarifies that the deadlines for submitting applications provided for in that Decree-Law are procedural in nature and are counted in working days.
Morais Leitão’s Energy and Natural Resources team will continue to closely monitor developments relating to this legislation and its implementing regulations, and remains fully available to address any questions that may arise.
