Background
The total capacity of applications for connection to the RTN (National Transmission Grid) relating to renewable energy plants currently stands at approximately 314.21 GW, a significant portion of which (140.33 GW and 105.90 GW respectively) is allocated to onshore solar and wind projects, with the remainder (approximately 68 GW) relating to offshore wind, hydroelectric, geothermal and biomass plants.
This figure remains well above the approximately 65 GW of new renewable capacity which, according to the PNIEC (National Integrated Energy and Climate Plan), is expected to be installed by 2030.
Even excluding offshore installations – which, as will be explained below, are excluded from the new rules on grid connections – pending applications exceed 248 GW: almost four times the incremental capacity indicated by the PNIEC.
This comparison confirms the issue already highlighted in our previous article ( link here): the capacity requested does not correspond to the capacity that will actually be built.
A very significant proportion of the allocated capacity is, in fact, still associated with STMGs (General Minimum Technical Solutions) that have yet to be accepted or to grid infrastructure projects that are still under assessment, whereas only a smaller proportion relates to initiatives that have already received the grid operator’s approval.
The sequential mechanism traditionally applied to connection requests has therefore resulted in a grid that is saturated, particularly “on paper”: each new application is assessed on the assumption that all previous requests may ultimately result in projects that are actually capable of reaching the construction stage, creating a dual risk of oversizing the grid’s development and delaying more mature initiatives behind projects that are still at an early stage.
The “DL Bollette”
A little over a year after the first proposals for reform, the regulatory framework has now changed significantly. Reference should be made, in particular, to Article 7 of Decree-Law No. 21/2026 (also known as the “DL Bollette”), under which:
the MASE (Ministry of the Environment and Energy Security) Decree (published on 8 September and whose contents are set out in greater detail below) establishes the functional criteria and operational procedures that Terna is required to follow in connection with the allocation and updating of the maximum additional capacity (see Article 7(2) of the DL Bollette).
Article 10-bis of Legislative Decree 190/2024
In addition, the DL Bollette has significantly amended Legislative Decree No.190/2024 (also known as the “Consolidated Law on Renewables”) by introducing in Article 10-bis new rules governing grid connection solutions, with significant implications both for future allocation of grid capacity and for connection solutions that have already been issued.
The new allocation mechanism
Under the above provision, ARERA is required to update the technical and economic conditions (i.e., essentially the Integrated Text on Active Connections – “TICA”) as well as the procedural arrangements for the connection to the electricity grid of renewable energy and storage facilities, with the exception of offshore installations, providing that:
the national transmission system operator:
may issue connection solutions relating to a connection point even where the relevant capacity exceeds the maximum capacity that can be accommodated at that connection point;
shall allocate the available grid capacity and issue the relevant connection solutions through transparent and non-discriminatory procedures;
shall definitively allocate the available grid capacity to the applicants selected under the aforementioned procedures who hold the relevant authorisation;
as part of its territorial planning activities and allocation procedures, shall take into account connection solutions relating to renewable energy or storage projects which, as at the date of publication of ARERA’s implementing provisions, have obtained a decision granting an exemption from the EIA (Environmental Impact Assessment), or a favourable EIA decision, or a favourable environmental compatibility opinion, provided that the projects in question have been submitted for environmental compatibility assessment together with the technical design of the connection solution, ncluding the related works for the development and upgrading of the national electricity transmission grid.
distribution system operators:
may issue, through transparent and non-discriminatory procedures, connection solutions on the grids under their jurisdiction relating to a connection point, even where the relevant capacity exceeds the maximum capacity that may be accommodated at that connection point;
may issue connection solutions for low-voltage grids also in relation to plants that enter into operation before any interventions that may be necessary on high- and extra-high-voltage grids have been completed;
may adopt any measures necessary to ensure the efficient management of grid capacity, including measures providing for connection solutions to lapse in the event of an unsuccessful outcome of the permitting or authorisation procedures or failure to comply with the deadlines for submitting applications for a PAS (Simplified Authorisation Procedure) or single authorisation (which must be submitted within 90 days of the date on which the grid works project is validated);
The implications for existing connection solutions
Among the most significant changes, particularly with regard to projects that have already been initiated or are in the process of being initiated, are the provisions of Article 10-bis, paragraphs 3, 5 and 6, according to which:
Based on a literal and systematic analysis of Article 10-bis and the Decree, it would appear that the loss of effectiveness applies exclusively to high-voltage connection solutions and not to connection solutions relating to low- or medium-voltage grids.
Indeed, as high-voltage connection solutions concern large-scale plants, they are the solutions that have the greatest impact on the virtual saturation of the grid; furthermore, this interpretation appears to be supported by Article 10-bis, paragraph 3, according to which – in the event of a loss of effectiveness – operators may participate in future procedures launched by Terna, without any reference being made to procedures falling within the remit of distribution system operators.
Moreover, the provision identifies Terna, and not the distribution system operators, as the sole entity responsible for notifying the loss of effectiveness of the connection solutions. This would suggest that the reform in question should not result in connection solutions relating to low- and medium-voltage grids lapsing.
In any event, it should be noted that, in order to obtain a definitive understanding of this issue, it will be necessary to await ARERA’s implementing provisions, which were due to be published by 22 August. Nevertheless, as at the date of this article, they are still pending and, accordingly, the above rules have not yet been implemented in practice.
The MASE Decree
In implementation of the provisions of Article 7(2) of the DL Bollette, on 8 September 2026, MASE signed Decree No. 291 (the “Decree”), which sets out:
As mentioned, however, the reform has not yet become fully operational in its most significant aspects: its practical effects will, in fact, depend to a significant extent on the measures that ARERA is required to adopt pursuant to Article 10-bis, paragraph 1, of the Consolidated Law on Renewables.
Definition of the micro-zones
The Decree confirms the move away from the purely individual management of connection applications.
The new system is based on territorial capacity planning and the creation of a catalogue of technical solutions accessible to operators.
In this context, the first element is represented by the “micro-zones”, the boundaries of which are to be
defined by Terna on the basis, among other things, of the objectives of the PNRR (Italy’s National Recovery and Resilience Plan) and the PNIEC, European, national and regional guidelines, expected developments in supply and demand, and distributors’ forecasts regarding new renewable capacity connected to their respective grids.
As regards the timetable:
Once defined, the methodology, boundaries and number of micro-zones must be updated at least every two years, also in light of the criteria to be established by ARERA.
The connection points and the maximum additional micro-zone capacity
For each micro-zone, Terna must then identify the connection points and the corresponding maximum additional micro-zone capacity on the basis, among other things, of the following criteria:
The maximum additional capacity must be updated at least quarterly, taking into account the permits issued, the status of the grid works, connection requests and the commissioning of the plants.
This represents a significant shift: the snapshot of the grid will no longer be static, but will have to be updated periodically to reflect the actual progress of projects.
The Offer and Open Seasons
One of the main pillars of the reform is the so-called “Offer”, that is, the set of minimum technical connection solutions made available by Terna as part of the capacity allocation procedures (also known as “Open Seasons”), which must be carried out at least quarterly.
In particular, at least thirty days before the opening of each Open Season, Terna must publish the maximum additional micro-zone capacity and the Offer, distinguishing between:
The Decree also strengthens transparency obligations; the TERRA portal must make available information on the location and current and prospective land occupation of all connection points and infrastructure included in the Offer.
Furthermore, for each request submitted to the RTN, Terna must publish the applicant, the technology, the requested injection and withdrawal capacities, the location, any connection solution already issued and, where available, the status of the authorisation process.
As a result, during an Open Season, the applicant will no longer necessarily receive an individually tailored connection solution according to the order in which the application was submitted. Instead, for each request, the applicant will select one of the solutions included in the “Offer”.
At the end of the Open Season, Terna will issue, via the TERRA portal, a “connection solution certificate”, which must subsequently be subject to Terna’s approval in relation to the applicant’s works (i.e., verification of the compliance of the technical documentation concerning the applicant’s works, limited to the interface with the grid facility used for the connection).
In this regard, the Decree clarifies a key point: the certificate, including the relevant approval, is sufficient to initiate the authorisation procedure and supplement the design documentation relating to the connection, but does not constitute a definitive allocation of either capacity or the connection point.
In accordance with Article 10-bis, the number of certificates may in fact exceed both the maximum additional capacity of the micro-zone and the number of physically available connection points.
This introduces a regulated system of overbooking: the system allows multiple projects to compete for the same capacity, on the assumption that only some of them will reach the required level of permitting maturity within the relevant timeframe.
However, the specific rules governing access, selection, priority, guarantees and lapse have yet to be defined by ARERA and will represent the key point of balance between market openness and investment certainty.
From certification to the definitive reservation of capacity
The main operational change lies in the clear separation between the availability of a technical connection solution and the definitive reservation of grid capacity.
The certificate becomes a “grid capacity reservation” only when the applicant notifies Terna that it has obtained the relevant authorisation (i.e., PAS; Single Authorisation and, where applicable, the relevant title for activities not requiring authorisation).
The reservation constitutes the definitive allocation of injection capacity and the connection point and results in the corresponding deduction from the micro-zone capacity and the Offer.
Where multiple projects are involved, Terna will apply a chronological criterion based on the date of publication of the relevant authorisations or permits. The holder must notify Terna of that date on the day following its publication.
For works falling within activities not requiring authorisation, the notification must instead be submitted within three working days of the commencement of the works. Failure to comply with these deadlines may expose the project to the consequences of subsequent saturation, including loss of effectiveness of the certificate.
Next steps
As mentioned, the issuance of the Decree merely concludes the first phase of the reform’s implementation. The decisive step will be the update of the ARERA regulatory framework, which will be required to translate the regulatory framework into rules applicable to individual applications.
In particular, ARERA will be required to regulate, among other things:
These are actual operational rules that should have been published by the end of August and which, it is hoped, will be made available in the coming weeks.
Further steps in the implementation of the reform are also provided for in the same Decree and include, in particular, the submission by Terna to MASE, by 9 October, of a proposed methodology for identifying the micro-zones, to be followed by the publication of the micro-zones within the subsequent 45 days (i.e. by 24 November).
Therefore, assuming that ARERA’s operational rules have been published by 24 November, we could tentatively expect the first notices confirming that existing STMGs have ceased to be effective by the end of this year, and the first Open Seasons at the beginning of 2027.
Preliminary considerations and potential impacts on M&A transactions
The new framework – pending the operational rules currently being issued by ARERA – is set to have an immediate impact on the renewables market.
The shift from the date of submission of the connection application to the date of publication of the authorisation radically changes the logic of the system: it will no longer be the project that first applied for access to the grid that is given priority, but the one that first completed and published its authorisation process.
In essence, the projects that obtain the relevant authorisation most quickly will be the first to secure definitive grid capacity, to the detriment of slower-moving projects, which will face an increased risk of losing the capacity allocated to them under the procedure launched by Terna in the event of definitive saturation of the relevant micro-zone.
In short, the system is shifting from “first come, first served” to “first authorised, first reserved”.
It goes without saying that this reform is set to have significant repercussions, including in the context of M&A transactions relating to renewable energy projects and platforms.
Under the traditional model, acceptance of the STMG and, above all, the subsequent approval and, where applicable, confirmation of validity pursuant to Article 33 of the TICA were frequently regarded as key elements in de-risking and enhancing the value of a project.
Conversely, under the new system, the availability of a certificate or approval does not, in itself, establish that grid capacity has been definitively reserved.
The point is particularly clear: in the absence of publication of the relevant authorisation or
permit – and of timely notification to Terna –, the certificate remains exposed to saturation at the connection point and may cease to be effective.
It follows that two projects located in the same micro-zone and holding similar certificates may present a vastly different risk profile depending on the status, timing and manner of publication of their respective authorisations.
The connection risk is therefore transferred, at least in part, to the authorisation procedure.
This favours initiatives in which a genuine investment in development has been made, but ties the consolidation of capacity to administrative timelines over which the applicant has only limited control and, in the event of overbooking, also to the speed at which competing projects in the same location proceed.
The risk is no longer merely that of obtaining the authorisation, but also of obtaining it and having it recognised for priority purposes before the capacity is taken up by other projects.
A project that has been authorised but for which there is no evidence of publication and the resulting reservation of capacity should not – at this stage – be valued as an asset with grid capacity definitively removed from the Offer.
Similarly, any alternative solution proposed by Terna may alter CAPEX, timelines, site availability, the authorisation process and energy yield, with direct effects on the financial model.
Finally, for portfolios under development, the reform may lead to greater dispersion in value among seemingly homogeneous projects: the quality of the authorisation process, the actual publication of the authorisation and the project’s position in time within the micro-zone will become even more significant selection factors. Grid capacity will thus cease to be a right that is essentially crystallised at the initial stage of development and will instead become an element that is consolidated only following the permitting process.
This regulatory choice addresses the legitimate objective of freeing up capacity currently occupied by projects that are not yet sufficiently mature. It remains to be seen, however, whether the system will be able to favour projects that are genuinely ready for construction without imposing an excessive level of uncertainty on operators during the authorisation phase.
In other words, if the Open Seasons, priority rules and information flows are not sufficiently clear and timely, there is a risk that virtual saturation will simply be replaced by a new form of regulatory volatility, which could affect the cost of capital and the marketability of assets.
The practical implications of this regulatory innovation will also need to be monitored in order to assess whether it will actually prove capable of ensuring efficient planning of the RTN infrastructure and, at the same time, protecting market participants by preventing – rather than creating – new bottlenecks.
It is worth emphasising that these are merely preliminary considerations. Indeed, in order to obtain a clear, complete and comprehensive picture of the new regulatory framework, it will be necessary to await ARERA’s operational rules.
> ^Data taken from Terna’s econnextion platform and updated as of 31 July 2026.
> ^“Micro-zone” means “the portion of the RTN within regional or sub-regional market areas, which allows for the effective representation of the main technical constraints – both physical and operational – relating to the intra-zone transmission of electricity” (see Article 2(1)(e) of the Decree).
> ^“Maximum additional micro-zone capacity” means the “additional feed-in capacity from renewable energy sources and storage facilities that can be accommodated in each micro-zone, calculated as the sum of the additional feed-in capacity that can be accommodated at all stations belonging to the micro-zone included in the Offer” (see Article 2(1)(d) of the Decree).
