The decision of the Ministry of Environment and Energy, published in Government Gazette Issue B’ 4262/13.07.2026, does not merely amend specific technical parameters of the programme; it also clarifies the framework governing extensions that may be granted during project implementation.
According to the new Implementation Guide, the basic deadline remains unchanged: every project approved under the programme must be completed within eight months from the date of issuance of the approval decision. Within this period, all energy upgrade interventions must have been completed, the second energy inspection must have been carried out, the relevant supporting documents must have been issued, and the first completion certification declaration must have been submitted.
The most significant change concerns the extension regime. The new guide stipulates that extension requests may be submitted exclusively on grounds of force majeure. Applications must be submitted electronically through the programme’s information system before the expiry of the applicable deadline and must be accompanied by the necessary documentation substantiating the reasons for the delay. Requests are assessed by the Implementation Body, and any extension decision must be duly justified.
In practice, this means that beneficiaries facing objectively unavoidable obstacles—such as natural disasters, significant delays in licensing procedures, exceptional technical issues, or other circumstances that could not have been foreseen or prevented—will have a clear institutional mechanism to avoid being removed from the programme due to missed deadlines.
At the same time, the Ministry of Environment and Energy retains the ability to grant horizontal extensions when required by the programme’s implementation conditions. Specifically, the guide provides that all deadlines included in the programme—whether relating to the submission of the Electronic Building Identity, the selection of a financing scheme, or the completion of works—may be extended either universally or for specific groups of applications, following a relevant announcement by the Ministry.
This provision is particularly important given that the programme is being implemented during a period of increased demand for energy-efficiency upgrades, combined with significant pressures on material supply chains, equipment delivery times, and the availability of specialized contractors. In previous years, similar programmes faced delays linked to permit approvals, the supply of windows, heat pumps, and insulation systems, as well as increased workloads for engineers.
However, the Ministry has also established a clear “red line.” Despite the possibility of extensions, completion of the physical and financial scope of the projects is under no circumstances permitted beyond the programme’s final deadline. This provision is directly linked to obligations arising from funding through the Recovery and Resilience Facility, as the relevant milestones must be achieved within specific timeframes.
Finally, the submission of outstanding supporting documents and the final completion certification declaration must be completed by 31 July 2026 for cases that are currently at the final stage of review.
