The Government of the Republic of Srpska has proposed tighter renewable-energy rules designed to prevent developers from dividing larger solar projects into multiple installations below 150 kW to gain access to guaranteed electricity purchase prices.
The proposed amendments target ground-mounted solar plants that qualify for the incentivised offtake regime. Projects of up to 150 kW would have to comply with a minimum-distance requirement, limiting the ability to register numerous nominally independent plants within the same development area.
The authorities identified cases in which land intended for a single large solar development had been divided into between 20 and 50 separate plots, with an individual plant registered on each plot below the 150 kW threshold. A development comprising 50 installations of 150 kW would amount to as much as 7.5 MW, even though each component could formally be treated as a small project.
This structure allowed developers to avoid concession requirements and obtain construction approvals from local authorities while securing guaranteed purchase prices for periods of up to 15 years. The economic advantage came not from project efficiency but from regulatory classification.
The amendments would also remove the present system of preliminary incentive approval. Developers would become eligible for guaranteed offtake only after construction had been completed and all legal and technical conditions satisfied.
That change materially alters the financing profile of small projects. Preliminary eligibility can support lender confidence before construction, whereas post-completion qualification transfers more regulatory and completion risk to project sponsors. Developers would need to finance construction without certainty that the asset will ultimately receive the expected support mechanism.
The revised framework could reduce speculative applications and prevent scarce incentive capacity from being captured by artificially fragmented projects. It may also create transitional risk for developments already structured around multiple special-purpose companies, land parcels or grid applications.
For lenders and investors, the decisive issue will be whether the final law contains grandfathering provisions for projects with existing permits, connection approvals or preliminary incentive status. Without clear transitional rules, projects that were compliant when initiated could face changes to revenue assumptions after development capital has already been committed.
The reform marks a broader shift away from capacity thresholds as the sole test of project eligibility. Regulators are increasingly looking at common ownership, shared connection infrastructure, adjacent land, coordinated construction and the economic substance of a development when deciding whether installations are genuinely separate.
