Romania’s new demand-response mechanism entered into force on 26 August, but the final regulation appears significantly narrower than the market initially described by energy regulator ANRE.
The regulator’s 19 August announcement presented demand flexibility as a new market instrument through which eligible consumers, suppliers and aggregators could voluntarily offer reductions in electricity consumption to transmission system operator Transelectrica and receive payment when selected.
ANRE explicitly said at the time that the service was not reserved exclusively for crisis situations, describing it instead as an economic mechanism allowing consumers to decide when reducing consumption was more valuable than continuing to use electricity.
However, Order 54/2026, published in Romania’s Official Gazette on 26 August, states that activation of the mechanism applies in defined crisis situations affecting operation of the national electricity system. These include national shortages threatening system adequacy, regional or European supply crises, extended extreme weather, prolonged outages of interconnectors or internal transmission lines constraining imports, and other emergency situations identified by the national dispatcher.
The distinction is commercially significant.
A continuously accessible demand-response market could support aggregators investing in telemetry, automation, industrial-load control and customer acquisition on the expectation that flexibility would be monetised regularly.
A mechanism activated primarily during system stress has a different revenue profile. It behaves more like an emergency reserve than a recurring flexibility market.
Under the published rules, Transelectrica is to determine whether the mechanism is needed after examining the day-ahead and balancing markets over the previous five completed working days. The trigger includes situations where selling offers have systematically failed to provide sufficient adequacy relative to electricity demand in individual trading intervals.
Once activated, the mechanism uses daily auctions for selected working-day intervals.
Consumption flexibility is traded in 15-minute periods, matching Romania’s imbalance-settlement interval, while the minimum quantity that may be offered is 0.5 MW.
Eligible providers include dispatchable consumers, electricity suppliers and aggregators that participate in the day-ahead market. End-users participating must have remotely readable meters, while customers already qualified and participating as balancing-service providers are excluded from simultaneously supplying the new service.
Transelectrica will publish its required reduction volume two days ahead of delivery. Offers are ranked by price and accepted until the required volume has been covered.
The mechanism can operate only for the period considered strictly necessary and for no more than one month without a new assessment.
That architecture has several consequences for potential aggregators.
First, the 0.5 MW minimum makes aggregation commercially relevant. A single large factory could qualify directly, but supermarkets, refrigeration facilities, commercial buildings, pumping systems or smaller industrial users would need to be pooled.
Second, the requirement for remotely readable metering makes digital infrastructure a prerequisite rather than an optional enhancement.
Third, the mechanism includes a baseline against which delivered flexibility is measured. Transelectrica and metering operators compare actual consumption with reference consumption based on previous operating periods.
For aggregators, getting that baseline right is essential. Demand response has value only if the market can distinguish genuine load reduction from electricity that would not have been consumed anyway.
But the most important issue is frequency of activation.
An aggregator investing, for example, €1 million in industrial controls, metering interfaces, forecasting software and customer contracts needs enough market events to recover those costs.
If the Romanian mechanism operates during ordinary high-price and tight-system periods, it could support a genuine commercial flexibility industry.
If activation is limited to exceptional adequacy or emergency events, expected annual revenues become much harder to predict.
This also affects industrial consumers.
A large energy-intensive factory may be willing to curtail production if the compensation exceeds its lost operating margin. Such customers do not necessarily require dozens of activations per year to participate.
Smaller flexible loads are different. Their individual revenues are lower, meaning aggregators need greater activation frequency or access to several value streams.
The strongest business model would therefore combine Romania’s new mechanism with balancing participation, portfolio optimisation, behind-the-meter energy management and potentially future DSO flexibility services rather than depending on one product.
There is also an important distinction between demand response and forced industrial curtailment.
Participation in the mechanism is voluntary. Eligible consumers specify both the amount they are prepared to reduce and the price required. Accepted offers become firm transactions and are verified against metering data.
That turns load shedding into a traded product rather than an administrative instruction.
Yet the wording of the final rule means Romania has stopped short of creating a continuously functioning flexibility exchange.
For Southeast European power markets, the Romanian experience is worth watching because the unresolved question is increasingly common: should flexible demand compete every day with generation, or should it remain a strategic instrument activated only when the conventional electricity market is under stress?
Romania has now built the auction machinery.
What remains uncertain is how often it will be allowed to run.
