Moldova: ANRE Implements Bundled Gas Capacity Rules, but Structural Barriers Remain

Country: Moldova | Commodity: Gas | Topic: Cross-Border Capacity, Regulatory Compliance

On 18 August, ANRE Moldova approved amendments to the Gas Network Code implementing the EU's bundled transmission capacity requirements at cross-border interconnection points under Regulation (EU) 2024/1789. The new mechanism is expected to apply from Gas Year 2026/2027, covering quarterly, monthly and daily capacity products.

Mirroring changes Ukraine adopted earlier, the amendment allows a holder of bundled transmission capacity to transfer the right to submit nominations and renominations to another shipper, while retaining responsibility for the underlying transportation contract and payments. Moldova and Romania opted for this operational approach rather than seeking an Article 70 derogation from the bundling requirement, despite the Regulation allowing it and comparable interconnection points (Hungary-Serbia, Bulgaria-Serbia) having already secured one.

The mechanism only takes effect after bundled capacity has been allocated: it eases how capacity is used, not who can compete for it. ANRE's own explanatory memorandum acknowledges several structural issues that remain unresolved: no mutual recognition of licences or market participant status between Moldova and neighboring jurisdictions, continued balancing and VTP access mismatches, and restrictions on secondary trading of bundled capacity. The Energy Community has flagged the same point: nomination transfer is an operational workaround, not full cross-border market integration.

Source: ANRE Moldova

For more information on cross-border gas capacity access and regulatory developments in Moldova, please contact CorreggioNET at info@correggionet.eu.