3516
Storage of electricity
This code covers activities of storing electrical energy in various forms (batteries, pumped hydro, compressed air, etc.) for subsequent redelivery to the grid or self-consumption. It is essential for companies developing and operating energy storage systems, contributing to grid balancing and integration of renewable sources. It involves the construction, maintenance, and operation of storage facilities, including energy conversion and reinjection into the system.
Entrepreneur Profile
Acest cod este destinat companiilor specializate în stocarea energiei, inclusiv operatori de sisteme de baterii la scară largă, dezvoltatori de proiecte de hidroacumulare, firme de servicii de echilibrare a rețelei și producători de energie regenerabilă care integrează stocarea. De asemenea, este util pentru startup-uri inovatoare în domeniul stocării și pentru companii care oferă servicii de stocare ca utilitate.
Who should avoid:
Avoid the exclusive use of code 3516 if the main activity of your company shifts towards other commercial or related branches not specified in the official description. See the excluded activities section below.
Authorization procedure and Trade Register aspects for NACE 3516
NACE code 3516, 'Storage of electricity', is a relatively recent class in the National Classification of Economic Activities, in the context of the development of storage systems (batteries, pumped hydro, hydrogen). When registering with the Trade Register (ONRC), the main activity must be stated, and the application is signed by the manager/sole associate. For companies, the articles of association and the affidavit under Law 359/2004 (regarding the registered office) are submitted. There is no specific minimum capital requirement for this class, but an opinion from ANRE (the National Energy Regulatory Authority) is required for economic operators intending to carry out storage activities as a system service or for the energy market. ONRC forwards the documents to ANRE ex officio if NACE code 3516 is mentioned as a main or secondary activity, but it is recommended to request ANRE's opinion ex officio.
Regulatory framework, specific approvals, and control institutions
Electricity storage activities fall under the Electricity and Natural Gas Law No. 123/2012, as amended. Operators must obtain an operating license from ANRE (storage license), depending on capacity and purpose. Environmental permits under Law 292/2018 on environmental impact assessment are mandatory, as well as a construction/operation permit for electrical installations. For battery storage, battery waste legislation (Government Emergency Ordinance No. 5/2015) also applies. Control institutions include ANRE, the Tax Authority (ANAF), Environmental Guard (periodic inspections), and the Fire Inspectorate (for fire safety in large installations). For the sale of stored energy between operators, ANRE approvals regarding participation in the balancing market apply.
Tax management, ANAF audit risk, and specific accounting
From an accounting perspective, energy storage is recorded as production/service activities, with specific stock accounts (raw materials – purchased and stored energy, possibly reflected in accounts 301 for green certificates or 345 for finished goods if energy is resold). Tax-wise, income from the sale of stored energy is subject to corporate income tax (16%) or micro-enterprise tax (depending on thresholds). VAT applies at the standard rate of 19% for energy supplies. A major ANAF audit risk is the correct recording of own consumption (energy consumed for storage vs. energy sold). Reporting obligations include: declaration 394 for supplies/acquisitions (if exceeding the EUR 10,000 threshold), VAT return (D300/D301), annual income declaration (D101). For producers with storage capacities, contributions to the green certificate system (excise duties, green taxes) also apply. The fiscal vector is completed at ONRC/ANAF with NACE code 3516; failure to declare it attracts penalties and additional taxation. ANAF may adjust income from energy trading if transfer pricing rules between related parties are not respected. We recommend preparing a transfer pricing file for companies trading stored energy with group entities.
Included Activities
- ✅ Operation of electricity storage facilities (batteries, pumped hydro storage, compressed air, flywheels)
- ✅ Storage of electricity for subsequent redelivery to the grid
- ✅ Activities of converting electrical energy into other forms of energy for storage and reconversion
- ✅ Maintenance and repair of electricity storage equipment
Excluded Activities
- ❌ Production of electricity (code 3511-3514)
- ❌ Distribution of electricity (code 3513)
- ❌ Trade of electricity (code 3514)
- ❌ Manufacture of batteries and accumulators (code 2720)
Similar or Related CAEN Codes:
From the same category of economic activities:
Întrebări Frecvente
What authorisations are needed for an electricity storage installation in Romania?
For storage installations, an establishment authorisation from ANRE, a technical connection permit from the grid operator, a building permit (if applicable), and subsequently an operating authorisation from ANRE are required. Additionally, environmental and fire brigade permits may be necessary.
What is the tax regime for income from electricity storage?
Income from electricity storage is considered income from commercial activities and is taxed according to general rules: corporate income tax (16%) or micro-enterprise income tax (1% or 3%, depending on turnover and number of employees). VAT applies at the standard rate (19%) for storage services.