The Government of the Republic of Srpska has proposed amendments to renewable-energy rules aimed at preventing developers from splitting larger solar developments into multiple installations below 150 kW to access guaranteed electricity purchase prices. The changes focus on ground-mounted solar plants that qualify for an incentivised offtake regime.
Minimum-distance requirements for small ground-mounted solar
Under the proposal, solar projects up to 150 kW would need to meet a minimum-distance requirement. The measure is intended to limit the registration of multiple nominally independent plants within the same development area.
The authorities cited cases where land planned for one large solar project was divided into between 20 and 50 separate plots. In those cases, a plant was registered on each plot with individual installations kept below the 150 kW threshold. A development with 50 installations at 150 kW each would total up to 7.5 MW, even if each component could be treated as a small project.
Guaranteed offtake eligibility after construction
The proposal also seeks to remove the current system of preliminary incentive approval for qualifying projects. Developers would be able to receive guaranteed offtake only after construction is completed and all legal and technical conditions are satisfied.
The change would affect how small solar projects are financed. Preliminary eligibility can support lender confidence before construction, while post-completion qualification shifts more regulatory and completion risk to project sponsors. Developers would need to fund construction without certainty that the asset will ultimately receive the expected support mechanism.
Transitional treatment and eligibility assessment criteria
The revised framework is intended to reduce speculative applications and prevent scarce incentive capacity from being taken up by artificially fragmented projects. It could also create transitional risk for developments already structured through multiple special-purpose companies, land parcels or grid applications.
For lenders and investors, a key point will be whether the final law includes grandfathering provisions for projects with existing permits, connection approvals or preliminary incentive status. Without clear transitional rules, projects that met requirements when initiated could see revenue assumptions change after development capital has already been committed.
The reform also moves beyond using capacity thresholds as the sole test for determining eligibility. Regulators are expected to consider factors including common ownership, shared connection infrastructure, adjacent land, coordinated construction and the economic substance of a development when assessing whether installations are genuinely separate.
