OUT-LAW ANALYSIS 16 min. read
RESS 6 operates separate auction pots for onshore wind and solar projects. Photo: Simon Roughneen/iStock
29 Jul 2026, 3:32 pm
The Irish government has finalised the terms and conditions for the sixth round of its renewable electricity support scheme (RESS 6).
The Department of Climate, Energy and the Environment (DCEE) has published the terms and conditions for the sixth round of RESS (Terms and Conditions). This follows a consultation carried out earlier this year on several proposed changes ahead of plans to launch the auction later this autumn.
While the auction retains the familiar two-way Contract for Difference (CfD) structure used in previous rounds, RESS 6 introduces a number of changes that should be considered before bids are submitted.
These are largely driven by the pre-qualification requirements set out in the EU's Net Zero Industry Act (NZIA) and include a new bid scoring methodology, additional supply chain and cybersecurity requirements, a two-pot auction structure for wind and solar projects, and new rules around previous RESS competition project eligibility and repowered projects.
The auction timetable is now available with the qualification application opening and closing dates running from 30 July to 27 August 2026. The auction is open for submissions from 29 October until 5 November.
The revised terms and conditions will have significant implications for Irish renewable energy procurement strategies, as well as contractual arrangements with equipment suppliers and contractors. Below we outline the new qualification and eligibility criteria that businesses need to know.
One of the most significant changes is the introduction of a Composite Evaluation Score (CES).
Instead of being solely ranked by price, as in previous rounds, qualified applicants will now be assessed against a combination of price and non-price criteria. The CES will have a value between 0 and 1.00 and is comprised of the following components:
It is important to highlight that generators seeking to benefit from the resilience score or energy system integration (ESI) score should be aware that any commitments made at bid stage become binding if the project is successful. Failure to deliver those commitments could constitute a breach of the terms and conditions.
The price score is calculated by reference to the relevant offer price and the maximum offer price considered (MOP) for the applicable auction pot.
The final effect of the price score methodology will depend on the detailed auction parameters published before the final application withdrawal date. Generators should therefore test bid sensitivities against the relevant pot structure, expected competition and the interaction between the price score and the available non-price criteria.
Although price remains the dominant scoring factor – accounting for 85% of the overall score – non-price criteria could prove decisive where competing bids are closely matched for winner selection.
In light of recent EU regulations, RESS 6 is embedding energy security directly into the award mechanism through supply chain origin and cybersecurity requirements. These measures form part of a broader focus on energy security and operational resilience across the renewables sector.
The resilience score rewards compliance with the minimum resilience requirement, which sets technology-specific thresholds against the origin and assembly of final products and main specific components in China.
The terms and conditions define final products as any one of the net-zero technology final products published in the Annex of Regulation (EU) 2025/1178.
For onshore wind projects:
For solar projects:
Where a successful applicant receives a resilience score of 0.05 on or before ‘milestone 7’, it must provide customs clearance and original equipment manufacturer documentation to substantiate its position.
Milestone 7 requires the generator to submit documentary evidence of the installed renewable capacity commitment and the CES commitments. Upon the request of the minister, they must also provide notice of any component changes and further documentation that could affect compliance.
Where milestone 7 remains incomplete by 5 December 2029, the minister may draw down up to 25% of the performance security at a rate of 4% per month. If milestone 7 remains incomplete by 5 June 2030, the letter of offer may be revoked and the remaining portion of the performance security drawn down.
The financial questionnaire accompanying the auction process also requires applicants to compare project costs with and without the resilience criteria. This suggests that the government is seeking to understand the additional costs associated with more resilient supply chains. Generators will therefore need to weigh the potential scoring benefit against any increase in procurement costs.
The ESI score is designed to reward projects that contribute to system flexibility and make more efficient use of network infrastructure. It is composed of a secondary technology score and a storage score and is worth up to 0.1.
The secondary technology score, worth up to 0.025, is available to hybrid wind and solar and hybrid wind and solar and storage projects. The score is determined by the proportion of a project’s secondary technology relative to its total offer quantity.
Projects with a secondary technology percentage of less than 10% receive no score, while projects with a secondary technology percentage between 40% and 49.99% receive the maximum secondary technology score of 0.025.
|
Secondary technology percentage |
Secondary technology score |
|---|---|
|
0% to <10% |
0 |
|
10% to <20% |
0.0063 |
|
20% to <30% |
0.0125 |
|
30% to <40% |
0.0188 |
|
40% to <49.99% |
0.0250 |
A storage score is available up to 0.075 where a project includes qualifying electricity storage capacity. To qualify, a project must satisfy the minimum storage requirement, meaning that its electricity storage capacity must be at least equal to the project’s total offer quantity.
|
Electricity storage duration |
Storage score |
|---|---|
|
≥ 0 to < 2 hours |
0 |
|
≥ 2 to < 4 hours |
0.0150 |
|
≥ 4 to < 6 hours |
0.0300 |
|
≥ 6 to < 8 hours |
0.0450 |
|
8 hours |
0.0600 |
|
> 8 hours |
0.0750 |
Where no secondary technology and no storage is offered, an offer shall receive an ESI score of zero.
The new cybersecurity obligations require applicants to confirm in their qualification declaration that they will implement appropriate technical and organisational security measures and that operational control of the project will be exercised by an operator established in the EEA.
This requirement does not preclude the involvement of non-EEA relevant suppliers, parent companies or any third-party established outside the EEA, provided they do not prevent the EEA-established operator from maintaining operational control of the project.
Applicants must also ensure that their relevant suppliers comply with specified cybersecurity requirements and meet certain notification obligations where third-country jurisdictional issues arise.
A relevant supplier is broadly defined to include any supplier or service provider with access to or influence over a project’s operational technology, communications systems, software, cloud infrastructure or cybersecurity arrangements.
Relevant suppliers must adopt appropriate cybersecurity measures, including controls relating to risk management, incident response, business continuity, supply chain security, vulnerability management, access controls and secure communications.
Additional obligations apply where a relevant supplier is subject to specified third-country jurisdictional influences. Where third-country criteria apply, projects must then submit a cybersecurity plan demonstrating that relevant data will remain within the EEA and will not be transferred outside it.
Cybersecurity obligations should be considered at an early stage and applicants should be aware that, changes in ownership structures or supplier arrangements could have implications for compliance and therefore, where appropriate, should reflect them in project documentation.
RESS 6 operates on the basis of a two-pot auction structure, with separate pots for onshore wind and solar projects.
The onshore wind pot covers onshore wind projects and hybrid wind-and-storage projects, while the solar pot covers solar projects and hybrid solar-and-storage projects. Hybrid wind-and-solar projects will be allocated according to their designated primary technology.
Notably, a number of project categories that were eligible for support under RESS 5 are no longer eligible under RESS 6, with the current scheme focusing primarily on onshore wind, solar and certain hybrid configurations. Excluded technologies include hydro, biomass high efficiency combined heat and power (HECHP), waste-to-energy HECHP, and biogas HECHP.
The utilisation of technology-specific auction pots is intended to ensure a more balanced deployment of renewable technologies and a more consistent application of technology-specific criteria. Separate onshore wind and solar pots reduce the risk of one technology dominating auction outcomes due to relative cost competitiveness, while maintaining competition within each technology category. The approach also removes the need to set an evaluation correction factor prior to auction.
Taken together, these measures indicate that the Government is looking beyond the lowest-cost renewable generation models. Instead, the focus is increasingly on how Projects contribute to the overall operation of the electricity system, including flexibility, security of supply and efficient network usage.
Beyond the scoring and auction structure changes outlined above, RESS 6 also raises important questions around grid connection and private wire arrangements.
As in previous auction rounds, projects participating in RESS 6 must remain "grid contracted projects" throughout the support period, maintaining grid connection arrangements with the TSO or DSO, as applicable, that allow them to export at least their total offer quantity.
What the terms and conditions do not address is the evolving regulatory treatment of private wire connections in Ireland. If private wire projects become more common, questions are likely to arise around how such structures fit alongside the grid connection requirements of RESS. This could become particularly relevant for co-located developments, large energy users and hybrid projects seeking greater flexibility in how power is supplied and consumed.
Generators exploring private wire models should therefore keep a close eye on regulatory developments and consider how future changes may affect project structure and revenue.
RESS 6 continues to use the hourly day-ahead market (DAM) price as the market reference price for settlement of the two-way CfD. However, the terms and conditions make clear that this position could change before the auction process is finalised.
The DCEE notes that both the use of the hourly DAM price and the one-hour settlement period remain subject to ongoing state aid discussions with the European Commission. Any changes will be confirmed before the final application withdrawal date.
While no changes have been confirmed or indeed are anticipated, ex ante markets that are typically used as the reference markets under renewable CfDs are likely to become more granular and generators and financiers should ensure that financial models are robust enough to accommodate a different pricing mechanism if required.
Although participants will have an opportunity to withdraw their applications once the final position is known, it is generally easier to build flexibility into commercial and financing arrangements from the outset than to revisit assumptions at a later stage.
One area that may require further clarification concerns the treatment of projects that participated in earlier RESS competitions, but that have not or may not reach commercial operation as originally planned.
Section 6.9(d) of the terms and conditions provides an eligibility route for certain RESS 1 projects that failed to achieve commercial operation by the relevant longstop date. However, no equivalent provision appears to exist for RESS 2 projects that may find themselves in similar circumstances.
A similar position was taken in the RESS 5 terms and conditions, where RESS 2 projects formed part of the broader eligibility framework, but did not benefit from the specific exemption available to certain RESS 1 projects.
It is unclear from the published documents whether this omission is intentional, or simply reflects a continuation of the existing drafting approach.
Generators with legacy RESS 2 projects that may not be able to reach commercial operation should therefore consider seeking clarification from the department at an early stage, particularly if participation in RESS 6 could form part of a revised development strategy.
Where a project has encountered delays outside the developer's control, understanding whether it remains eligible for future support rounds may have a significant impact on investment decisions and project viability.
The RESS 6 terms and conditions introduce a more relaxed framework for repowered projects compared to the position under RESS 5. Where a site has previously been used for a renewable electricity generation project, the repowered asset must restore generation capacity to at least the maximum export capacity (MEC) under the applicable grid connection agreement and the investment in the project must total at least €300,000 per MW of such capacity.
However, unlike previous rounds, the total offer quantity submitted into RESS 6 may comprise only part of the repowered project’s MEC. Unlike RESS 5, there is no requirement to ensure a 50% increase in the deemed energy quantity at the site. This provides generators with greater flexibility in relation to commercial structuring.
The revised terms and conditions also clarify that a repowered project may participate in RESS 6 where the existing project received support under an earlier Irish support scheme, provided that at least 20 years have elapsed since the first payment under that scheme.
Together, these changes may facilitate further investment in existing renewable energy assets approaching the end of their operational life, while supporting upgrades, replacement equipment and other redevelopment works designed to maintain and enhance Ireland's renewable generation capacity.
RESS 6 also raises questions around the treatment of guarantees of origin (GoOs).
As part of the qualification process, applicants must confirm that they will not seek GoOs for electricity supported under RESS 6. This reflects the position under Statutory Instrument 350 of 2022, which provides that a renewable electricity unit cannot receive both a GoO and a RESS payment. This restriction is consistent with the approach adopted in previous RESS auctions.
At the same time, the European Commission's recent guidance on the design of two-way CfDs recognises the continued role of market-based instruments alongside CfD support and discusses the interaction between CfDs and instruments such as PPAs. Against that backdrop, questions may arise as to how restrictions on the use of GoOs by RESS-supported projects will interact with broader European policy developments.
It is worth noting that RESS 6 adopts a stricter approach to project withdrawal than previous auction rounds. Once a generator has entered into an implementation agreement and received a letter of offer, it is no longer entitled to withdraw from its obligations under the scheme. Any purported withdrawal will have no legal effect.
This represents an important change from the position under RESS 5, where certain projects could withdraw from the scheme before the commencement of the support period and, in limited circumstances, subsequently become eligible to seek GoOs.
Although many aspects of RESS 6 will be familiar to participants, the latest auction introduces a broader set of considerations than previous rounds.
Price remains the dominant factor in determining auction outcomes, but generators can no longer afford to focus exclusively on bid price. Issues such as supply chain resilience, cybersecurity compliance, storage integration and project design are now more closely linked to auction competitiveness and ongoing contractual compliance.
The introduction of non-price scoring criteria, separate auction pots for wind and solar, enhanced security requirements and new disclosure obligations all point towards a more sophisticated policy framework. In practical terms, bidders will need to devote greater attention to procurement strategies, contractual arrangements, financing assumptions and compliance planning well before the qualification process begins.
Generators now have greater clarity on the rules that will apply. The challenge will be translating those rules into a competitive bidding strategy while ensuring that the commitments made during the application process can be delivered throughout the life of the project.
Written by
