RESS 6 will support successful renewable electricity generation projects for a period until 4 March 2046, or the date 16.5 years after a project’s RESS 6 Support Start Date, whichever is the earliest to occur.
We previously considered the consultation on RESS 6 in our Insights blog post: Energy Update: Next steps for the Renewable Electricity Support Scheme. We also outlined the Department’s decision on non-price criteria to be applied in RESS pursuant to the EU Net-Zero Industry Act (“NZIA”) in our Insights blog post: Renewable energy update: Non-price criteria decision.
In this briefing we look at some of the further detail now indicated in the final RESS 6 T&Cs, and some of the key differences as compared to RESS 5.
Pre-qualification criteria
Requirements to demonstrate the three NZIA pre-qualification criteria (responsible business conduct, cybersecurity and data security, and ability to deliver) are mainly at Section 6 of the T&Cs. Compliance is declared in the Qualification Declaration at bid stage and verified at delivery through the Milestones a project is required to complete under its Implementation Agreement (“IA”).
As regards cybersecurity and data security, enduring requirements include that operational control of the RESS 6 project must be exercised by an operator established in the EEA. This appears to exclude UK-based operators from exercising operational control. However, it is clarified that the existence of a non-EEA parent company does not prevent compliance, provided the operator maintains operational control of the project. Similarly, the involvement of a Relevant Supplier or any other third-party entity established outside the EEA, whether acting as service provider, control centre provider, remote monitoring provider, maintenance contractor, software provider or managed service provider, does not of itself prevent compliance, subject to the same condition.
The T&Cs define third country risk by reference to two triggers, and it is worth recalling that the Initial Decision on Implementation of the NZIA in RESS (PDF, 257 KB) indicated the UK was not considered as a high-risk third country for the purposes of the relevant data transfer restrictions.
Applicants must provide confirmations in the Qualification Declaration relating to: commitment to appropriate technical and operational measures to manage cybersecurity risks across network and information systems; the EEA operational control requirement; compliance with requirements regarding Relevant Suppliers; and, where the applicant or a Relevant Supplier is subject to the jurisdiction of a third country, compliance with reporting obligations.
Composite evaluation score
The scoring methodology is now more fully specified. Offers will be ranked based on a Composite Evaluation Score (“CES”), comprising a Price Score, Resilience Score, and Energy System Integration Score.
Price Score (up to 0.85)
Each offer receives a Price Score of up to 0.85, calculated by reference to how the bid price compares to the Maximum Offer Price Considered (“MOP”) for its Pot, using an exponent k, to be published by the Minister before the Final Application Withdrawal Date.
Critically, the formula is forward-looking: the score is determined solely by reference to the MOP published before the auction, not by reference to the lowest bid or any ex-post variable.
Resilience Score (0 or 0.05)
This is binary. An offer receives a Resilience Score of 0.05 where it meets the Minimum Resilience Requirement, or 0 where it does not. The score reflects the contribution of the project to supply chain diversification, assessed by reference to the number of Final Products and Main Specific Components sourced from countries presenting supply chain concentration risks under the Commission Communication.
The technology-specific thresholds are now precisely stated. For onshore wind, at least 75% of Final Products must not originate from or be assembled in China; at least 75% must not contain more than three Main Specific Components from China; at least 75% must not contain drivetrains originating from China; and at least 50% of permanent magnets must not originate from or be assembled in China. For solar, Final Products must not be assembled in China; at least four Main Specific Components must not originate from China; and PV inverters and cells must not originate from, and PV modules must not be assembled in China.
Energy System Integration (“ESI”) Score (up to 0.10)
Each offer receives an ESI Score up to a maximum of 0.10, comprising a Secondary Technology Score plus a Storage Score. For hybrid wind-solar projects, the Secondary Technology Score scales from 0 (below 10% secondary technology) through 0.0063 (≥10% to <20%), 0.0125 (≥20% to <30%), 0.0188 (≥30% to <40%), to a maximum of 0.0250 (≥40% to <49.99%).
To attract any Storage Score, Electricity Storage Capacity must be at least equal to the Total Offer Quantity of the project. Once that condition is met, the Storage Score is 0 for Electricity Storage Duration under 2 hours; 0.0150 for 2 – 4 hours; 0.0300 for 4 – 6 hours; 0.0450 for 6 – 8 hours; 0.0600 at 8 hours; and 0.0750 for over 8 hours.
Therefore 8+ hours of storage duration delivers the maximum Storage Score (0.075), and a well-configured hybrid project can theoretically accumulate close to the full 0.10 ESI allocation. It is understood that the purpose is to encourage delivery of the duration of storage required in Ireland’s current energy mix.
At this stage, however, there are significant hurdles to integrating ESI solutions in projects bidding into RESS auctions. The CRU’s Maximum Export Capacity (“MEC”) sharing decision and the EirGrid/ESB Networks Implementation Roadmap indicate that some of the reforms needed to enable hybrid ESI configurations are in train, and that these will take time to deliver. We look at these developments in the following Insights blog posts:
- Energy update: Sharing Maximum Export Capacity at electricity grid connection points
- Energy update: Implementation roadmap for hybrid co-located sites with MEC sharing
Compliance with NZIA commitments
Compliance with the NZIA non-price qualification and award criteria described above are embedded in the IA, including through requirements to comply with the T&Cs (Section 9 on enduring eligibility requirements is particularly relevant) and two new Milestones.
- Milestone 6: Generators must submit evidence of compliance with the responsible business conduct and cybersecurity and data security requirements. If not complete by the Interim Milestone Date of 5 June 2029, the Minister may draw down up to a maximum of 25% of the Performance Security (4% per month). If not complete by the Final Milestone Date of 5 December 2029, the Letter of Offer is revoked and the remaining Performance Security drawn down.
- Milestone 7: Generators must submit the Installed Renewable Capacity Commitment (a director declaration) and evidence of compliance with documents related to the resilience and/or ESI score. If not complete by the Interim Milestone Date of 5 December 2029, the Minister may draw down up to a maximum of 25% of the Performance Security (4% per month). If not complete by the Final Milestone Date of 5 June 2030, the Letter of Offer is revoked and the remaining Performance Security drawn down.
There is a new limb in the IA’s force majeure definition in respect of resilience and ESI. Force majeure includes: (i) sudden and unforeseeable disruptions to international supply chains resulting from geopolitical events, trade embargoes, sanctions or natural disasters that make it impossible for the Generator to procure certain Final Products and/or Main Specific Components, or (ii) the bankruptcy or insolvency of a supplier of a Main Specific Component, where no alternative supplier meeting the Minimum Resilience Requirement can deliver the component within a timeframe that would allow the Generator to achieve Commercial Operation by the Longstop Date. There are carve-outs relating to general price increases, delays caused by the Generator’s failure to place orders in a timely manner, and any circumstances known or reasonably foreseeable at the time of submission of the Resilience Declaration.
Further differences from RESS 5
Fewer technologies are eligible for RESS 6 support. RESS 6 is open to onshore wind, solar, and hybrid combinations of those technologies with each other and with storage (whereas RESS 5 was additionally open to hydro, biomass HECHP, waste-to-energy HECHP, and biogas HECHP).
Repowering eligibility is structured differently. A repowered project must involve investment of at least €300,000 per MW of capacity made after the execution of the IA. Its generation capacity must be restored to no less than the MEC under the existing grid connection agreement, with the Total Offer Quantity comprising part or all of that MEC. This replaces the RESS 5 requirement of a 50% increase in deemed annual output, a meaningful relaxation for older sites where modern turbines deliver greater efficiency without necessarily increasing nameplate capacity. Projects are ineligible for RESS 6 until at least 20 years have elapsed since the first payment they received under any previous scheme. This is significant in that it potentially opens RESS 6 to a substantial cohort of legacy REFIT sites.
In terms of running the auction, there will be two technology-specific Pots (an Onshore Wind Pot and a Solar Pot), which means that wind and solar projects no longer compete directly against each other on price. If a project comprises both technologies, the technology with the greater MW capacity dictates the Pot in which it competes. The Minister will determine Maximum and Minimum Quantities in annual GWh for each Pot, taking into account factors which include energy and climate targets.
There is a different approach to winner selection. Eligible Offers are accepted in turn starting from the offer with the highest CES, proceeding through the list up to and including the offer for which the total Deemed Energy Quantity in the relevant Pot first meets or exceeds the Pot Auction Starting Quantity (“ASQ“). After that, additional eligible Offers continue to be accepted in sequence until the next eligible Offer in the list either has a CES more than 5% lower than the offer that first caused the Pot ASQ to be met or exceeded, has an Offer Price at or above 90% of the Maximum Offer Price Considered, or would cause the total Deemed Energy Quantity accepted to exceed the Pot’s Maximum Quantity.
There are stronger obligations relating to the Public Service Obligation (“PSO”). Milestone 9 requires the Generator to submit evidence that the Supplier PPA counterparty has made a submission for the relevant PSO year by an Interim Milestone Date of 3 May 2029 and a Final Milestone Date of 4 November 2030. A Generator exporting electricity while not included in the PSO is ineligible for Unrealised Available Energy Compensation and Support Payments, and liable for all Difference Payments that would have been payable during the period concerned.
Projects are now prohibited from withdrawing from RESS 6 where a Generator has executed an IA and received a Letter of Offer (whereas there was some Ministerial discretion in previous auctions).
Next steps
The RESS auction is expected to run (PDF, 147 KB) as follows (subject to anticipated final State aid approval):
- Qualification submission window: 30 July 2026 – 27 August 2026
- Final qualification decisions: 21 October 2026
- Auction submission window: 29 October – 5 November 2026
- Provisional results: 18 November 2026
- Final auction results: 2 December 2026
- Notices of Award: 10 December 2026