Policy context and tender reform objectives

The proposed reforms to the tender system aim to inter alia place greater emphasis on price competitiveness and introduce other strategic criteria, such as cybersecurity requirements and “buy European” considerations.

In parallel, following the very recent decision of Jo Brouns to grant the permit for the Ventilus project, the development of the Princess Elisabeth Zone appears to have regained prominence on the policy agenda.

Princess Elisabeth Zone back on the agenda

Following the 2025 decision  by Federal Minister of Energy Mathieu Bihet, to put the ongoing procedure for Lot I of the Princess Elisabeth Zone on hold, and after several consultation rounds with the sector, long awaited proposed amendments to the Royal Decree of 3 June 2024 were published on the website of the FPS Economy on Friday 17 April 2026.

The draft Royal Decree, which is up for consultation until 30 April 2026, refines the competitive tendering procedure, as well as the conditions and procedure for the granting of domain concessions and the general terms and conditions governing the use of the plots for the construction and operation of installations for the production of electricity from renewable energy sources in the marine areas under Belgian jurisdiction.

Ventilus permit and grid infrastructure developments

In addition, on 27 April 2026, Minister Jo Brouns granted the necessary permits for the construction of the grid reinforcement project known as Ventilus. Together with the Boucle du Hainaut grid reinforcement project, Ventilus is considered a critical enabling infrastructure for transporting offshore-generated electricity to the Belgian mainland. These decisions mark a significant shift in the energy landscape, following months of uncertainty and speculation, and are expected to accelerate the development of offshore wind farms in the Princess Elisabeth Zone.

Legal uncertainty and consultation process

It should, however, be emphasised that the proposed amendments to the Royal Decree have not yet been formally adopted and remain subject to a public consultation, which is open from 20 April 2026 to 30 April 2026. During this consultation period, potential developers, investors, suppliers and other relevant market participants are invited to submit their comments. Note that the decision is also subject to an opinion from the Council of State. Furthermore, it should be noted that the permits granted for the Ventilus project may still be subject to judicial review proceedings, which could result in delays to the project’s implementation.

A. Lowest cost takes all

The central element of the reform is the decision to design the tender as an essentially price-based auction, with a single award criterion based exclusively on the strike price to be submitted by the bidders. The secondary award criteria have been removed and each concession will be awarded to the eligible bidder that offers the lowest strike price for electricity.

This represents a material change compared to the previous framework, which provided for two award criteria, namely the strike price (weighted at 90%) and a citizen participation component (weighted at 10%) in the overall assessment. Under the proposed future procedure, the award decision will be entirely price-based. The citizen participation element has been fully discarded and will no longer constitute either an award criterion or an admissibility requirement. The rationale underpinning this approach is the assumption that citizen participation could lead to increased costs, while prioritising price is considered paramount.  

By removing this, the choice is to simplify and de-risk the tender for developers, hoping for keener price competition and ensuring that public support (via the Contract for Difference mechanism (CfD)) goes as far as possible.

Additionally, by abolishing the strike price cap as an admissibility criterion (previously ~€95/MWh) the tender procedure will become a true open bid.

B. Single support scheme – no more PPA opt-out

The amended rules also streamline the revenue support scheme. Belgium is fully committing to a two-sided CfD for these projects, a model guaranteeing that projects earn their strike price, with payments flowing either from the government to the producer or vice versa depending on market prices. What’s new in the consulted text is the removal of the option that would have let bidders partially step outside the CfD by using Power Purchase Agreements (PPAs) for a portion of their output. The so-called “optional mechanism” (i.e. carve-out), which could potentially have carved out up to 50% of production for PPAs, will be repealed. All production volumes will count towards the CfD calculations. This change avoids creating a two-tiered revenue stream and ensures all projects share the same straightforward risk profile for investors. Developers will still be able to sign private PPAs for commercial reasons, but those won’t reduce their obligations under the CfD.

The tweaks also included a refined reference price formula (incl. treating negative power prices as zero in the average) and a redefined “correction factor” to align with EU state aid approvals, thereby ensuring that the CfD even works during unusual market conditions.

C. New EU-driven criteria: Resilience and sustainability front and center

Beyond pricing, what’s really new is the incorporation of qualitative pre-conditions inspired by European industrial and climate policies. In this context, the following changes can be put forward:

    • Supply chain resilience: Each bidder must adhere to strict sourcing rules designed to strengthen European supply chains. This is a transposition of goals from the EU’s Net-Zero Industry Act (NZIA). In relation to that, bidders must ensure most of their wind farm components are not from China. The headline numbers: at least 75% of turbines cannot be Chinese-made or assembled, and among those turbines, only up to 4 critical components can be of Chinese origin. Plus, no more than 85% of the project’s permanent magnets can come from China. These thresholds essentially force a diversified procurement strategy, spreading supply chain risk. These commitments are verified by a declaration of honor in the bid, and later the winning concessionaire will have to prove compliance (e.g. by submitting customs documentation within 2 years of operation).
    • Carbon footprint: The other EU-aligned innovation is making carbon footprinting and sustainability reporting mandatory. By forcing every bidder to produce a detailed life-cycle carbon assessment of their project, Belgium is pushing developers to internalize the climate impacts of construction, not just the climate benefits of operation. Now, carbon costs must be quantified and reported upfront, using a standardized method, and verified by an independent expert.
    • On the cybersecurity and data protection side, the amendments bring in a series of qualitative obligations influenced by the NZIA and related implementing rules. Bidders have to submit robust security system plans on how they’ll secure networks, how they’ll keep sensitive operational data within jurisdictions that respect EU law, and how they’ll handle supply chain security. Each bidder must provide a declaration of compliance with a list of specific cybersecurity controls. Once a project is under development, the concession-holder will need to demonstrate that these measures are actually implemented, and they must continuously report on cyber safeguards during construction and operation. Alongside cybersecurity, a corporate social responsibility clause now requires bidders to provide information on corporate social responsibility measures.
D. Investor-friendly tweaks – financial and timeline adjustments

Amid these higher standards, the government also decided to reduce upfront burdens and add certainty for developers.

A standout is the removal of the onerous bid bond requirement for all bidders. Previously, every bidder had to lock in a multi-million euro guarantee just to submit an offer. Now, only the winning bidder will need to provide a financial guarantee, after being awarded the concession.

Another small but meaningful change: tenderers no longer need to submit a binding insurance quote at bid stage for covering their civil liability. Only the winning concessionaire must secure the required insurance by financial close.

E. Timeline changes also favor developers

The proposal entails a minimum six months bid preparation time, in combination with a fixed five-month evaluation period (meaning: no open-ended waits for results). The construction period extension to 60 months addresses a serious concern: global supply chain delays have made 48-month build deadlines challenging. Now with 60 months, developers have more buffer to handle supply chain issues and disruptions. Combined, these adjustments show a clear responsiveness to the industry’s feedback.

Outlook for offshore wind development in Belgium

In conclusion, although the wait for the updated offshore wind tender framework has been significant, it reflects Belgium’s ambition to combine cost efficiency with high-quality project delivery, enabling highly competitive clean energy developments while supporting Europe’s broader net-zero and energy security objectives. In addition, following Jo Brouns’ decision to grant permits for the Ventilus grid reinforcement project, a renewed sense of momentum has emerged after months of uncertainty.

Together with the proposed amendments to the Royal Decree, this development may enable progress on Plot I of the Princess Elisabeth Zone and contribute to a more robust legal and investment framework, offering greater clarity on both the tender criteria and the grid infrastructure to be delivered by Elia Group.

However, uncertainty remains. It is still unclear whether the permits granted for the Ventilus project will be challenged before the Council for Permit Disputes, and when—and in what final form—the Tender Royal Decree will ultimately be adopted, following the public consultation and the opinion of the Council of State.