White paper · EU permitting

Europe set the clock. The file is still national.

Permitting used to be a matter of patience. It is now a matter of law with a deadline attached, and that changes what a developer has to be able to prove.

Published 22 September 2026, updated 5 October 2026 · Download the PDF (9 pages)

The Renewable Energy Directive as revised in 2023 put maximum durations on renewable permitting and required member states to designate acceleration areas where those durations are shorter still. The Net-Zero Industry Act, Regulation (EU) 2024/1735, did something adjacent for manufacturing and strategic projects: recognition, priority status, bounded procedures. Taken together, Brussels stopped asking member states to be faster and started telling them by when.

For anyone developing projects, this is genuinely good news. It is also more complicated than it looks, and the complication is where projects are still lost.

Three things the deadline does not do

It does not start when you file. It starts when the authority holds a complete application. Completeness is defined nationally, sometimes regionally, and it is the developer's problem. A twelve-month statutory ceiling is not twelve months from your submission; it is twelve months from the day nobody can any longer send the file back. The single most expensive document in a project is the one nobody realised was missing.

It does not harmonise the procedure. A directive sets an outcome and leaves the route to the member state. The result is that the same technology, in the same year, under the same European instrument, moves through three visibly different machines.

It does not stand still. Transposition is not one event. It arrives in tranches, is amended, is corrected in the official gazette on a Tuesday, and applies to projects already in flight.

The same directive, three machines

Greece transposed through L.5151/2024 (ΦΕΚ Α' 173) and then legislated acceleration areas in L.5299/2026 (ΦΕΚ Α' 67, 5 May 2026). Inside an acceleration area the ambition is explicit: total permitting to the operating licence within twelve months. Outside it, the ordinary Greek sequence still governs, with its own filing windows and its own clocks.

Italy consolidated in D.Lgs 190/2024, the Testo Unico. Its logic is not a single procedure at all but four, selected by what you are building and how large it is: attività libera at the smallest scale, the simplified PAS above it, Autorizzazione Unica at regional competence for the broad middle, and the state Autorizzazione Unica through PAUR for the largest. The regime is not a preference. It is a consequence of the project's own facts, and getting it wrong is not a delay, it is a restart.

Switzerland is outside the Union and worth reading precisely for that reason. The Energy Act (EnG, SR 730.0) Art. 14a gives solar and wind of national interest a concentrated cantonal plan approval: one decision that fixes land use and carries every cantonal and communal permit plus expropriation rights, and the cantonal government decides within 180 days of a complete filing. It is the same idea Europe is reaching for, expressed as one door rather than as a ceiling on many.

A developer with projects in two of these three is not running one permitting process with local variations. They are running two different bodies of law that happen to share a vocabulary.

Where the time actually goes

Ask a permitting manager where a year went and the answer is rarely the authority.

It went into establishing which regime applies. Into assembling a file whose completeness rules live in four documents. Into a supplementary-information request that arrived while someone was on leave, with a clock already running. Into discovering that the environmental study circulating internally was not the version filed. Into a lender asking, at financial close, for evidence that every permit was valid on a given date, and a team opening folders to reconstruct it.

None of that is a legal problem. All of it is an information problem, and it is the reason a statutory ceiling and a real project duration are different numbers.

What we built, and what it does

MitOS is a permitting and project-controls system for energy infrastructure. Greece, Italy and Switzerland are live today, each on its own law and its own authorities, and it is built to add more.

The path is derived, not templated. A project's permitting sequence comes from the law itself. Change one project fact, the technology or the capacity, and the whole path re-derives. Every requirement carries the article it comes from. This is the difference between a checklist that encodes what someone remembered and a route that can be interrogated.

Every step names who decides it and the clock that governs it, or states plainly that the law sets no time limit. Silence is not an answer a permitting system should give, because a step with no stated deadline and a step whose deadline nobody entered look identical.

Legal texts are the official publications. ΦΕΚ, Gazzetta Ufficiale, Fedlex, frozen with a content hash and re-verified mechanically. The official publication alone is authoritative and MitOS is not legal advice; what the product guarantees is that what you are reading is what was published.

When the law moves, projects do not move silently. An in-flight project keeps the legal basis it adopted, sees a reviewable diff of what changed, and adopts the change explicitly, with the amending act cited. Nothing already completed is retroactively unticked. This matters more than it sounds: the alternative is a system that quietly rewrites a project's requirements and leaves the team to discover it at a hearing.

Ninety days of forward view, and a live flag feed. What is due and what is at risk surfaces while there is still time to act on it, which is the only window in which a permitting risk is still a decision rather than a fact.

The rest of the project, on the same record

Permitting does not fail in isolation, so the system does not stop there.

Land sits as a parcel register with securing status and live spatial checks against government open data. Contracts, guarantees and invoices have registers with beneficiaries, amounts, VAT and expiry, because a guarantee that lapses unnoticed is a permitting problem wearing a finance costume. Documents are versioned on the step they belong to, with a data room for external parties and an executive binder on demand. Financing keeps progress, milestones and a full-life model connected: NPV, IRR, break-evens, debt capacity, so the consequence of a slipped date is visible in the number the board actually asks about.

The portfolio reads on one screen, with every alarm landing on the project that raised it. And the output is decision-grade: status reports, financing memos and evidence packs exported to PDF and Word, generated from live data rather than retyped, each carrying a tamper-evident fingerprint.

It runs as a desktop edition where nothing leaves your machine, or as a cloud workspace for teams. One product, the same engine.

What it does not do

It does not file for you, and it does not tell you that a submission will be accepted. It is not legal advice, and it does not replace your lawyer or your consultant. It will not shorten a statutory clock, because nothing can.

What it does is make the path explicit, current and evidenced, so the time a project loses is the time the law actually requires rather than the time an organisation spends finding out what the law requires.

Europe has set the clock. Whether a project meets it is still decided by how well the file is kept.

See it on your own project stages

A short, focused demo on your real project stages, or the paper as a PDF to share with your team.

Legal instruments are described in substance. The official publication alone is authoritative, and MitOS is not legal advice.

Permitting energy projects is a labyrinth. MitOS is the thread.