Biomethane Action Plan: Monitoring Group

Renewable gases play a key role in Portugal’s measures for combating climate change and achieving carbon neutrality. For this reason, various initiatives aim to promote their financial and technological viability.

For example, Ordinance 15/2023 set up a centralized purchasing system for biomethane and green hydrogen produced through water electrolysis (see Legal Flash Centralized purchasing system for biomethane and hydrogen produced through water hydrolysis). Similarly, the Biomethane Action Plan, as part of the National Energy and Climate Plan 2021–2023 (PNEC 2030), commits to adopting measures to support Portugal’s energy transition, enhance competitiveness, and reduce greenhouse gas emissions. The Biomethane Action Plan 2024–2040 (“PAB”) was approved by Council of Ministers Resolution 41/2024 of March 15.

The PAB outlines a two-phase strategy for developing the biomethane market:

• Phase 1 (2024–2026): Creating a biomethane market in five key sectors:

1. Urban waste
2. Waste water
3. Agriculture
4. Livestock
5. Agribusiness.

This phase focuses on converting existing biogas production to biomethane and investing in new biomethane plants in regions of interest, particularly through using high-potential waste.

• Phase 2 (2026–2040): Strengthening and consolidating the market by developing new regional value chains and promoting research and innovation in biomethane production technologies.

On May 27, 2024, Order 5971-A/2024 was published, opening a tender through an electronic auction, including the sale of the respective guarantees of origin (see post Renewable gas auction). This measure allocates €140 million over 10 years to incentivize green hydrogen and biomethane projects.

As established in Council of Ministers Resolution 41/2024 of March 15, the Monitoring and Coordination Group for the Biomethane Action Plan 2024–2040 (“GAC-PAB”) was established through Order 1604/2025 of February 4 to ensure the PAB is implemented effectively. The GAC-PAB comprises a group of representatives from various public and private energy, agricultural and environmental sectors, led by a board including the National Energy and Geology Laboratory (“LNEG”), the Directorate-General for Energy and Geology, and the Portuguese Environment Agency.

• GAC-PAB’s main tasks

The GAC-PAB’s main tasks include:

•    promoting the implementation of the PAB’s various lines of action, ensuring institutional coordination and monitoring progress;

•    identifying the regulatory and economic–financial support instruments for biomethane production;

•    assessing infrastructure needs, particularly connections to the gas transmission network for biomethane injection;

•    setting specific targets, including the integration of biomethane into the public gas network (RPG);

•    assessing opportunities for biomethane use in transportation and industry, focusing on industries included in the intensive energy consumption management system; and

•    proposing measures and actions to develop the biomethane market in Portugal.

• Timeline for documents to be submitted by GAC-PAB

The GAC-PAB must submit the following documents to the Ministry of Energy and Environment:

•    Within three months of its creation:

1. A detailed timeline for PAB actions, prioritizing measures, assigning responsibilities among represented entities, and identifying the resources needed to perform them.
2. A tool for monitoring the plan’s implementation, including goals and indicators.

•    PAB implementation assessment:

1. Annual assessment after the GAC-PAB creation date, the content of which is to be published on the LNEG website.

•    By December 31, 2026:

A proposal to review the PAB.

The GAC-PAB will cease operations on December 31, 2026.

Biomethane investors should closely monitor the documents submitted by the GAC-PAB, which will provide detailed information on timelines, goals, and key indicators for the PAB’s implementation.