The test is whether the EU can reengineer its rules and institutions to make faster permitting standard practice, without compromising legitimacy, democratic accountability, legality, or environmental protection. In competition with jurisdictions where centralized state machinery can deliver scale, the EU must make law work faster.
Not by bypassing rights, but by redesigning procedures to front-load environmental review, consolidating decision making, and clarifying public interest tests. Such smarter legal design can deliver the speed that Europe needs.
The EU's new architecture of speed
Three legislative pillars now define the EU’s accelerated permitting model.
First, the Renewable Energy Directive (RED III) recasts time as a legal entitlement by establishing maximum permitting deadlines and mandating one-stop shops and digital portals. It also aims to shift environmental assessment from project level to plan level, through “renewables acceleration areas”. These are predefined areas, selected and assessed by government at a plan level, where the environmental review is front-loaded through strategic environmental assessment. Within renewables acceleration areas, renewable energy projects that comply with the rules and measures identified in the plans prepared by government are in principle exempt from the obligation to carry out a specific environmental impact assessment at project level. These projects also benefit from shorter permit deadlines and streamlined procedures. By moving key impact assessments to the stage of designating the renewables acceleration areas, RED III aims to convert litigation risks for projects into ex ante planning obligations for government. The European Commission recently proposed the Grid Package, which proposes an amendment of RED III. The amendment would exempt smaller solar and storage installations from any administrative permits and would limit the permit-granting procedures to six months (three months for grid connection procedures).
Legal challenges are expected to focus on the designation of and rules for the renewables acceleration areas, rather than on individual permits for projects within such areas. At the project level, contestable matters are expected to narrow to compliance with the renewables acceleration area rules and unresolved site-specific issues. RED III also introduces further mechanisms for speeding up permitting, including a presumption that renewable energy and related grid and storage are overriding public interests when balanced against nature considerations.
Second, while RED III focuses on clean power generation, the Net-Zero Industry Act (NZIA) applies a comparable fast track framework to both the manufacturing of clean tech equipment and the entire carbon capture, transport, use, and storage system. Maximum deadlines for permit-granting, “Strategic Project” priority and “acceleration valleys” (government-designated specific areas to accelerate net-zero industrial activities) are a deliberate industrial policy. For example, designation of a project as a Strategic Project under the NZIA confers concrete speed advantages. Strategic Projects benefit from shorter maximum permitting deadlines compared with non-strategic projects, and are prioritized in administrative sequencing. In practice, these measures will compress timelines for equipment manufacturing facilities and for carbon capture, transport, use and storage infrastructure.
The third pillar concerns accelerated permitting for electricity networks. Under the Trans-European Networks for Energy Regulation (TEN-E), in-scope cross-border energy infrastructure projects benefit from fast track administrative and judicial procedures, including streamlined permitting processes. The aim is to prevent the electricity grid becoming the bottleneck that slows the EU’s transition to clean energy. TEN-E similarly mandates coordinated permitting through a one-stop shop and sets binding overall time limits for the permitting of certain projects. In addition, the above-mentioned Grid Package intends to streamline permitting for Projects of Common Interest and Projects of Mutual Interest, with a maximum of 42 months across the pre-application and statutory phases. The Grid Package also aims to speed up the permitting process for (regular) electricity networks and connection procedures for renewable installations. In this respect the Grid Package intends to introduce a time limit of two years for grid authorization procedures, extendable by up to one additional year in duly justified extraordinary cases.
It also states that requests for additional information from project promoters must be made within three months of application. Tacit approval applies where authorities fail to act within the deadline, except for environmental decisions and grid connection permits.
Taken together, the EU is rebalancing administrative burdens and streamlining permitting procedures for energy transition projects, with the aim of prioritizing decarbonization and industrial resilience.
However, such recalibration will hinge on Member States building the administrative capacity to do it well. For instance, strategic environmental assessments for renewables acceleration areas must be sufficiently granular to displace project-level studies in practice. That requires better data, expert staffing, and genuine early participation, all at the Member State level. One concrete danger is that if authorities do not put enough resources into the planning stage, projects will again necessitate one-off, project-specific studies, negating the anticipated benefits.
What do expect over the short, medium, and long term
In the short term (6–12 months), elements of the EU’s permitting reforms will inevitably be challenged, including the new deadlines. Issues will therefore be tested in court. In parallel, however, authorities will gain experience in dealing with the accelerated permitting procedures. For lawyers and project teams, the immediate job will be to design projects to fit the new simplified model (including by using standard design envelopes and combined permits) and to keep clear records showing how they meet pre-approved environmental measures at plan level so they can withstand legal scrutiny.
In the medium term (12–18 months), the grid will be both the main bottleneck and the key opportunity. As indicated above, the European Commission aims to accelerate the permitting procedures for the electricity grid with the Grid Package. The Grid Package will need to be enacted in the medium term and subsequently implemented in national law.
Over the long term (18 months–5 years), faster permitting will progress from a policy imperative to an established reality. Day-to-day government practice will adopt the fast permitting approach for clean energy projects, with clean energy infrastructure treated as an overriding public interest. Difficult issues will remain, including on cumulative impacts, biodiversity recovery, and local opposition. But as new instruments such as renewables acceleration areas and net-zero acceleration valleys mature, the default is likely to move away from project-by-project challenges, with pre-assessment of suitable areas becoming a more established norm. That is how the EU’s permitting system can remain one that prioritizes transparency and consequential openness to legal challenge, and at the same time supports the rapid scaling up of the future’s green projects.
Conclusion
The EU cannot simply replicate the top-down permitting pace used elsewhere. But it can win by sticking to strong, consistent rules, and if each stakeholder maintains a clear view of the public interests at stake. This calls for treating permitting authorities as critical infrastructure, attaching enforceable consequences to deadlines, and declining to revisit plan-level decisions for each project. If the EU maintains that legal discipline, ‘faster permitting’ stops being a slogan and becomes the EU’s practical answer to a more fragmented world.
