text: Recommendation No 02/2026

text: OJ L158, 14.6.2019, p. 22. 2 In the Clean Energy Package approved in late 2018 the recast of

text: Regulation (EC) 714/2009

text: , i.e.

text: Regulation (EU) 2019/943

text: , proposed by the European Commission, includes provisions that modified the operation of several NC and GL, as well as additional areas for NC and GL to be developed (e.g. demand response, cybersecurity). Page 1 of 8

text: Recommendation No 02/2026

text: ‘TYNDP’ stands for Ten-Year Network Development Plan, cf.

text: Article 30(1) of Regulation (EU) 2019/943

text: and Regulation 2022/869. 4 ‘ERAA’ is the European Resource Adequacy Assessment, cf.

text: 5 See

text: Article 37(1) of Regulation (EU) 2019/943

text: . 6 ACER Market Integration Report 2024 (https://www.acer.europa.eu/sites/default/files/documents/Publications/ACER_2024_MMR_Market_Integration. pdf) 7 In the Nordic region alone, a three-month delay in flow-based coupling was estimated to negatively affect social welfare by over €60 million – See p.24 of the External parallel run evaluation report - For assessment by the NRAs of the Nordic CCR, as required by the Nordic DA/ID CCM 8 With enforcement this document refers to the process leading into a non-compliance decision and in some cases issuing appropriate sanctions.

text: Recommendation No 02/2026

text: 39th European Electricity Regulatory Forum conclusions (see https://energy.ec.europa.eu/events/39theuropean-electricity-regulatory-forum-2024-05-27_en)

text: Recommendation No 02/2026

text: (18) The national regulatory authorities are entrusted with ensuring the compliance of electricity undertakings with their obligations under EU law. This is being done by organising coordinated compliance monitoring projects of different TCMs. Monitoring is at the core of a robust compliance procedure and the most impactful phase for safeguarding the implementation of high-quality projects in due time. Monitoring activities are necessary to guarantee, among other aspects, the systematic identification of the root causes of the delays.

text: Recommendation No 02/2026

text: Recommendation No 02/2026

text: For clarity, when referring to 'All TSOs’ obligations, we are referring to the provisions that are assigned to TSOs as a collective and not including any obligations that are assigned to ENTSO-E; when referring to ‘All NEMOs’ obligations we are referring to the provisions that are assigned to NEMOs as a collective. 11 ACER ran a survey in 2024 among 19 national regulators, to compare national enforcement processes. 12 Such as in the 15’ MTU, LTFB and CGM cases.

text: Recommendation No 02/2026

text: Changes to

text: Article 4(7)

text: may also need to be reflected in

text: Article 6(10) of Regulation (EU) 2019/942

text: . 14 In particular, the ‘Meroni-doctrine’ and the ensuing case-law (

text: ESMA), relating to questions concerning EU agencies’ powers.

text: Recommendation No 02/2026

identifier: ACER Recommendation No 02/2026

title: ACER Recommendation 02-2026 on reasoned proposals for the improvement of the regulatory framework to ensure robust implementation of the internal electricity market rules

text: RECOMMENDATION No 02/2026 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 27 March 2026 on reasoned proposals for the improvement of the regulatory framework to ensure robust implementation of the internal electricity market rules

text: THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to

text: Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators , and, in particular,

text: Article 3(1)

text: thereof, Having regard to the outcome of the consultations with national regulatory authorities, Having regard to the outcome of the consultation with ACER’s Electricity Working Group, Having regard to the favourable opinion of the Board of Regulators of 11 March 2026, delivered pursuant to

text: Article 22(5)

text: (a) of

text: Regulation (EU) 2019/942

text: Whereas:

text: I. INTRODUCTION

text: (1) The European electricity sector is undergoing a profound transformation to become more efficient, secure, affordable and sustainable. Since the adoption of the Third Energy Package and the Clean Energy Package , the EU has progressively established a detailed set of rules through Network Codes (NC) and Guidelines (GL) and under

text: Regulation (EU) 2019/943

text: . Their implementation, via the adoption of Terms and Conditions or

text: Methodologies (TCMs), is critical to achieving the full benefits of the Internal Electricity Market. The TCMs are approved by either the regulatory authorities or ACER and may be Union-wide or regional in scope.

text: (2) NCs, GLs and TCMs, as well as the

text: Regulation (EU) 2019/943

text: , set out obligations for Transmission System Operators (TSOs) and Nominated Electricity Market Operators (NEMOs). These rules also include obligations for the ENTSO for Electricity (ENTSO-E) and regional coordination centres (RCCs), which carry out important tasks for the implementation of the Internal Electricity Market. ENTSO-E is responsible for several tasks across regulations and TCMs, for example, ensuring the functioning of the 3 4 Transparency platform, the TYNDP or the ERAA . RCCs perform important tasks to support TSOs in contributing to the efficient and secure operation of the electricity system across borders within defined regions, including for example capacity calculation, security analysis, and outage planning .

text: (3) While important achievements have been reached in recent years, implementation delays continue to hinder the full realisation of the Union’s electricity market integration policy objective. As of 2024 , over a quarter of the TCMs under review experienced substantial setbacks, frequently causing cascading effects on related projects. There are also persistent delays in the implementation of

text: Regulation (EU) 2019/943

text: obligations.

text: (4) Slowdowns in the implementation of these rules technically impact the improvement of the functioning of the system and can generate economic costs, with different levels of potential welfare loss.

text: (5) A credible and resilient enforcement framework is necessary and important to ensure the implementation of the rules. The legal framework must support the resilience and operational security of the electricity system and ensure that the Internal Electricity Market rules achieve their intended aims. This means that legal actions (regulatory interventions) should be taken when the supervised entities fail to comply with legal obligations under the applicable legal framework. In this case, enforcement actions could determine sanctions or penalties in specified circumstances.

text: (6) To address the concerns about implementation delays, in May 2024, in the framework of the European Electricity Forum, the European Commission requested ACER and

text: regulatory authorities ‘to make a recommendation on how to strengthen the regulatory framework to reduce implementation delays, looking into enforcement, incentives as well as governance’.

text: II. PROCEDURE

text: (7) ACER carried out extensive discussions among regulatory authorities during 2024 and 2025. The discussions focused on the implementation delays and on identifying gaps and proposing solutions with the aim to improving the current framework to support a timely, effective and robust implementation of the Internal Electricity Market rules.

text: (8) Dedicated discussions took place on monitoring, investigation and enforcement aspects regarding Union-wide and regional entities (focusing on ENTSO-E and regional coordination centres (RCCs)), as well as regarding the obligations imposed on all TSOs or all NEMOs and the potential design of incentive schemes.

text: (9) In parallel, regulatory authorities discussed and coordinated actions on a few cases of identified delay, to ensure an efficient implementation of those TCMs through the enforcement process.

text: (10) ACER’s Electricity Working Group (AEWG) was consulted between 12 November and 20 November 2025 and provided its advice on 25 November 2025.

text: (11) In its advice, the AEWG generally supported the draft ACER Recommendation, while noting the concerns by some regulatory authorities on key areas. The expressed concerns were mainly on shifted responsibilities and stressing the importance of a proper legal assessment.

text: (12) On 10 December 2025, a first discussion on the draft ACER Recommendation took place at ACER’s Board of Regulators, which was followed by another discussion on 28 January 2026 with a BoR proposal for amendments. In response to this proposal for amendments, the Director submitted a revised draft ACER Recommendation. During the meeting of 11 March 2026, a further BoR proposal for amendments was adopted and integrated into the final version of this Recommendation.

text: (13) This Recommendation reflects the comments put forward by regulatory authorities during the AEWG consultation, namely concerning the proposals for amendments presented in Chapter V, and reflects the revisions that took place following the BoR discussions.

text: (14) On 11 March 2026, ACER’s Board of Regulators issued a favourable opinion to this Recommendation pursuant to

text: Article 22(5)

text: (a) of

text: Regulation (EU) 2019/942

text: III. LEGAL GROUNDS FOR THE PRESENT RECOMMENDATION

text: (15) Pursuant to

text: Article 3(1) of Regulation (EU) 2019/942

text: , ACER may, upon a request of the European Parliament, the Council or the Commission, or on its own initiative, provide an opinion or a recommendation to the European Parliament, the Council and the Commission on any of the issues relating to the purpose for which it has been established.

text: (16) In accordance with

text: Article 1(2) of Regulation (EU) 2019/942

text: , the purpose of ACER is to assist the regulatory authorities in exercising, at Union level, the regulatory tasks performed in the Member States and, where necessary, to coordinate their action and to mediate and settle disagreements between them. ACER also contributes to the establishment of high-quality common regulatory and supervisory practices, thus contributing to the consistent, efficient and effective application of Union law to achieve the Union's climate and energy goals.

text: (17) ACER is tasked with monitoring and contributing to the implementation of the network codes and guidelines as provided in

text: Article 5(1)

text: d) of

text: Regulation (EU) 2019/942

text: and

text: Article 32 of Regulation (EU) 2019/943

text: . Furthermore, ACER monitors regional cooperation between transmission system operators in the electricity sector as well as the execution of the tasks of ENTSO-E and other entities with regulated functions of Unionwide dimension as provided in

text: Article 4(2) of Regulation (EU) 2019/942

text: IV. MAIN FINDINGS

text: i Implementation Monitoring

text: (19) It follows from the discussions that it is necessary to continuously follow closely and actively the implementation of TCMs and the performance of TSOs/NEMOs’ obligations as well as Union-wide organisations’ or RCCs’ tasks to be able to detect at an early stage any potential delay and potentially react to it, following up directly to prevent or shorten the delay. ACER and regulatory authorities indicate their continued commitment to dedicating more resources, where available, to the monitoring of all relevant entities.

text: (20) Additionally, it was identified that TCM implementation timelines are not always sufficiently detailed or justified in the documents submitted for regulatory approval. A justification for the set deadline is important to understand its potential challenges and any impact on related projects.

text: ii ENTSO-E and RCCs

text: (21) If a potential circumstance of non-compliance arises regarding the obligations of ENTSO- E or RCCs, it is necessary to ensure a swift and adequate response through an effective framework. It is recognised from the discussions that the current framework concerning EU-wide and regional entities as reflected in

text: Article 4(7)

text: and (8) of

text: Regulation (EU) 2019/942

text: could be improved to some extent in terms of streamlining the decision-making process.

text: (22) In simple terms, the current legal framework splits the process into two steps. The first one is related to the identification of a non-compliance situation and, where applicable, the determination of measures to be taken by the concerned entity to remedy the noncompliance. Under the current framework, this first step may be referred to ACER for a decision. The second step refers to the potential sanctioning decision to ensure compliance (namely to impose effective, proportionate and dissuasive penalties in the context of the rules provided in

text: Directive (EU) 2019/944

text: (23) Three key challenges have been identified. The first lies on the necessity for these entities to have the suitable governance structure, the means to fulfil their tasks and to be held accountable for the non-compliance.

text: (24) The second key challenge comes from the current wording of the Regulation itself, which specifies that the relevant regulatory authorities must coordinate in order to jointly identify a non-compliance of a regional or Union-wide entity with its obligations and must take, unanimously, coordinated decisions within a period of four months establishing whether there is non-compliance with the relevant obligations and, where applicable, determining the measures to be taken by those entities to remedy that non-compliance.

text: (25) The third key challenge lies with the framework for the carrying out of the second step. This step may lead to an imbalanced distribution of administrative and financial burdens among regulatory authorities, as it is reliant on the single regulatory authority of the Member State where the entity is located to carry out the proceedings to impose penalties, (whereas the case is of Union or regional dimension).

text: iii Projects entailing a collective responsibility of TSOs and NEMOs

text: (26) In 2021, ACER and regulatory authorities agreed on a process for coordination on enforcement. Particularly since 2024, there has been significant concerted effort by the regulatory authorities and ACER to coordinate monitoring, investigation and enforcement actions towards their national TSOs or NEMOs for failure to comply. Indeed, the analysis of the outcome of a few identified cases indicates better enforcement cooperation, showing improved awareness raising and a better understanding of the causes of implementation delays. Conversely, the experience from national actions taken regarding the cases to date also shows that regulatory authorities may, in accordance with their national law, act differently when it comes to national procedures concerning the same case.

text: (27) The enforcement of individual obligations of TSOs and NEMOs poses no problem to regulatory authorities, with the process relying on the application of national rules and the competence of each individual regulatory authority. At the same time, the current enforcement process could be falling short when tackling delayed implementation or failure to comply cases where, across Union obligations, all TSOs or all NEMOs are tasked with jointly carrying out an obligation and collectively fail.

text: (28) The first key challenge is that there is no detailed allocation of responsibility between the different TSOs and/or NEMOs involved in the implementation. In a situation of proven collective failure to deliver joint obligations, the responsibility of each TSO or NEMO needs to be assessed individually by each regulatory authority at national level.

text: (29) The second key challenge is that national sanctioning procedures vary significantly in terms of measures, timelines and processes. Despite following a coordinated approach, regulatory authorities may face different conclusions to their national investigations. This effect is particularly evident when TSOs/NEMOs are dependent on their peers in neighbouring Member States to achieve compliance and especially when actions must be taken collectively .

text: V. LEGISLATIVE AMENDMENTS

text: (30) It follows from the previous section that ACER and regulatory authorities have concluded on the need for legislative amendment proposals to be developed concerning subsections i and ii of Section IV. The proposals should be consistent with the objectives of the Clean Energy Package and ensure the respect for the principles of proportionality and subsidiarity. The Commission should conduct an in-depth assessment against Union law and its general principles to ensure legal feasibility. Furthermore, the Commission should conduct a complete impact assessment including an assessment of the proposals’ effectiveness in ensuring timely implementation.

text: (31) Concerning subsection iii of Section IV, no legislative amendments are proposed at this stage. ACER recommends that further assessment is conducted by the Commission to further improve effective and credible enforcement of the obligations put collectively on all TSOs and all NEMOs.

text: i Implementation monitoring

text: (32) ACER proposes the introduction of new provisions (in the

text: Regulation (EU) 2019/943

text: or in the relevant NC and/or GL) ensuring that TCMs include more details and justifications about their implementation timeline, including details on the distribution of the relevant tasks, the expected net benefits of the TCM and the potential impact in case of implementation delay. When the TSOs and/or NEMOs draft TCMs, they must in the future include better justifications of the implementation deadlines, and the potential interrelations among the involved processes, and must be required to regularly report on the implementation.

text: ii ENTSO-E and RCCs

text: (33) ACER proposes the revision of

text: Article 4(7)

text: and (8) of

text: Regulation (EU) 2019/942

text: for the improvement of the enforcement framework in case of non-compliance of ENTSO-E and RCCs. The amendment of Articles 2 and 3 of the

text: Regulation (EU) 2019/942

text: , as well as Article 59 of the

text: Directive (EU) 2019/944

text: would also be required.

text: (34) Throughout the discussions, regulatory authorities generally supported a swifter procedure and the attribution of some sanctioning competences to ACER. This includes the possibility for ACER to impose sanctions or penalties if requested by the regulatory authority where ENTSO-E or the RCC has its seat. ACER’s competences should be defined in clearly delineated and precise terms in

text: Regulation (EU) 2019/942

text: . Such decision-making by ACER must be in line with the jurisprudence of the European Court of Justice and with the principles of subsidiarity and proportionality.

text: (35) The involvement and cooperation of the regulatory authorities in the ACER decisions must be guaranteed throughout the decision-making process, from the assessment of the noncompliance to the definition of the enforcement measures, via the discussion in the task forces and ACER’s Electricity Working Group as well as, finally, per the obtainment of the necessary favourable opinion by the ACER’s Board of Regulators.

text: (36) Any appeal procedures of an ACER decision would take place at Union level, and any resulting judicial costs would be incurred by ACER. ACER would apply the penalties/sanctions that would be defined in the ACER Regulation. This would require amendments to

text: Regulation (EU) 2019/942

text: HAS ADOPTED THIS RECOMMENDATION:

text: ACER recommends - amendments to improve TCM implementation deadlines as well as the introduction of reporting obligations to mitigate implementation delays of all entities that are addressed by TCMs, - amendments to further improve effective and credible enforcement of compliance of ENTSO-E´s and RCCs’ obligations, notably as regards

text: Article 4(7)

text: and (8) of

text: Regulation (EU) 2019/942

text: and - that further assessment is conducted by the Commission to ensure effective and credible enforcement of all TSOs and all NEMOs obligations.

text: This Recommendation is addressed to the European Commission. Done at Ljubljana, on 27 March 2026.

text: - SIGNED -

text: Fоr the Agency The Director ad interim

text: V. ZULEGER


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identifier: ACER Recommendation No 03/2013

publisher: Europeiska unionens byrå för samarbete mellan energitillsynsmyndigheter

sprak: en

title: ACER Recommendation 03-2013 on the Network Code on Gas Balancing of Transmission Networks

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text: Publishing date: 27/03/2013

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title: ACER Recommendation 03-2014 on Incentives for Projects of Common Interest and on a Common Methodology for Risk Evaluation

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identifier: ACER Recommendation No 03/2015

title: ACER Recommendation 03-2015 on the Network Code on Electricity Balancing

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text: OJ L158, 14.6.2019, p. 22. OJ L 158, 14.6.2019, p. 54–124. OJ L 112, 24.4.2016. Page 1 of 8

text: Recommendation No 03/2023

text: OJ L 223,18.8.2016 ACER/ CEER draft Policy Paper on the revision of network code on requirements for grid connection of generators and network code on demand connection Policy Paper on the revision of the Network Code on Requirements for Grid Connection of Generators and the Network Code on Demand Connection.

text: Recommendation No 03/2023

text: Recommendation No 03/2023

text: Due to the numerous and extensive amendments, ACER proposes that the RfG Regulation and the DC Regulation are repealed.

text: Recommendation No 03/2023

text: Recommendation No 03/2023

text: Recommendation No 03/2023

text: Recommendation No 03/2023

identifier: ACER Recommendation No 03/2023

title: ACER Recommendation 03-2023 on reasoned proposals for amendments to the network codes on requirements for grid connection of generators and on demand connection

text: RECOMMENDATION No 03/2023 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 19 December 2023 on reasoned proposals for amendments to the

text: Commission Regulation (EU) 2016/631 of 24 April 2016

text: establishing a network code on requirements for grid connection of generators and

text: Commission Regulation (EU) 2016/1388 of 17 August 2016

text: establishing a network code on demand connection

type: rubrik

text: THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to

text: Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators , and, in particular,

text: Article 3(1)

text: thereof, Having regard to

text: Regulation (EU) 2019/943

text: on the internal market for electricity , and, in particular,

text: Articles 59(2)

text: (a) and 60(3) thereof, Having regard to the outcome of the public consultations, Having regard to the outcome of the consultation with ACER’s Electricity Working Group, Having regard to the favourable opinion of the Board of Regulators of 13 December 2023, delivered pursuant to

text: Article 22(5)

text: (a) of

text: Regulation (EU) 2019/942

text: , Whereas:

text: I. INTRODUCTION

text: (1) In September 2022, in the framework of the Grid Connection Stakeholders Committee, the European Commission proposed that ACER initiates the process to prepare reasoned proposals for amendments to the grid connection network codes, namely the

text: Commission Regulation (EU) 2016/631 of 14 April 2016

text: establishing a network code on requirements for grid connection of generators (hereafter: the RfG Regulation) and

text: the

text: establishing a network code on Demand Connection (hereafter: the DC Regulation) .

text: (2) In May and September 2022, ACER published a draft Policy Paper (jointly with CEER) and a Policy Paper . In the latter, ACER provided a high-level outline of the main areas to improve the RfG Regulation and the DC Regulation. The ACER Policy Paper reflected ACER’s considerations on possible amendments to the grid connection network codes following input received from stakeholders during the summer 2022.

text: (3) The Policy Paper addressed potential amendments to the network codes concerning among others: technical requirements for storage, mobile storage and electrical charging points; requirements for mixed customer sites (MCSs), active customers and energy communities; significant modernisation of system users’ facilities and equipment; advanced capabilities for grids with significant distributed energy resources (DER) and converter-based technologies; and criteria to determine generators significant for the system.

text: II. PROCEDURE

text: (4) ACER conducted a first public consultation with stakeholders from 26 September until 21 November 2022, to collect stakeholders’ proposals on the amendments of the RfG Regulation and the DC Regulation. The evaluation of responses to the public consultation is detailed in Annex 6 to this Recommendation.

text: (5) In addition to the public consultation, ACER held three public workshops with stakeholders, with the purpose to introduce the proposed amendments, and a webinar (19 July 2023) to assist stakeholders in providing feedback to the public consultation and allow stakeholders to pose questions to ACER and the regulatory authorities involved in the drafting of the amendments. The workshops focused on specific regulatory issues, namely: electromobility, power-to-gas demand units and heat-pumps (17 April 2023), rate of change of frequency and grid forming capabilities (10 May 2023), and electricity storage (11 May 2023).

text: (6) Throughout the procedure, ACER engaged with interested stakeholders in the review of the amendments in order to ensure that they had sufficient opportunity to express their views and concerns. Further, several meetings, with representatives of the relevant European stakeholders’ associations, were held on specific proposed amendments (mainly concerning Rate of Change of Frequency (RoCoF) and electromobility).

text: (7) In accordance with

text: Article 60(3) of Regulation (EU) 2019/943

text: on the internal market for electricity (hereafter: Electricity Regulation) and

text: Article 14 of Regulation (EU) 2019/942

text: , ACER conducted a second public consultation from 17 July until 25

text: September 2023 to gather stakeholders’ views on concrete amendment proposals to the electricity grid connection network codes. The evaluation of responses to the public consultation is detailed in Annex 7 to this Recommendation.

text: (8) ACER’s Electricity Working Group (hereafter: AEWG) was consulted between 20 November and 21 November 2023, and provided its advice on 23 November 2023.

text: (9) In its advice, the AEWG endorsed the draft ACER Recommendation on reasoned proposals for amendments to the RfG Regulation and to the DC Regulation.

text: (10) In its advice, the AEWG considers that as regards the RfG Regulation and the DC Regulation no significant concerns by NRAs have been stated. The AEWG invites ACER to take note of the comments raised by specific NRAs and some that have already been resolved during the meeting.

text: (11) On 13 December 2023, ACER’s Board of Regulators adopted an amendment on the proposed RfG Regulation and issued a favourable opinion, pursuant to

text: Article 22(5)

text: (a) of

text: Regulation (EU) 2019/942

text: , on the proposed RfG Regulation, as revised by its amendment, and on the proposed DC Regulation.

text: III. LEGAL GROUNDS FOR THE PRESENT RECOMMENDATION

text: (12) In the framework of the Grid Connection Stakeholders Committee in September 2022, the European Commission proposed that ACER initiates the process to prepare reasoned proposals for amendments to the grid connection network codes.

text: (13) The RfG Regulation and the DC Regulation are network codes, as referred to by

text: Article 59 of Regulation (EU) 2019/943

text: on the internal market for electricity (hereafter: Electricity Regulation)relating to the area of ‘network connection rules’ under

text: Article 59(2)

text: (a) of the Electricity Regulation, which is specified as including rules on the connection of transmission-connected demand facilities, transmission-connected distribution facilities and distribution systems, connection of demand units used to provide demand response, requirements for grid connection of generators, requirements for high-voltage direct current grid connection, requirements for direct currentconnected power park modules and remote-end high-voltage direct current converter stations, and operational notification procedures for grid connection.

text: (14) Article 60 of the Electricity Regulation defines a process for the amendment of network codes within the areas listed in

text: Article 59 (1)

text: and (2) thereof, with ACER having a formal role for the proposal of such amendments.

text: (15) According to the first sentence of Article 60(3) of the Electricity Regulation, ACER may make reasoned proposals to the Commission for amendments, explaining how such proposals are consistent with the objectives of the network codes set out in Article 59(3) of the same Regulation. Article 59(3) of the Electricity Regulation does not refer explicitly to objectives and states that the Commission should establish a priority list every three years, identifying the areas to be included in the development of network codes. Instead, subsequently,

text: Article 59(4)

text: and (11) of the Electricity Regulation do

text: define objectives for the development of network codes, namely contribution to market integration, non-discrimination, effective competition, and the efficient functioning of the market. Accordingly, the reference in Article 60(3) of the Electricity Regulation to the objectives of Article 59(3) of that Regulation should be read together with

text: Article 59(4)

text: and (11) of the same Regulation and in light of the objectives listed therein. Therefore, these objectives are also relevant for the amendments proposed in this Recommendation (as detailed in the reasoning provided in Annexes 3, 4 and 5).

text: (16) According to the second sentence of Article 60(3) of the Electricity Regulation, where ACER considers an amendment proposal to be admissible and where it proposes amendments on its own initiative, ACER should consult all stakeholders in accordance with

text: Article 14 of Regulation (EU) 2019/942

text: . Pursuant to

text: Article 14(1) of Regulation (EU) 2019/942

text: , ACER, in the process of proposing amendments of network codes under Article 60 of the Electricity Regulation, has to ‘extensively consult at an early stage market participants, transmission system operators, consumers, end-users and, where relevant, competition authorities, without prejudice to their respective competence, in an open and transparent manner, in particular when its tasks concern transmission system operators’.

text: (17) Finally, according to

text: Article 3(1) of Regulation (EU) 2019/942

text: , ACER may, upon a request of the European Parliament, the Council or the Commission, or on its own initiative, provide an opinion or a recommendation to the European Parliament, the Council and the Commission on any of the issues relating to the purpose for which it has been established.

text: (18) As indicated by

text: Articles 59(2)

text: (a) and 60(3) of the Electricity Regulation, ACER’s contribution to the amendment of network codes concerns issues relating to a purpose for which ACER has been established.

text: IV. MAIN FINDINGS

text: (19) ACER found that amendments to the RfG Regulation and the DC Regulation would be required in the areas set out in paragraphs (26) to (41). In line with the Commission’s request and taking into account the outcome of extensive consultation with the relevant stakeholders, ACER has proposed those amendments in Annexes 1 and 2 to this Recommendation for the reasons detailed in Annexes 4 and 5 to this Recommendation explaining how such proposals are consistent with the objectives in Article 59(4) of the Electricity Regulation .

text: (20) The amendments proposed by ACER take into consideration the advice received from the AEWG (see above in paragraphs (9)-(10)).

text: a. Consultation of the AEWG

text: (21) With reference to the comments of specific NRAs (as annexed in AEWG Advice), they are related in essence to the following: - As regards the RfG Regulation, the comments refer to clarification on the term “same underlying technology”, clarification on the definition of “maximum capacity”, the use of different term regarding the content of charge for electricity storage modules, the consideration of distribution faults for fault-ride-through capability for electric vehicles (EVs), the application of provisions for small type C power park modules (PPMs) regarding grid forming capability in line with type B PPMs provisions, the aggregation of EVs and electric vehicle supply equipment, the final operational notification procedure for EVs and type A power-generating modules (PGMs), clarification on the timeline for the submission of the proposal of transmission system operators (TSOs) regarding significant modernisation, the consideration of nuclear safety rules and the provisions on information exchange of type B PGMs; - As regards the DC Regulation, the comments refer to adjustment of Figure (3)XX.c on limited frequency sensitive mode (LFSM) capabilities of V1G electric vehicles, the consideration of distribution faults for fault-ride-through capability for EVs and power-to-gas demand units, additional requirements for data centre demand units and clarification on the timeline for the submission of the proposal of TSOs regarding significant modernisation.

text: (22) ACER’s consideration of the comments from regulatory authorities on the different topics is indicated, where pertinent, in Annexes 1 and 2 to this Recommendation.

text: b. Amendment of the Board of Regulators

text: (23) CRU submitted an amendment request regarding paragraph 3 of Article 30 of the RfG Regulation. ACER Director submitted a counter proposal to this amendment of paragraph 3 of

text: Article 30

text: (24) The Board of Regulators adopted the amendment with regard to the proposed paragraph 3 of Article 30 of the RfG Regulation regarding the issue of the final operational notification (FON) for type A PGMs.

text: (25) ACER took this amendment into account and revised the proposal for amendments to the RfG Regulation accordingly (see Annexes 1 and 1a).

text: c. Amendments to the RfG Regulation

text: (26) For the general provisions, ACER proposes amendments to definitions, significant modernisation, expansion of application to electricity storage modules, Vehicle-to-Grid (V2G) electric vehicles and associated V2G electric vehicles supply equipment, power generating modules embedded in networks of industrial sites, and regulatory aspects.

text: (27) For the general requirements, ACER proposes amendments to general requirements for type A B, C and D power-generating modules, introduction of requirements for type EV1 and EV2 V2G electric vehicles and associated V2G electric vehicles supply equipment as well as introduction of requirements for type EV3 electric vehicles and associated V2G electric vehicle supply equipment and V2G electrical charging parks.

text: (28) For the requirements for synchronous power-generating modules, ACER proposes amendments to the requirements for type A, B, C and D synchronous power-generating modules.

text: (29) For the requirements for offshore power park modules, ACER proposes amendments to the frequency and voltage stability requirements, robustness requirements, system restoration requirements as well as general management requirements applicable to ACconnected offshore power park modules.

text: (30) For the connection of new power-generating modules, ACER proposes the introduction of new article on the connection procedure for type EV2 and associated V2G electric vehicle supply equipment and for type EV3 and associated V2G electric vehicle supply equipment.

text: (31) For compliance monitoring, ACER proposes amendments to compliance testing, on compliance testing for V2G electric vehicles and associated V2G electric vehicle supply equipment, for type B power park modules, for offshore power park modules, compliance simulations for type B and C for synchronous power-generating modules, for type B and C power park modules and on equipment certificates.

text: (32) For the monitoring of implementation, ACER proposes amendments to update the monitoring process in accordance with the Electricity Regulation.

text: (33) For the transitional and final provisions, ACER proposes amendments to transitional provisions regarding emerging technologies and introduces new final provisions.

text: d. Amendments to the DC Regulation

text: (34) For the general provisions, ACER proposes amendments to the definitions, scope of application, significant modernisation and regulatory aspects.

text: (35) For the connection of the transmission connected demand facilities, transmission connected demand facilities and distribution systems provisions in the DC Regulation, ACER proposes amendments to general requirements (amendment to short circuit requirements, reactive power requirements, demand connection and demand reconnection and simulation models) and to operational notification procedure (amendments to interim operational notification and to final operational notification).

text: (36) For the connection of demand units used by a demand facility or a closed distribution system to provide response services to system operator, ACER proposed amendments to the general provisions of the operational notification procedure, to procedures for demand units providing demand response services.

text: (37) ACER proposed the introduction of new provisions on connection of unidirectional charging (V1G) electric vehicles and associated electric vehicles supply equipment, power-to-gas units and heat pumps (general requirements, operational notification procedure).

text: (38) Regarding compliance, ACER proposed amendments on the general provisions so as the demand units and V1G vehicles and associated electric vehicles supply equipment, power-to-gas units and heat pumps to be included. ACER also proposed amendments to compliance simulations for transmission connected distribution facilities.

text: (39) For the non-binding guidance and monitoring of implementation, ACER proposed amendments to align the monitoring process with the provisions of the Electricity Regulation.

text: (40) For the transitional and final provisions, ACER proposes amendments to transitional provisions regarding emerging technologies and introduces new final provisions.

text: (41) For Annexes I and II, ACER proposed amendments to general frequency ranges and time period referred to in

text: Article 12(1)

text: , and voltage ranges and time periods referred to in

text: Article 13(1)

text: , respectively,

text: HAS ADOPTED THIS RECOMMENDATION:

text: 1. ACER recommends to amend

text: establishing a network code on requirements for grid connection of generators, in accordance with Annex 1, for the reasons explained in Annex 4.

text: 2. ACER recommends to amend

text: establishing a network code on demand connection, in accordance with Annex 2, for the reasons explained in Annex 5.

text: This Recommendation is addressed to the European Commission.

text: Done at Ljubljana, on 19 December 2023.

text: - SIGNED -

text: Fоr the Agency The Director

text: C. ZINGLERSEN

text: Annexes:

text: Annex 1 – Amended RfG Regulation Annex 1a – Amended RfG Regulation TC compared to the current Regulation Annex 2 – Amended DC Regulation Annex 2a – Amended DC Regulation TC compared to the current Regulation Annex 3 – Policy Paper Annex 4 – Reasoning to proposed amendments to the RfG Regulation Annex 5 – Reasoning to proposed amendments to the DC Regulation Annex 6 – Evaluation of responses to the public consultation (26 September until 21 November 2022) Annex 7 - Evaluation of responses to the public consultation (17 July until 25 September 2023).


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text: Agency for thee Cooperation oof Energy Reguulators Trg Republikke 3 10000 Ljubljana, SSlovenia

text: Ref: AA13-MMG-12-003 ACERR Recommendaations on Recorrds of Transactiions for balanciing and transportation contractts

identifier: ACER Recommendation No 06/2013

title: ACER Recommendation 06-2013 on REMIT Records of Transactions

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text: RRecommmenndatioons

text: to the Commmissionn as regards thee recordds of wholesalle energgy markket ttransacctions, inncludinng orderrs to traade, acccordinng to AArticle 8 of Regulation (EU) Noo 1227/22011 conncerning balanncing market annd transsportatiion conntracts

text: 26 March 2013

text: AAccording to Article 7((3) of Reguulation (EU)) No 1227/22011 on whholesale Ennergy MMarket Integrity and TTransparenccy (“REMIT”), the Agency for thee Cooperatioon of EEnergy Reggulators (thee “Agency” or “ACER””) may makke recommeendations too the CCommissionn as to the records off transactions, includinng orders too trade, whhich it cconsiders are necessary to effectively monitoor wholesalee energy maarkets.

text: TThe Agenccy has consulted wiith interestted partiess, includingg with Nattional RRegulatory Authorities (“NRAs“), ccompetent financial suupervisory aauthorities in the MMember Sttates, natioonal compeetition authhorities andd ESMA and provideed its RRecommendations to the Commmission on 23 Octobber 2012. HHowever, wwhen pproviding itss Recommmendations, the Agenccy announcced its intention to loook in mmore detail into balanccing market and transpoortation conntracts.

text: TThis documment containns the Recoommendatioons to the CCommissionn as regards the RREMIT recoords of wholesale enerrgy market ttransactionss, including orders to ttrade, oon balancing markets aand in transsportation ccontracts, which it conssiders necesssary tto effectiveely monitor wholesalee energy mmarkets andd as regards the REEMIT implementinng acts accoording to Arrticle 8 of REMIT.

text: Relatedd Documennts

text:  ACEER Work Prrogramme 22013, http://www.acer.europa.euu/portal/page/portal/ACCER_HOMEE/The_Agenncy/Work_pprogramme/ ACEERWP%2022012FINAL.pdf

text:  ACEER Recommmendations to the Commmission ass regards thee records oof wholesalee energy marrket transacctions, includding orders to trade, acccording to Article 8 of f Regulationn (EU) No 1227/201, 23 OOctober 2012, http://www.acer.europa.euu/remit/Docuuments/Reccommendattions%20onn%20REMITT%20Recorr ds%%20of%20traansactions..pdf

text:  ACEER Guidancce on the appplication off the definitions set outt in Article 22 of Regulattion

text: (EU) No 11227/2011

text: of the European Parliaament and oof the Council of 25 Occtober 2011 on nd whoolesale enerrgy market iintegrity andd transpareency, 2 edition 2012, http://www.acer.europa.euu/remit/Docuuments/1st__edition_ACCER_guidance.pdf

text: (EU) No 11227/2011

text: of the European Parliaament and oof the Council of 25 Occtober 2011 on st whoolesale enerrgy market iintegrity andd transpareency, 1 edition 2011, http://www.acer.europa.euu/remit/Docuuments/1st__edition_ACCER_guidance.pdf

text:  REGGULATION

text: (EU) No 12227/2011

text: OOF THE EURROPEAN PARLIAMENNT AND OF THE COUUNCIL on wwholesale energy markket integrity and transpaarency, http://eur-lex.euuropa.eu/LeexUriServ/LLexUriServ.ddo?uri=OJ:LL:2011:326:0001:00166:en:PDF

text:  REGGULATION

text: (EC) No 7113/2009

text: OFF THE EUROOPEAN PAARLIAMENTT AND OF TTHE COUUNCIL of 133 July 20099 establishinng an Agenccy for the CCooperation of Energy RRegulators

text: http://eur-lex.euuropa.eu/LeexUriServ/LLexUriServ.ddo?uri=OJ:LL:2009:211:0001:00144:EN:PDF  REGGULATION

text: (EC) No 7114/2009

text: OFF THE EUROOPEAN PAARLIAMENTT AND OF TTHE COUUNCIL of 133 July 20099 on conditioons for acceess to the network for ccross-bordeer exchhanges in eelectricity annd repealingg

text: Regulation (EC) No 11228/2003

text: , http://eur-lex.euuropa.eu/LeexUriServ/LLexUriServ.ddo?uri=OJ:LL:2009:211:0015:00355:EN:PDF  REGGULATION

text: (EC) No 7115/2009

text: OFF THE EUROOPEAN PAARLIAMENTT AND OF TTHE COUUNCIL of 133 July 20099 on conditioons for acceess to the natural gas ttransmission networks and repealing RRegulation (

text: (EC) No 1775/2005

text: , http://eur-lex.euuropa.eu/LeexUriServ/LLexUriServ.ddo?uri=OJ:LL:2009:211:0036:00544:EN:PDF

text: Tabble of Coontents

text: 1 Inntroductionn

text: Backgrround

text: On 23 OOctober 20012, the Aggency providded the Coommission wwith its Reccommendattions on thee Recordss of Transaactions, including ordeers to tradee, which it cconsiders nnecessary to effectively monitor r wholesale energy maarkets and as regardss the REMITT implemennting acts aaccording too Article 88 of REMIT..

text: The Aggency consiiders thesee recommenndations ass a sound basis for thhe development of thee REMIT records of transactionns and impplementing acts. The rrecommenddations werre consultedd with releevant stakeeholders, inccluding ESMMA, nationaal financial mmarket authhorities and competition authoritties. Responnses received were takken into acccount as muuch as posssible.

text: In its reecommendaations of 233 October 22012, the AAgency indiccated its inttention alsoo to develop recommmendations on the REEMIT recordds of transaactions andd implementing acts foor balancingg market contracts and transporrtation contracts and too consult reelevant stakkeholders ahhead of their adoption.

text: In the mmeantime, the Agencyy has conssulted with ENTSO-E and ENTSSOG on thee records oof transacttions for baalancing maarket contracts and trannsportation contracts. Their viewss, as well as stakehoolder views expressed during the public conssultation of the draft reecommendaations, weree taken innto account as much ass possible.

text: Objective of thesee recommeendations

text: These rrecommenddations commplement the Agency’ss recommenndations froom 23 October 2012 as regardss balancing market contracts and ttransportatioon contractts.

text: The purrpose of thee recommenndations prresented in this documment is to asssist the Coommission in drafting the REMITT implementting acts acccording to AArticle 8 of tthe Regulattion.

text: 2 Recommenddations on Records oof Transacttions for baalancing mmarket contracts

text: Backgrround

text: Contraccts in balanncing markkets are coovered by tthe definitioon of wholeesale energgy products accordinng to Articcle 2(4) of REMIT and balancingg markets are covereed by the definition oof wholesaale energy markets acccording too Article 2(66) of REMIT. Thereforre trading iin balancingg market contracts faalls within thhe scope off REMIT.

text: According to Article 8(1) of RREMIT, maarket participants, or aa third partyy on their bbehalf, shaall provide the Agenccy with a reecord of wholesale eneergy market transactioons, includinng orders too trade, oon the basiis of the CCommission’s implemeenting acts. In its recoommendatioons from 233 Octoberr 2012, thee Agency cconsidered that for reecords of ttransactions in balanccing markeet contractts, Annexess II.1, II.2 aand II.3 could be takenn as a reference, but inndicated itss intention too consult on that isssue separattely with TSSOs or perrsons organnising thesee markets oon behalf oof TSOs bbefore recommending records of transactionns for the rreporting of f such information. Thee Agency furthermoore recommmended thaat the implementing acts shoulld stipulatee a phasedd approacch by delayying the repoorting of reccords of traansactions in balancingg market coontracts by 66 months.

text: Responnses on thee Consultaation Paperr

text: The Ageency has inn the meanttime, in adddition to its public conssultation, coonsulted bilaterally with relevantt stakeholdeers.

text: Recommendationns

text: On the basis of thhe Agency’ss own viewws and takinng into acccount the reesponses reeceived, thee Agency recommennds the folloowing:

text: Recommendationn on recordds of transsactions inn balancingg market ccontracts: TThe Agency recommmends that tthe data coollection of records of ttransactionss in balanccing market contracts is postponned until the relevant network coodes apply.. Separate implementing acts for records oof transacttions in baalancing maarket contrracts should take intoo account these netwwork codess. Balancing market ccontracts shhould thereffore currenttly not be included in thhe list of conntracts to bee reportedd. The Ageency considders that ssuch separaate implementing actss for balancing markeet contractts should aapply after the expiraation of a relevant transitory peeriod of 122-24 months following the day oof entry intoo force of thhe Networkk Codes on Electricity Balancing and on Gas Balancing

text: Until thee entry into application of such separate impllementing aacts, nationaal regulatoryy authorities should collect infoormation annd monitor balancing markets onn the basiss of their coompetences rd under thhe 3 energgy package on a regulaar basis, paarticularly puursuant to AArticles 35 eet seq. of thee Electricity Directivee and

text: Articles 39

text: et seeq. of the GGas Directivve. They shhall regularly inform thee Agency about the balancing mmarket deveelopments aand the outtcome of their monitoriing activities in the context of thhe cooperattion with thee Agency, aaccording too

text: Article 16(1)

text: , subparaagraph 3, oof REMIT, in order too enable the Agency tto carry outt its monitooring of whoolesale eneergy markets accordinng to Article 7(1) of RREMIT effecctively and efficiently, in particulaar as regarrds potentiaal cross-mmarket abuse cases.

text: Explanaatory text

text: Balancing marketss, as defineed in the reelevant Fraamework Guidelines, nnamely the Frameworrk Guidelinnes on Gas Balancing in Transmission Syystems (FGGB-2011-G-002) from 18 Octobeer 2011 aand the Frramework Guidelines on Electrricity Balanncing (FG--2012-E-0099) from 188 Septemmber 2012, are currently still veery differennt across Europe. Thhere are ccurrently noo Europeaan standarddised produucts. This wwould makee the pan-EEuropean mmonitoring oof balancingg marketss very difficcult. Thereffore, for thhe sake of efficiency, it is recommmended tto await thee relevantt balancingg network ccodes which foresee hharmonisation of prodducts on thhe balancingg marketss. The relevvant Framewwork Guidelines stipulaate that the network coodes on ballancing shaall take preecedence oover relevaant national frameworkks (legislation, regulattion, codes, standardss, etc.) forr cross-bordder and marrket integraation issues and national framewoorks shall bee adapted too the exteent necessaary to ensurre proper immplementatioon at the naational levell.

text: 3 Recommenddations on Records oof Transacttions for traansportatioon contraccts

text: Backgrround

text: Article 22(4)

text: (c) and (d) of REMIT specifiically definees contracts relating tto the transsportation oof electricity or naturaal gas in thee Union andd derivativess relating too the transpportation of electricity oor natural gas in the UUnion as wwholesale ennergy produucts. Thereffore, the traading of thesse contracts falls within the scoppe of REMIT.

text: According to Article 8(1) of RREMIT, maarket participants, or aa third partyy on their bbehalf, shaall provide the Agenccy with a reecord of wholesale eneergy market transactioons, includinng orders too trade, oon the basiis of the CCommission’s implemeenting acts. In its recoommendatioons from 233 Octoberr 2012, thee Agency understoodd transportaation contraacts accordding to Artticle 2(4) oof REMIT as capacityy contracts for the trannsportation of natural ggas or electtricity in thee Union. Thee Agency consideredd that for reecords of traansactions in transporrtation contrracts, Anneexes II.1, II.22 and II.33 could be taken as a referencce, but indicated its inntention to consult onn that issuee separattely with TTSOs or ppersons organising thhese markkets on beehalf of TSSOs beforee recommmending reccords of trransactionss for the rreporting off such infoormation. TThe Agency furthermmore recommmended thhat the implementing aacts shouldd stipulate aa phased aapproach by delayingg the reportting of recorrds of transactions in trransportatioon contractss by 6 montths.

text: Responnses on thee Consultaation paperr

text: Recommendationns

text: Recommendationn on recorrds of trannsactions iin transportation cappacity conntracts: Thee Agency maintains its positionn expressed in its reccommendattions from 23 Octoberr 2012. Thee implemeenting acts should stippulate a phhased approoach for traansportationn capacity ccontracts by delayingg the reportting of recorrds of transactions in trransportatioon capacity contracts bby 6 monthss, unless energy coommodity aand transpoortation caapacity are in fact obtained in one singlee transacttion. The Agency believes thaat the repporting conntent of mmarket trannsactions oof transportation capaacity contraacts, includinng market ccoupling contracts listeed by powerr exchanges which mmake the avvailable trannsmission ccapacity bettween two mmarket areaas tradeablee in the formm of Phyysical Transmission RRights (“PTTR“), shouuld be maade accordding to the Agency’s recommmendations from 23 OOctober 2012, on the basis of Annnexes II.1, II.2 and II.3 of thesee recommmendations with additional fieldss reflecting the specifficities of ttransportation capacity contractts on whicch the Ageency has consulted during its ppublic consuultation. Thhe reportingg content of primary market traansactions bby TSOs, oor third parties acting oon their behhalf, also on behalf of the othher markett participannts, could, however, be limitedd to the rreporting oof disaggreegated trannsparency iinformation according to Regulations (EC) NNo 714/20009 and (ECC) No 715//2009, incluuding relevaant guidelinees and netwwork codes.

text: As exprressed in thhe recommeendations frrom 23 Octoober 2012, the recordss of transacctions shouldd include lifecycle information on the prre- and poost-trade sttages of a transaction, includingg information on the physical seettlement of the contracct. This alsoo applies to transportattion capacity contractts. In particcular, for thhe purposee of monitoring the immpact of maarket coupling for dayyahead aand intradaay markets, the Agenccy considerrs it necesssary to collect informaation on Neet

text: Transfeer Capacity (NTC), Avaailable Trannsfer Capaccity (ATC), and, followwing the swwitch to flowwbased mmarket coupling, Available Crosss Zonal Cappacity for day-ahead oor intraday markets, as well as informationn on the nominations oof market cooupling conntracts by ceentral counterparties too TSOs oon the correesponding bborders of tthe contractts. The impplementing acts shouldd enable thee Agency to collect ssuch informaation accorrding to Artiicle 8 of REEMIT.

text: Explanaatory text

text: The bilaateral consuultations didd not indicatte any reason why the Agency shhould modifyy its position expresssed in its reecommendaations from 23 Octobeer 2012. Thhe Agency therefore mmaintains itts positionn expressedd therein.

text: The addditional fieldds to be addded in Annnexes II.1, II.2 and II.33 of the recoommendatioons from 23 Octoberr 2012 as aa new sectioon “Additionnal data forr transportattion capacitty contractss” before thee section “Lifecycle information”” are the following (nummbering to bbe adjusted accordinglyy):

text: Additionaal information for capacity ccontracts ffor the transportaation of eleectricity or natural gaas

text: 1. Transporrtation typee Identifiees the transsportation tyype of the ccontract.

text: 2. Originating Market Identifiees the originnating markket area conncerned.

text: 3. Destinatiion Market Identifiees the markket area where the deliivery will take plaace.

text: 4. Intrasysttem(s) Where applicable the system(s) used to transport betweeen the sellerr’s and buyeer’s system.

text: 5. Interconnnection Pooint(s) Where applicable identificatioon of the border(s), border point(s) or entry/exit point(s) of a transpoortation contract.

text: 4 Conclusionss and takinng the way forward

text: This doocument coontains the Agency’s Recommenndations onn the Records of trannsactions on balancinng market contracts aand transpoortation conntracts under REMIT which it coonsiders aree necessaary effectiveely and efficciently to moonitor wholeesale energgy markets uunder the RRegulation.

text: The Ageency considders these recommenddations as ccomplemennting its recoommendations from 233 Octoberr 2012 and a sound baasis for the developmeent of the RREMIT records of transsactions andd implemeenting acts..

text: The Aggency is aavailable too support the Commmission serrvices and to providee additionaal recommmendations in the coursse of the fuurther development of tthe REMIT implementiing acts andd will conttinue the invvolvement oof stakeholdders on issuues related to the impleementation of REMIT.

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identifier: ACER Recommendation No 07/2013

title: ACER Recommendation 07-2013 Regarding the Cross-Border Cost Allocation Requests Submitted in the Framework of the First Union List of Electricity and Gas Projects of Common Interest

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title: ACER Recommendation 08-2013 on the Network Code on Load-Frequency Control and Reserves

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identifier: ACER Recommendation No 09/2013

title: ACER Recommendation 09-2013 on the Network Code on Operational Security

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title: ACER Recommendation 10-2013 on the Network Code on Operational Planning and Scheduling

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identifier: ACER Opinion No 01/2011

title: ACER Opinion 01-2011 on the ENTSO-E Statutes Rules of Procedure and List of Members

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title: ACER Opinion 01-2012 on ENTSOG's 2012 Annual Work Programme

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identifier: ACER Opinion No 01/2013

title: ACER Opinion 01-2013 on the Network Code on Gas Balancing of Transmission Networks

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identifier: ACER Opinion No 01/2014

title: ACER Opinion 01-2014 on the ENTSO-E Guideline for Cost-Benefit Analysis of Grid Development Projects

text: Publishing date: 31/01/2014

text: Document title:

text: We appreciate your feedback

text: Publishing date: 31/01/2014

text: Document title:

text: We appreciate your feedback


identifier: ACER Opinion No 01/2015

title: ACER Opinion 01-2015 on the ENTSO-E Draft Ten-Year Network Development Plan 2014

text: Publishing date: 04/02/2015

text: Document title:

text: We appreciate your feedback

text: Publishing date: 04/02/2015

text: Document title:

text: We appreciate your feedback


identifier: ACER Opinion No 01/2016

title: ACER Opinion 01-2016 on ENTSO-E Winter Outlook Report 2015-16 and Summer Review 2015

text: Publishing date: 12/02/2016 Document title: on ENTSO-E WOR 2015-16 and SR 2015

text: We appreciate your feedback

text: We appreciate your feedback


identifier: ACER Opinion No 01/2017

title: ACER Opinion 01-2017 on the ENTSO-E Draft TYNDP 2016


identifier: ACER Opinion No 01/2018

title: ACER Opinion 01-2018 on ENTSO-E Winter Outlook Report 2017-18 and Summer Review 2017


identifier: ACER Opinion No 01/2019

title: ACER Opinion 01-2019 on Draft ENTSO-E Annual Work Programme 2019


text: OJ L158, 14.6.2019, p. 22. Page 1 of 3

text: Opinion No 01/2020

text: Opinion No 01/2020

identifier: ACER Opinion No 01/2020

title: ACER Opinion 01-2020 on the Draft ENTSO-E Annual Work Programme 2020

text: PUBLIC

text: OPINION No 01/2020 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 7 February 2020 on the draft ENTSO-E Annual Work Programme 2020

text: THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to

text: Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators , and, in particular,

text: Article 4(3)

text: (b) thereof, Having regard to

text: Regulation (EU) 2019/943

text: of the European Parliament and of the Council of 5 June 2019 on the internal market for electricity, in particular,

text: Article 32(2)

text: thereof, Having regard to the favourable opinion of the Board of Regulators of 22 January 2020 delivered pursuant to

text: Article 24(2) of Regulation (EU) 2019/942

text: , Whereas:

text: 1. INTRODUCTION (1)

text: Article 32(2) of Regulation (EU) 2019/943

text: requires the European Network of Transmission System Operators for Electricity (‘ENTSO-E’) to submit a draft annual work programme, including the information regarding the consultation process, to ACER for an opinion. (2) On 9 December 2019, ENTSO-E submitted to ACER for its opinion the draft ENTSO- E Annual Work Programme 2020 (the ‘Work Programme 2020’), which covers the period from September 2019 to December 2020.

text: 2. SUMMARY OF ENTSO-E ANNUAL WORK PROGRAMME 2020 (3) The Work Programme 2020 presents the activities which ENTSO-E plans for 2020 along two main areas. Chapter 1 describes the work for the implementation of network codes and guidelines and include a special focus on the implementation of the deliverables under the Clean Energy Package (CEP) and on the network interface: transmission and distribution, transmission system operators and distribution system operators (TSO-DSO). Chapter 2 provides an overview of future power system development and transparency with a special focus on infrastructure development, resource adequacy, regional development and data exchange.

text: 3. ASSESSMENT OF THE WORK PROGRAMME 2020 Legal framework (4) According to Article 30(4) of the

text: Regulation (EU) 2019/943

text: , the annual work programme has to contain a list and description of the network codes to be prepared, a plan on coordination of operation of the network, and research and development activities, to be realised in that year, and an indicative calendar. (5) Article 31(1) of the

text: Regulation (EU) 2019/943

text: requires ENTSO-E, while preparing the annual work programme, to conduct an extensive consultation process, at an early stage and in an open and transparent manner, involving all relevant stakeholders and, in particular, the organisations representing such stakeholders, in accordance with the rules of procedure referred to in

text: Article 29

text: . (6) According to

text: Article 4(3)

text: (b) of

text: Regulation (EU) 2019/942

text: , in its opinion on the draft ENTSO-E annual work programme, ACER has to take into account the objectives of non-discrimination, effective competition and the efficient and secure functioning of the internal market for electricity. (7) According to

text: Article 4(5) of Regulation (EU) 2019/942

text: , ACER has to assess the ENTSO-E draft annual work programme also with regard to a sufficient level of crossborder interconnection open to third-party access and the compliance with the relevant provisions of

text: Regulation (EU) 2019/943

text: and

text: Directive (EU) 2019/944

text: . Compliance with

text: Regulation (EU) 2019/942

text: and

text: Regulation (EU) 2019/943

text: (8) The focus of the Work Programme 2020 is on the implementation of network codes and of the deliverables of the Clean Energy Package. (9) The Work Programme 2020 contains a list and a description of the network codes that have been prepared and are now to be implemented, observations with regard to the envisaged coordination of network operation, references to research and development activities to be realised, and indicative calendars for deliverables. (10) ENTSO-E carried out a public consultation on a draft version of its work programme 2020 from 17 October 2019 to 15 November 2019.

text: 4. ASSESSMENT OF ENTSO-E ANNUAL WORK PROGRAMME 2020 (11) ACER regrets ENTSO-E’s unwillingness to play a more active coordination role in the Bidding Zone review process.

text: 5. CONCLUSION (12) ACER considers the informal draft of the ENTSO-E Annual Work Programme for 2020 in line with the requirements of Articles 30(4) and 31(1) of the

text: Regulation (EU) 2019/943

text: . ACER did not identify such elements in the Work Programme 2020 that would suggest that the Work Programme 2020 has negative effects on nondiscrimination, effective competition, efficient and secure functioning of the electricity market, or the sufficient level of cross-border interconnection open to third party access. ACER did also not identify any incompliance with relevant provisions of

text: Regulation (EU) 2019/943

text: and

text: Directive (EU) 2019/944

text: . HAS ADOPTED THIS OPINION: 1. ACER considers the Work Programme 2020 in line with the requirements of Articles

text: and

text: of Regulation (EU) 2019/943 and with the objectives and requirements of

text: Articles 4(3)

text: (b) and 4(5) of

text: Regulation (EU) 2019/942

text: . 2. This Opinion is addressed to the European Network of Transmission System Operators for Electricity. Done at Ljubljana, on 7 February 2020. - SIGNED - Fоr the Agency The Director C. ZINGLERSEN


text: Opinion No 01/2021

text: ENTSO-E, “Winter Outlook 2020-2021 & Summer Review 2020”, 30 November 2020. https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/201130_Winter%20Outlook%202020-2021_Report.pdf. ACER Decision No. 08/2020 of 6 March 2020 on the methodology for short-term and seasonal adequacy assessments is available on: https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Individual%20decisions/ACER%20Decision% 2008-2020%20on%20the%20shortterm%20and%20seasonal%20adequacy%20assessments%20methodology_RPR8.pdf. The accompanying annexes to the decision are available on: https://www.acer.europa.eu/Official_documents/Acts_of_the_Agency/Pages/Annexes-to-the-DECISION-OF- THE-AGENCY-FOR-THE-COOPERATION-OF-ENERGY-REGULATORS-No-08-2020.aspx. 3 ENTSO-E, “Winter Outlook 2020-2021 & Summer Review 2020 – Country Comments”, 30 November 2020. https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/201130_Winter%20Outlook%202020-2021_country%20comments.pdf. 4 https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/data/Supply_WOR_20-21.xlsx. 5 https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/data/Transfer%20Capacities_WO_20-21.xlsx

text: Opinion No 01/2021

text: https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/data/PECD_2020_edition_2020_Offshore.zip. 7 https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/data/PECD_2020_edition_2020_Onshore.zip. 8 https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/data/PECD_2020_edition_2020_PV.zip. 9 https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/data/Hydro_WOR%202020-2021.zip. 10 https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/data/Demand_WOR_2020_2021.xlsx. 11 https://eepublicdownloads.entsoe.eu/clean-documents/sdcdocuments/seasonal/WOR2020/data/Availability_ClimateDependentOtherNonRES_WOR%202020-2021.xlsx.

text: Opinion No 01/2021

text: Table 1: Assessment of Winter Outlook 2020-2021 against high-level requirements of STSAA methodology

text: Opinion No 01/2021

text: Equivalent deadlines apply for the Summer Outlook assessments. The STSAA methodology defines the period between 1 June and 30 September as the core period for the Summer Outlook, extendable between 1 May and 31 October if specific and relevant risks are expected. The deadline for publication is the first day of the concerned assessment period, like for the Winter Outlook assessment. The RPR Regulation sets 1 June as the deadline for the Summer Outlook assessment.

text: Opinion No 01/2021

text: For example, according to the Country Comments Report, the non-market measures include strategic reserves that are available in Germany, Finland and Sweden and other types of out of market supply- and demand-side reserves that can be used for security of supply purposes. Similar to our comments on the Summer Outlook 2020, this report does not specify the kind of non-market measures in Malta. 14 For example, it is not clear whether the assessment has considered measures such as emergency assistance on interconnectors, voltage reduction and interruptibility schemes that could be considered non-market measures.

text: Opinion No 01/2021

text: Opinion No 01/2021

text: Opinion No 01/2021 2. This Opinion is addressed to the European Network of Transmission System Operators for Electricity. Done at Ljubljana, on 9 March 2021.

identifier: ACER Opinion No 01/2021

title: ACER Opinion 01-2021 on ENTSO-E Winter Outlook 2020-21 and Summer Review 2020

text: PUBLIC

text: OPINION No 01/2021 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 9 March 2021 ON THE ENTSO-E WINTER OUTLOOK 2020-2021 AND SUMMER REVIEW 2020

text: THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to

text: Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators, and, in particular,

text: Article 4(3)

text: (b) thereof, Having regard to

text: Regulation (EU) 2019/943

text: of the European Parliament and of the Council of 5 June 2019 on the internal market for electricity and, in particular,

text: Articles 30(1)

text: (m) and 32(2) thereof, Having regard to

text: Regulation (EU) 2019/941

text: of the European Parliament and of the Council of 5 June 2019 on risk-preparedness in the electricity sector and repealing Directive

text: and, in particular,

text: Article 9(2)

text: thereof, Having regard to the favourable opinion of the Board of Regulators of 25 February 2021, delivered pursuant to

text: Article 22(5)

text: (a) of

text: Regulation (EU) 2019/942

text: , Whereas:

text: 1. INTRODUCTION

text: (1) On 30 November 2020, the European Network of Transmission System Operators for Electricity (‘ENTSO-E’) published its annual winter adequacy outlook report for 2020-2021 (‘Winter Outlook 2020-2021’) together with a review of the main events occurred during summer 2020 (‘Summer Review 2020’). On 26 January 2021, ENTSO-E submitted the Winter Outlook 2020-2021 to ACER for its opinion, according to Articles

text: and

text: of Regulation (EU) 2019/943 (hereafter the

text: ‘Electricity Regulation’). The document is entitled “Winter Outlook 2020-2021 - Summer Review 2020” (the ‘Report’).

text: (2) Pursuant to

text: Article 4(3)

text: (b) of

text: Regulation (EU) 2019/942

text: (hereafter the ‘ACER Regulation’) and

text: Article 30(1)

text: (m) of Electricity Regulation, ACER may provide an opinion to ENTSO-E on their seasonal adequacy assessments, taking into account the objectives of non-discrimination, effective competition, and efficient and secure functioning of the internal market for electricity. In view of these objectives, and to steer the implementation of ACER Decision No. 08/2020 on the methodology for short-term and seasonal adequacy assessments (hereafter the ‘STSAA methodology’) towards the desired outcomes, ACER considers it appropriate to issue this opinion (the ‘Opinion’) on the submitted Report.

text: (3) The Report is accompanied by a document including country-specific comments on the expected security of supply situation in their system during winter 2020-2021 and analyses of events or operational challenges occurred during summer 2020. The document is entitled “Winter Outlook 2020-2021 – Summer Review 2020: Country Comments” (the ‘Country Comments Report’).

text: (4) Moreover, the Report is complemented by data used for the Winter Outlook analysis:

text: a spreadsheet file providing relevant input information with respect to supply data ; a spreadsheet file providing the expected transfer capacities between the studied zones ;

text: a spreadsheet file providing wind offshore generation time series from the ENTSO-E Pan-European Climate Database (‘PECD’) ; a spreadsheet file providing wind onshore generation time series from the ENTSO-E PECD ; a spreadsheet file providing solar generation time series from the ENTSO-E PECD ; a folder containing spreadsheet files per country providing relevant input with respect to hydroelectric power modelling ; a spreadsheet file providing projected electricity demand data for the concerned assessment period based on realised demand in different historical years ; and a spreadsheet file providing availability information for climate-dependent resources other than renewable sources .

text: 2. ASSESSMENT OF THE WINTER OUTLOOK 2020-2021 AND SUMMER REVIEW 2019-2020

text: Legal Framework

text: (5) Pursuant to

text: Article 30

text: (l)(m) and Article 32(2) of Electricity Regulation, ENTSO-E shall adopt seasonal adequacy assessments and submit them to ACER for an opinion. Seasonal adequacy assessments include a winter and a summer adequacy assessment, as specified in

text: Article 9(2) of Regulation (EU) 2019/941

text: (hereafter the ‘Risk Preparedness Regulation’).

text: (6) In providing its opinion, ACER takes into account the objectives of nondiscrimination, effective competition, and efficient and secure functioning of the internal market for electricity, as required by

text: Article 4(3)

text: (b) of ACER Regulation.

text: Article 30(1)

text: (m) and Article 32(2) of Electricity Regulation do not explicitly require ENTSO-E to adopt summer and winter reviews and submit to ACER for an opinion. However, such reviews are of utmost relevance for the preparation of future seasonal adequacy assessments, provide lessons learnt from the past and, equally, constitute a

text: long-standing practice of ENTSO-E. Therefore, in this Opinion, ACER deems it appropriate to consider not only the Winter Outlook 2020-2021, but also the Summer Review 2020.

text: Assessment against high-level requirements of STSAA methodology

text: (8) ACER observes that the Winter Outlook 2020-2021 assessment is increasingly in line with the STSAA methodology and fully or partially meets the high-level requirements laid down in Article 3 of the methodology. At the same time, ACER considers there is scope for improvement for meeting all methodological requirements and enhancing the usefulness and clarity of the analysis and report. Table 1 presents ACER’s assessment of the Winter Outlook 2020-2021 with regards to the high-level requirements of the STSAA methodology. The remainder of this section describes these requirements in more detail.

text: 2.2.1. Probabilistic assessment

text: (9) The Winter Outlook 2020-2021, like the Summer Outlook 2020, uses a probabilistic methodology to assess the risks for the season ahead, consistently with the STSAA methodology. This is in contrast to past Winter Outlooks that used a deterministic approach, and represents a significant improvement of the seasonal adequacy assessments, as introduced by the STSAA methodology.

text: 2.2.2. Analysis timeframe and timing of publication

text: (10) The Winter Outlook analysis covers the core period between 1 December and 31 March, pursuant to Article 3(4) of the STSAA methodology. In compliance with Article 3(4) and 3(6) of the methodology, the analysis extends to November, due to higher than normal planned maintenance.

text: (11) ENTSO-E published the Report on 30 November 2020. The STSAA methodology sets the first day of the concerned seasonal assessment, 2 November in this case, as

text: the deadline for publication. Even though the publication’s timing is not in line with the STSAA methodology, ACER recognises that ENTSO-E engaged closely with the Electricity Coordination Group to communicate the provisional results of the analysis in the run-up to the publication. This enabled Member States and Transmission System Operators (‘TSOs’) to consider mitigating measures for any identified adequacy risks. ACER also observes that the analysis for the Winter Outlook 2020- 2021 took place in a context of heightened challenges and uncertainties due to the COVID-19 pandemic. Finally, ACER notes that the Report’s publication was in time for the deadline set in Article 9(2) of Risk Preparedness Regulation, determined as 1 December.

text: (12) ACER observes that meeting both aforementioned deadlines is the absolute minimum legal requirement. Publishing the seasonal assessment earlier than those would be beneficial, as it would allow market participants sufficient time to respond to any risks, especially for the initial period of the season under examination . ACER recognises that publishing earlier is a balancing exercise between using as accurate data as possible and providing timely information to the market and other participants. ACER encourages ENTSO-E to strive to publish in advance of these deadlines (e.g. few weeks to a month) to enhance the usefulness of the analysis.

text: 2.2.3. Risk indicators

text: (13) Pursuant to Article 3(7) of the STSAA methodology, seasonal adequacy assessments shall be based on any relevant metrics, including: Loss of Load Expectation (‘LOLE’), Loss of Load Probability (‘LOLP’) and Expected Energy Non-Served (‘EENS’). Like the Summer Outlook 2020, the Report does not include the LOLE metric. ACER observes that the calculation of LOLE (in a given modelled zone during a given time period) would allow to better assess the level of security of supply in the analysed area, as a complement to the LOLP and EENS. LOLE is one of the most recognised risk metrics across adequacy assessment studies. In addition, reliability standards, providing a reference point for the security of supply outlook, are commonly defined in LOLE terms.

text: 2.2.4. Sensitivity analysis with non-market measures

text: (14) Pursuant to

text: Article 3(8)

text: (e) of the STSAA methodology, seasonal adequacy assessments shall include a sensitivity analysis to assess possible measures to prevent

text: or mitigate adequacy risks, in particular with respect to the use of non-market measures to mitigate an electricity crisis.

text: (15) The Winter Outlook 2020-2021 report contains such a sensitivity. The Report usefully describes the non-market measures considered in the sensitivity and their impact on risk indicators. It places special focus on the modelled zones with identified adequacy risks, assuming normal market operations only.

text: (16) ACER observes that the list of non-market measures considered appears not exhaustive however. The analysis seems to focus on strategic (or similar) reserves only , while no other measures are analysed. There is a general lack of information about the type of measures examined for consideration in this analysis . In the future, ACER expects the analysis to consider all non-market measures, as identified and developed in the risk preparedness plans of Member States, pursuant to Chapter III of Risk Preparedness Regulation. ACER observes that a proper characterisation of the resources modelled in seasonal assessments ensures a better understanding from relevant stakeholders.

text: Areas for improvement and assessment of specific issues of Winter Outlook 2020-

text: 2021 and Summer Review 2020

text: (17) Overall, the Report represents an improvement on the Summer Outlook 2020. It describes the potential adequacy risks and mitigation actions in more detail and with enriched clarity. At the same time, ACER observes there is still significant scope for further improvement of the analysis and report; below, ACER presents a nonexhaustive list of areas for consideration for the improvement of future seasonal adequacy assessments.

text: (18) ENTSO-E undertook the analysis for the Winter Outlook 2020-2021 in an environment of significant uncertainty due to the COVID-19 pandemic. The analysis recognises so and includes a dedicated section on the uncertainties related to the evolution of the pandemic. The results of the analysis refer to a scenario, drawn in August-September 2020, assuming no second wave of the pandemic. This assumption was already invalidated before the beginning of the core period concerning the assessment. In this context, ACER considers that a more detailed analysis of the uncertainties related to the pandemic, complemented with sensitivity analyses, would provide a more complete picture of the adequacy risks for the season ahead.

text: (19) The seasonal adequacy assessment would also benefit from flow-based modelling for the relevant capacity calculation regions, as recognised in the Report. Flow-based modelling would enable a more accurate assessment of the transfer capacities between modelled zones, and therefore enhance the quality of the results.

text: (20) In terms of clarity of the Report, ACER observes the following:

text: In the case of generation, the Report contains information about the evolution of thermal capacity in winter 2020-2021, although it is not clear what the reference season or year for these changes is. To further aid understanding of these changes, the Report could also contain information about the relative changes in installed thermal capacity. Moreover, the Report lacks equivalent information about the evolution of variable renewables in the system, as well as demand side response and storage. Given the increasing significance of these types of resources for security of supply, ACER believes that a more detailed description of their projected development (e.g. absolute and relative changes year-on-year) would increase understanding of the assessment. In particular, ACER notes that the Report and accompanying data files do not contain any information about storage, with the exception of pumpedstorage hydro. There is also scope to further clarify the definition of different availability parameters and enhance the Report’s readability. Particularly, the definition of “further availability limitations” could be further detailed with specific definitions for different types of resources and concrete examples. ACER observes that the Report does not contain any information about flows with non-explicitly modelled systems. ENTSO-E has clarified that the assessment considers all relevant such systems. ACER urges ENTSO-E to report the assessment’s assumptions regarding non-explicitly modelled systems in future seasonal assessments. The Report does not offer any information about how ENTSO-E and TSOs have derived the assessment’s main underlying assumptions. It states that: “To ensure the highest quality of data used in assessments, they are prepared by experts working within dedicated teams”. However, the Report provides no information about the work undertaken by these expert groups. For future seasonal adequacy assessments, ACER suggests that ENTSO-E develops a methodological appendix that summarises the main assumptions (e.g. data used for estimating the unplanned outages for thermal generation). Finally, ACER is of the opinion that the Report would benefit from a summary sheet of the studied scenario and sensitivities. This sheet could contain key assumptions underlying the scenario, such as peak demand and installed capacities per resource type, and key differences for the considered sensitivities with regards to the main scenario. Such an addition would enable the reader to quickly obtain an overview of the studied scenario and sensitivities.

text: (21) In relation to the Summer 2020 Review, ACER notes the following:

text: The Report briefly describes the most significant challenges and events that occurred during the summer period. These contain challenges with voltage regulation and a particularly tight situation on 15 September, which led several TSOs to issue an Alert State in the European Awareness System. The Report offers limited information about the measures applied to overcome these situations. ACER considers it would benefit from a more detailed description of the measures and their impact on the market. For example, it would be useful to detail what was the impact on market prices and how market participants responded to the alerts in the European Awareness System. While TSOs have heightened responsibility for addressing adequacy risks, at and close to real-time, the market may also alleviate these risks. ACER observes that, according to the Report, TSOs had to “deplete all real-time measures” in order to address the challenging situation on 15 September. However, the Report does not describe how close TSOs were from implementing load shedding across the region facing system stress, or the scope of these “realtime measures”. Once again, ACER recommends that ENTSO-E describes in more detail this type of events in future reports.

text: 3. CONCLUSION

text: (22) ACER did not identify any elements in the Report that would suggest that the Winter Outlook 2020-2021 and the Summer Review 2020 have negative effects on nondiscrimination, effective competition, and efficient and secure functioning of the internal market of electricity.

text: (23) In line with the assessment provided in Section 2 above and with the STSAA methodology, ACER found that:

text: The Winter Outlook 2020-2021 represents an improvement on the Summer Outlook 2020 and past Winter Outlooks, increasingly in line with the STSAA methodology. Nevertheless, the analysis is not fully in line with the STSAA methodology. Article 10(2) of the STSAA methodology stipulates the full implementation of the methodology by 6 March 2021, at the latest. ACER thus urges ENTSO-E to fully comply with the methodology as of the next seasonal assessment, the Summer Outlook 2021, expected by 1 June 2021. Moreover, there is still significant scope to enhance the quality and completeness of the analysis, and usefulness and clarity of the report. ACER has offered a number of suggestions to this effect in the Opinion,

text: HAS ADOPTED THIS OPINION:

text: 1. ACER considers that the Winter Outlook 2020-2021 and the Summer Review 2020 are in line with the requirements of

text: Article 4(3)

text: (b) of ACER Regulation.

text: - SIGNED -

text: Fоr the Agency The Director

text: C. ZINGLERSEN