DSO Connection Queue Reform — The Swedish Policy Response

Sweden has a connection queue problem. It has a constellation of regulatory responses — some already in force, some proposed, some still being designed. The responses are coherent in direction but scattered across instruments, timelines, and actors. This synthesis maps what Sweden is actually doing about grid connection queues and asks whether the pieces add up to a solution.

The problem: three structural causes

The EU grids package guidance (C/2025/8473, December 2025) identifies three structural causes of connection queues, all present in Sweden:

1. Phantom congestion from luftbokning (air booking): DSOs historically plan from contracted power (abonnerad effekt) rather than actual physical load (faktisk belastning). A customer who contracts 100 kW but consistently draws 60 kW ties up 40 kW as a phantom reservation. At scale — across hundreds of thousands of connections — this creates grid congestion that does not physically exist. Ei estimates significant portions of apparent Swedish grid constraint are phantom. (Source - Ei R2024-14 Outnyttjad Kapacitet (2024))

2. Speculative and non-progressing applications: Connection requests are filed before projects are investmentready, locking capacity that may never be used. In Slovakia, an estimated 50% of reserved grid capacity is blocked by speculative applications. Sweden’s connection queue at Svk and regional DSO levels has similar dynamics, particularly for large-scale production (wind, data centers). First-come-first-served queue logic rewards early filing over project readiness.

3. Reactive grid planning: Grid construction takes 4–10 years; connection lead times are 2–3 years. A DSO that waits for formal applications before investing cannot meet its statutory two-year connection obligation as demand materializes. Reactive planning creates a structural lag that queues cannot resolve.

Layer 1 — Faktisk belastning and capacity calculation reform

Ei‘s response to phantom congestion is the faktisk belastning doctrine, reaffirmed in Ei R2024:14:

DSOs must calculate available grid capacity using the actual physical load of existing customers, including statistical diversity effects (lastdiversifieringsfaktorer) — not the sum of their contracted capacities.

Operationally: use AMI smart meter data (hourly); apply diversity factors (a group of customers never simultaneously reaches contracted maximum); update periodically; document methodology for Ei oversight.

The legal clarification that makes this work: Abonnerad effekt under EIFS 2022:1 is a cost-allocation criterion — how grid costs are divided among customers — not a right to specific physical grid capacity. A customer who has contracted 100 kW cannot legally claim that the DSO must reserve exactly 100 kW of grid capacity for them at all times. This distinction separates the tariff question (how costs are allocated) from the planning question (how much capacity actually exists).

The asymmetric constraint: DSOs must use faktisk belastning for capacity calculations but cannot unilaterally reduce a customer’s contracted capacity based on observed usage. Abonnerad effekt is a contractual right requiring customer consent or a tariff redesign process. This creates a one-way unlocking: DSOs can see more available capacity than contracted sums suggest, but cannot force customer contracts to reflect reality.

Layer 2 — Ei ställningstaganden on connection obligations

In 2025, Ei published four ställningstaganden (formal position statements) that collectively define a more demanding connection obligation than DSOs had previously faced. (Source - Ei Ställningstaganden Anslutningsprocessen (Ei2025-02 till 05))

Flexibility as prerequisite for connection delay (Ei2025:02)

The most significant enforcement signal: when a customer appeals to Ei that their connection time is unreasonably long (4 kap. 13 § ellagen), Ei will verify that the DSO investigated whether flexible resources could free up grid capacity before citing capacity shortage. This converts the flexibility assessment in 4 kap. 2 § ellagen from a consideration into an enforceable prerequisite. A DSO that delays a connection without demonstrating flexibility was assessed and found insufficient cannot rely on capacity shortage as a defence.

Ei also endorsed mognadsgrad (project maturity assessment) as a queue management tool — the methodology developed by Svk and Energiföretagen that grades applications by permitting, financing, and technical readiness. DSOs using mognadsgrad must ensure non-discrimination.

Additional positions: DSOs should disclose standardised connection routines for all installation types (not just production/storage as currently required by law); connection timelines should be provided for all facility types immediately.

Anticipatory investment as legal obligation (Ei2025:03)

Proactive grid building is not discretionary — it is required by the combination of:

• 3 kap. 1 § ellagen: operate the grid efficiently, safely, reliably
• 4 kap. 1 § ellagen: connection obligation
• 4 kap. 5 § ellagen: connection within two years maximum

A DSO that waits for formal applications before investing will systematically fail the two-year obligation as demand arrives. The DNDP is the legal vehicle for translating this obligation into concrete anticipatory investments.

Capital base conditionality and the safety valve: Anticipatory assets enter the capital base only when they enter service (Förordning 2018:1520). This creates tension: build early, but only recover costs when in service. The escape valve is 5 kap. 7 § ellagen — Ei may allow capital base inclusion before full utilization where circumstances justify. This is the cost-recovery safety net for genuinely proactive investments.

External financing of grid components (Ei2025:04)

No regulatory barrier prevents a connecting customer from financing, or pre-purchasing on behalf of, grid components needed for an extension — even before a connection agreement is signed. During long equipment lead times (transformers, switchgear: up to 2032 for some components per EU grids package data), customers can pre-order to shorten the build phase. Assets enter the capital base at commissioning with the correct rådighet indicator (Ägd/Hyrd/partial).

Referral rules (Ei2025:05)

Svenska kraftnät‘s transmission grid can become obligated to connect a customer who bypassed the regional grid entirely (4 kap. 1 § connection obligation). Svk cannot automatically redirect such applicants. Referral to a lower grid level is permitted (4 kap. 2 §) but requires special reasons (inefficiency, safety risk). Ei recommends — but cannot require — applicants to apply first to the lowest suitable level.

Layer 3 — Svk’s anvisningssystem proposal

In April 2026, Svenska kraftnät submitted a government assignment report proposing structural reforms to TSO-level connection allocation. (Source - Svk Anslutningsprocessen Rapport (2026))

Kapacitetszoner and intressentpooler — replacing queue logic

The core proposal: an anvisningssystem (allocation system) with kapacitetszoner (capacity zones) for specific customer categories, extending the existing offshore wind allocation model to land-based connections. A kapacitetszon defines:

• Reserved capacity around one or more connection points
• A kapacitetskarta showing available capacity at current, 5-year, and 10-year horizons
• Intressentpooler through which competing projects advance based on tillståndsmässig mognad (permitting maturity) — not arrival order

This directly implements the EU guidance’s “first-ready, first-served” recommendation. For categories where permits are insufficient as criteria (e.g., data centers), supplementary binding commitments serve as selection criteria. Svk explicitly rejects auctions — they would disadvantage smaller actors and create secondary capacity markets.

Locational signals: the anvisningssystem generates signals guiding specific customer categories toward connection points that are systemically beneficial — near generation surplus, where local flexibility can reduce transmission needs, or where combined solar+wind capacity is under-utilized due to over-reservation.

Coordination improvements

• Linked applications (matchning): production and consumption applicants filing jointly share capacity costs and reduce grid expansion needs. Svk will develop affärsmatchning principles
• Mandatory tripartite dialogue: Svk, regional grid company, and large customer must engage in three-way dialogue for major applications — clarifying prerequisites and alternatives before formal applications are submitted
• Ansökningsplattform: Svk reversed its 2024 opposition and will investigate a central platform for information exchange about connection queue applicants to facilitate matching
• Actual utilization profiles: Svk and regional DSOs are developing capacity allocation principles based on actual load profiles, not contracted maximums — directly addressing the phantom congestion issue at TSO level

Fossil-free production requirements

Svk proposes investigating whether large-scale new electricity users should be required to contribute new fossil-free production as a connection condition (via PPA or equivalent). This is the most structurally ambitious element of the proposal and the one with the most unresolved legal and economic questions — Svk explicitly notes it has not completed feasibility analysis.

Layer 4 — EU regulatory instruments now entering Swedish law

Art. 6a — Flexible connection framework

Directive 2024/1711 made Art. 6a mandatory for all member states: DSOs may (and must have the framework to) offer flexible connection agreements in capacity-constrained areas, where customers accept curtailable connections in exchange for faster or cheaper access. Prop. 2025/26:16 (in force 1 January 2026) tasked Ei with developing the framework — certification criteria for effektregleringssystem, the FCA methodology, technical requirements. Deadline: 17 July 2026. As of May 2026, no published framework.

Art. 6a is the regulatory mechanism that resolves the legal tension in Villkorade Avtal: under current law, conditional connections are a contractual workaround lacking clear statutory basis and with disputed scope. Art. 6a provides that foundation. Commission Recommendation C(2026)2850 further specifies that energy communities are eligible for Art. 6a flexible connections. (Source - Prop. 2025-26-16 Forbattrad utformning av EUs elmarknad (2025))

Art. 31.3 — Quarterly capacity publication

Directive 2024/1711 also adds Art. 31.3: DSOs must publicly disclose available capacity for new connections within their area with high spatial resolution, updated at minimum quarterly. Disclosure must include: capacity under pending applications; and — critically — availability of flexible connections in congested areas. This makes Art. 6a flexible connection opportunities machine-readable and public. Connection applicants must receive progress updates within 3 months of application and quarterly thereafter.

This is the transparency layer that makes the capacity calculation reform (Layer 1) market-visible. Without it, faktisk belastning liberates hidden capacity only for DSOs and those who ask directly. With it, any applicant can see where flexible connections are available before filing. Requires Ei föreskrifter to implement; not yet issued.

Empirical baseline — regional and transmission connection times (2023–2024)

Ei PM2026:05 (2026) provides the first systematic supervisory measurement of actual connection lead times at the regional and transmission grid level, covering 2023–2024 completed connections at six regional DSOs plus Svenska kraftnät.

Offer times far exceed two-year presumption

The time to issue a connection offer (from complete application) ranged from 406 days (Ellevio) to 1,620 days (Vattenfall Eldistribution, 130 kV) — all well above the two-year presumptive maximum of the connection obligation itself, let alone the time actually needed to complete the connection.

Completion times — 3 to 8+ years at scale

Share exceeding both legal limit and customer deadline

Svk’s transmission connections are the most severe: 60% exceeded both the two-year limit and the customer’s own requested timeline. For nätförstärkning connections at 400 kV, the average completion time approaches or exceeds a decade.

Why alternatives to grid reinforcement were not used

This is the most policy-relevant finding for the Layer 2 ställningstaganden framework. Ei asked each company what non-reinforcement alternatives had been investigated and implemented in cases where capacity constraints caused delays.

The answer across all seven companies: none.

The reported reasons:

• Three companies: facilities were physically too large to connect to existing grid, or no regional grid existed in the area — making market-based solutions (including flexible connections) physically inapplicable
• One company explicitly: the rules around Villkorade Avtal are perceived as unclear, so the company does not apply them to any significant extent
• One company (E.ON Energidistribution, which operates live flex markets at distribution level): noted that flexibility markets and villkorade avtal have significant socioeconomic potential at regional level, but customers show limited willingness to enter villkorade avtal due to curtailment risk; the company is developing alternatives and flexibility markets for earlier connections pending reinforcement
• One company: offers a villkorat avtal or customer-specific cost when a flexibility service meets reliability and availability requirements
• Four companies have no established methodology to evaluate costs and benefits of non-reinforcement alternatives

This directly validates the policy imperative behind Ei2025:02: requiring DSOs to demonstrate that flexibility alternatives were investigated is necessary precisely because they are currently not being investigated. The empirical record shows zero cases at regional/transmission level where alternatives were actually implemented.

Transparency gaps

Three of the seven companies publish no information about their current capacity situation. One was developing capacity publication tools with a planned Q1 2026 go-live. Ei concluded that this information gap affects not just individual customer planning but delivery security and electrification planning more broadly — reinforcing the Art. 31.3 quarterly publication requirement (Layer 4).

How the layers interact

Faktisk belastning (Layer 1) + Art. 31.3 (Layer 4) form a two-sided capacity transparency reform: Layer 1 requires DSOs to calculate capacity correctly; Layer 4 requires them to publish it. Together they address the information asymmetry that drives phantom congestion and steers applicants toward congested areas.

Ei2025:02 (flexibility as prerequisite) + Ei2025:03 (anticipatory investment) + Ei R2024:14 (faktisk belastning) form Ei’s enforcement posture: a DSO facing a connection complaint must demonstrate it (a) calculated available capacity correctly, (b) investigated flexibility as an alternative, and (c) planned proactively rather than reacting to applications.

Svk’s anvisningssystem (Layer 3) + Ei2025:02 mognadsgrad + EU guidance first-ready-first-served converge on the same queue management principle from different levels: TSO-level capacity zones replace first-come-first-served; DSO-level maturity grading filters applications by readiness; EU guidance endorses both.

Art. 6a (Layer 4) + Art. 31.3 (Layer 4) + Svk locational signals (Layer 3) form the demand-steering toolkit: flexible connections in constrained areas provide a faster route for applicants willing to accept curtailability; public capacity maps make constrained vs. unconstrained areas visible; locational signals steer applicants toward areas with headroom.

What is not yet resolved

The reforms address the information and queue management dimensions of the connection problem. They do not resolve the physical constraint dimension: lead times for transformers and cables remain 2–4 years even when capacity is identified and applications are well-managed. The anvisningssystem’s capacity maps and maturity-based allocation can redirect demand toward available capacity, but cannot compress equipment lead times or accelerate permitting for new infrastructure.

Relationship to other wiki pages

• Distribution System Operator — detailed coverage of Ei ställningstaganden, faktisk belastning doctrine, Art. 31.3, and Art. 6a in DSO context
• Villkorade Avtal — Art. 6a is the statutory upgrade for conditional connections
• Anvisningssystem — primary concept page for Svk’s kapacitetszoner proposal
• Congestion Management — queue management and capacity allocation as congestion tools
• Distribution Network Development Plan — the DNDP as the planning vehicle for anticipatory investment (Ei2025:03)
• Flexibility Need Assessment — FNA and DNDP together define the grid-level demand for flexibility, which in turn determines where Art. 6a flexible connections are most needed
• Ei — ställningstaganden series; faktisk belastning doctrine; Art. 6a mandate
• Svenska kraftnät — anvisningssystem proposal; mandatory tripartite dialogue; referral rules