Flexibility Need Assessment
The Flexibility Need Assessment (FNA; Swedish: Flexibilitetsbehovsbedömning or Flexibilitetsbehovsanalys) is a mandatory biennial process requiring TSOs and DSOs to quantify, report, and aggregate their flexibility needs at national level.
EU legal basis
The FNA is mandated by Art. 19e of Regulation (EU) 2019/943, as amended by Regulation (EU) 2024/1747 (Electricity Market Design Reform 2024). Art. 19e requires each member state to conduct an FNA at least every two years, covering at least the next 5–10 years. Key requirements from Art. 19e:
- Responsible body: the regulatory authority or another designated authority/entity (in Sweden: Svenska kraftnät as Designated Entity, under Ei supervision)
- Methodology: ENTSO-E and EU DSO Entity jointly develop the data type/format and analytical methodology; submitted to ACER for approval
- ACER approval deadline: 17 April 2025 (methodology) — met by ACER Decision 05-2025 (published 25 July 2025)
- Report contents: seasonal/daily/hourly flexibility needs; demand response and storage potential; market barriers and mitigation; digitalisation contribution; cross-border flexibility potential
- Submission: to Commission and ACER; published; ACER issues cross-border analysis within 12 months
The methodology established by ACER Decision 05-2025 (the FNAM — FNA Methodology) is secondary EU legislation directly applicable in all member states. This means part of the NC DR framework is already in force, even before the main network code is formally adopted. (Source - Electricity Market Design Reform Regulation (EU 2024-1747))
Definition and purpose
Formal definition (Bilaga I): “Med flexibilitetsbehov avses behov av att ändra eller begränsa kunders inmatning och uttag av el.” — The need to change or limit customers’ electricity injection and withdrawal.
Operationally: the summated maximum average hourly power [MW] that must be available to ensure all grid assets stay within a DSO’s operational transfer limits (operationella överföringsgränser), given projected customer connections in a target year and the expected grid structure for that year. (Source - FNA Bilagor I-V (2025-2026))
The FNA provides a structured, harmonized analysis of how much flexibility — at both system level and network level — is required to:
- Integrate increasing volumes of variable renewable generation
- Maintain operational security as electrification increases demand
- Enable faster customer connections without grid reinforcement bottlenecks
Critically, the FNA is a needs description only. It does not determine who procures flexibility, which mechanisms are used, or how costs are allocated. Those questions belong to Flexibility Market rules, Villkorade Avtal, and the broader Network Code on Demand Response market framework. (Source - FNA Överenskommelse Svenskt genomförande 2026 (2025))
Up-regulation and down-regulation
Down-regulation (nedreglering) — DSO needs to: reduce a customer’s injection, enable greater-than-normal withdrawal, or activate a customer to increase withdrawal. Grid situation: too much generation / too little demand locally.
Up-regulation (uppreglering) — DSO needs to: increase a customer’s injection, reduce allowed withdrawal, or activate a customer to reduce withdrawal. Grid situation: too much demand / too little generation locally.
What counts and what doesn’t
Counts: flexibility for N-1 contingencies where customers remain energized. Does not count: events leading to customer disconnection. Explicitly excluded from FNA 2026: voltage regulation needs (methodology not yet mature); SO GL §182 situations (customers constrained due to balancing market participation — §182 agreement not yet in place).
FNA scope vs DNDP scope
The FNA covers a broader set of flexibility needs than the DNDP (Distribution Network Development Plan):
| DNDP (nätutvecklingsplan) | FNA | |
|---|---|---|
| Scope | Flexibility as alternative to grid investment (villkorade avtal + market procurement) | All needs to change/limit customer injection/withdrawal |
| Purpose | Grid development planning | National flexibility policy and targets |
| Relationship | DNDP need is a subset of FNA need | FNA = DNDP + all other injection/withdrawal constraints |
A DSO reporting only its DNDP-identified flexibility in the FNA is likely underreporting. (Source - FNA Bilagor I-V (2025-2026))
Two dimensions
The FNAM (FNA Methodology) distinguishes two types of flexibility need:
| Dimension | What it covers | Primary actors |
|---|---|---|
| System flexibility | Balancing production and demand across the entire electricity system; frequency management | Svenska kraftnät (TSO), balancing markets |
| Network flexibility | Managing bottlenecks and voltage problems in the transmission and distribution grid | DSOs at all levels, TSO for transmission |
Three system flexibility need types (FNAM Arts. 8–10)
The FNAM breaks system flexibility into three indicators, each derived from ERAA/NRAA economic dispatch:
- RES integration needs (Art. 8): the quantity of flexibility required to reduce renewable curtailment and achieve the member state’s RES target; calculated as the gap between actual curtailment and the RES integration target
- Ramping needs (Art. 9): flexibility to cover expected variation of the residual load (demand minus non-dispatchable generation), assuming perfect forecast — addresses technical constraints not captured in hourly ERAA modelling
- Short-term flexibility needs (Art. 10): flexibility to cover unexpected variations from forecast errors and forced outages; the portion covered by frequency restoration reserve (FRR) capacity is already counted and not double-counted
These three indicators are computed at bidding-zone level, then fine-tuned using network needs data where a materiality threshold is met.
DSO network flexibility needs — qualitative data limitation (FNAM Art. 11)
DSOs must quantify their network flexibility needs as MW and MWh per target year. Critical rule: if a DSO cannot provide quantitative data, it may submit qualitative information instead — but qualitative data cannot be used in the fine-tuning process (Art. 11.3). Fine-tuning only occurs when DSO RES curtailment from network constraints exceeds 10% of system-level RES curtailment (or when prequalification limits exceed 10% of installed capacity). DSOs submitting only qualitative data are therefore excluded from the system-level fine-tuning step in the first FNA cycle.
(Source - ACER Decision 05-2025 FNAM Annex I (2025))
Process and outputs
The FNA feeds into a regulatory cascade with specific deadlines:
DSOs report needs to regionnät/Svk
↓
National FNA report
↓ submitted to ACER + European Commission
↓ deadline: July 2026 (first cycle)
↓
National indicative targets for non-fossil flexibility
↓ deadline: January 2027
↓
ACER EU-wide report + gap analysis
↓ deadline: July 2027
↓
Biennial repetition (FNA 2028, FNA 2030…)
FNA results must feed into national Distribution Network Development Plans (DNDPs / nätutvecklingsplaner) — the same data and methods are used for both. (Source - Flexibilitetsbehov FNA Energiföretagen Sverige (web, 2026))
Swedish reporting structure
Sweden’s implementation uses the standard TSO-DSO hierarchy:
lokalnät (local DSO)
│ reports needs per bilaga III (Excel template)
│ to the regionnät they are connected to
↓
regionnät (regional DSO)
│ aggregates own needs + underlying lokalnät data
↓
Svenska kraftnät
│ compiles national picture, performs TSO-level analysis
↓
ACER + European Commission
Geographic granularity: per elhandelsområde (bidding area; SE1–SE4). Data aggregated to highest voltage level (130–220 kV).
The entity that reports the need is the one experiencing the constraint — not necessarily the one obligated to resolve it. If a lokalnät is constrained by its subscription capacity to the overlying regionnät (even if that reflects a bottleneck in the overlying network), the lokalnät reports the flexibility need. This separates the reporting obligation from the procurement obligation; the latter follows the Ei2025:01 rule that the operator whose own network contains the physical constraint bears the obligation to act. (Source - FNA Överenskommelse Svenskt genomförande 2026 (2025))
Report structure and key output questions
The FNA 2026 report (drafted by Svenska kraftnät as Designated Entity) must answer four key questions in its conclusions:
- What flexibility need does Sweden have to achieve its renewable electricity targets for the next 5–10 years?
- What potential does non-fossil flexibility have to meet needs at transmission and distribution level?
- What market barriers exist? How can they be counteracted?
- How has increased digitalization contributed to the transmission and distribution system?
Questions 3 and 4 are addressed through the market barriers and digitalization evaluation (Bilaga V), which collects structured survey data from DSOs and flexibility providers. Legal basis: Art. 19e of the Electricity Market Regulation (EU) 2019/943 as amended by Regulation 2024/1747 (Source - Electricity Market Design Reform Regulation (EU 2024-1747)). (Source - FNA Bilagor I-V (2025-2026))
Six FNAM barrier categories (from Bilaga V)
The FNAM specifies six categories of market barriers that must be evaluated:
- Lack of proper legal framework for market access to new entrants and small actors
- Lack of enablers and incentives to provide flexibility
- Restrictive requirements to provide balancing services
- Restrictive requirements to provide congestion management
- Complex, lengthy, and discriminatory administrative requirements
- Lack of regulatory incentives to system operators to consider non-wire alternatives — this directly corresponds to the CAPEX bias that Ei‘s TOTEX reform addresses
The survey asks DSOs directly: “Are there sufficient incentives for network companies to consider flexibility solutions as an alternative to building grid?” This will produce Sweden’s first official, systematic answer to the CAPEX bias question from the DSO community itself.
Swedish FNA 2026 — first cycle
Sweden’s first FNA was agreed in an Överenskommelse (tripartite agreement) signed 2025-11-25 by Svenska kraftnät, Ei, and DSO representatives (Vattenfall Eldistribution, E.ON Energidistribution, Göteborg Energi, Ellevio, Kraftringen Nät) via Energiföretagen Sverige.
The agreement adopts minimum requirements for the first cycle, with explicit ambition to expand in FNA 2028.
Technical scope of FNA 2026
| Parameter | FNA 2026 decision |
|---|---|
| Target years | 2030 and 2035 |
| Seasons | Winter (Nov–Mar) and summer mandatory; month optional |
| Power (MW) | Mandatory |
| Energy (MWh) | Deferred to FNA 2028 — replaced by qualitative reasoning (skäl) |
| RES curtailment share | Mandatory (downward flexibility need from solar/wind/hydro curtailment) |
| Connections >50 MW | Excluded (Svk already has this in its scenarios) |
Phase 2 timeline
Key dates from Bilaga IV (as of early April 2026, the data collection phase is complete and aggregation is underway):
| Date | Milestone | Status |
|---|---|---|
| 2025-11-27 | Agreements (Fas 1) signed | ✓ Done |
| 2025-12-01 | Regionnät → lokalnät: capacity indications | ✓ Done |
| 2026-01-20 | Svk → underlying networks: connection point capacity | ✓ Done |
| 2026-03-16 | Lokalnät → regionnät: data/information delivered | ✓ Done |
| 2026-04-07 | Regionnät → Svk: aggregated data delivered | ✓ Done (yesterday) |
| 2026-04-21 | Svk: preliminary draft report to Ei + DSO | Past — status unconfirmed |
| 2026-06-29 | Svk: report to Ei for approval | Upcoming |
| 2026-07-28 | Ei approves; Svk submits to ACER/Commission/government | Target |
| 2026-08-17 | Energiföretagen webinar 8: results and improvements | Future |
(Source - FNA Bilagor I-V (2025-2026))
What is deferred to FNA 2028
Four significant data elements were agreed to be deferred from FNA 2026:
-
Contractual means (villkorade avtal vs market-based) — “the regulatory framework is still unclear.” Direct acknowledgment that the Ei2025:01 / Art. 6a ambiguity around Villkorade Avtal has not yet been resolved enough to report procurement pathway data.
-
Guiding criteria (FNAM Art. 16.4) — assessing which existing flexibility resources can meet identified needs requires a flexibility register and full customer visibility that do not yet exist in Sweden.
-
Grid prequalification data (SO GL Art. 182) — the formal TSO-DSO agreement on how flexibility activations are constrained for grid safety is not yet concluded; expected H1 2026.
-
Svk transmission network needs — Svenska kraftnät will not report transmission-level flexibility needs in FNA 2026 due to insufficient methodology maturity; deferred to FNA 2028. The first FNA thus covers only distribution-network flexibility needs.
These four deferrals are diagnostic: they map exactly onto the infrastructure that does not yet exist (flex register, SO GL Art. 182 agreement, transmission methodology) and the regulatory ambiguity that is still being resolved (procurement mechanisms).
NC DR Art. 29.1 — the three-way FNA-DNDP-NC DR linkage
NC DR Art. 29.1 requires each system operator at least every two years to perform a biennial assessment of the need for and procurement of DR/storage as alternatives to system expansion. This assessment formally integrates FNA and DNDP:
FNA (ACER Decision 05-2025 / Art. 19e Reg. 2019/943)
↓ must be considered by
NC DR Art. 29.1 biennial assessment
↓ is used to fulfill
DNDP obligations (Directive Art. 32(3) and 51(3))
The assessment must also be publicly consulted. This means the FNA is not a standalone exercise — it is the upstream input that flows into both the NC DR biennial assessment and the DNDP cycle, making the three instruments mutually reinforcing. (Source - FNA Webinar 7 (2026-03-16))
ACER/CEER confirmation: The 2025 ACER/CEER guidance on distribution network planning explicitly states: “DNDPs are the primary source of DSOs’ data and analyses” for the FNA. The guidance also explicitly names Tabell 15 (FNAM Annex 2 data template) as the bridge format — DNDPs should populate the same Tabell 15 template used for FNA reporting. This is the most authoritative confirmation of the DNDP-FNA relationship available. (Source - ACER CEER DNDP Guidance (2025))
Sweden’s comparative position: Sweden is one of only 4 EU countries that have quantified flexibility needs in their DNDPs (alongside Denmark, Portugal, and Slovenia). Sweden’s DNDP first round (2025) specified only one direction, where the other three countries provided both upward and downward estimates — but this is already corrected in FNA 2026, not deferred to FNA 2028 as earlier expected. The Tabell 15 v1.03 reporting template (Bilaga III, dated 2026-03-16) contains obligatory rows for both ↑ uppreglering and ↓ nedreglering, for each target year (2030 and 2035) and each season (Vintersäsong and Sommarsäsong); a value must be entered for both directions even where it is 0. The downward (nedreglering) need is additionally split out via the mandatory Andel av nedregleringsbehov som utgörs av RES-begränsning (MW) column. Both-direction reporting therefore applies from FNA 2026. Portugal is still cited by ACER/CEER as the most advanced country, using probabilistic analysis and cost-benefit comparison of flexibility vs. reinforcement. (Source - ACER CEER DNDP Guidance (2025), Source - FNA Bilagor I-V (2025-2026))
(Note: the template’s predefined season values are spelled “Vintersässong” / “Sommarsässong” — a misspelling in the official Svk/Ei workbook; the correct Swedish is “säsong”.)
Art. 31.1 — flexible connection agreements treated as firm
A critical methodological rule from NC DR Art. 31.1: flexible connection agreements (villkorade avtal) shall be treated as firm connection agreements when assessing flexibility needs. The controllable capacity contracted under a villkorat avtal must be counted as always-available capacity — meaning the DSO must report the full underlying grid constraint, not a number reduced by existing contractual coverage.
This ensures FNA and DNDP figures represent true infrastructure gaps. Only permanent solutions under Art. 6a.1.c are exempted. (Source - FNA Webinar 7 (2026-03-16), Villkorade Avtal)
Relationship to NC DR
The FNA sits within the NC DR implementation architecture but is operational ahead of the main network code:
- ACER Decision 05-2025 (FNAM) is already published and binding — part of the NC DR framework entered into force in July 2025
- The FNA results will inform the flexibility register design (what resources exist to fill the identified gaps)
- The FNA will shape DSO Congestion Management planning and the case for local Flexibility Market development
- The NC DR’s transparency requirements for DSO flexibility procurement and DNDP publication are tightly linked to FNA outputs
Practical tools for flexibility need quantification
Energiforsk’s methodology study (2025:1088) describes two specific tools for the need analysis step that go beyond the basic load-vs-limit approach used by major DSOs, and two further Energiforsk reports add complementary methods:
Endre Technologies probabilistic method: Rather than comparing a single forecast against the constraint limit (deterministic approach), Endre’s tool disaggregates load profiles by customer type (household, commercial, industrial) and builds probability distributions for overload scenarios. The result is expressed as Txx-year return periods — e.g., “the probability that MW demand will exceed the constraint limit is equivalent to a 1-in-20-year event.” This allows DSOs to say “we have a 5% chance of overload per year, requiring ~40 hours of flexibility on average” rather than a binary “congested / not congested” classification. The approach mirrors the N-1 probabilistic dimensioning used at transmission level.
RISE AMI classification tool: Identifies each customer’s heating type (direct electric, heat pump, district heating), EV charging presence, solar panel installation, and price-responsive behaviour patterns — directly from smart meter hourly data, without requiring manual surveys or customer self-reporting. Once customers are classified by resource type, DSOs can estimate aggregated flexibility potential behind any feeder: e.g., “this 100-customer feeder has 23 heat pump customers totalling ~200 kW of thermostat-controllable load.”
Together these tools address the two core data gaps in DSO flexibility need analysis: how severe is the constraint probabilistically (Endre), and what resource potential exists to address it (RISE). Both are being piloted in Sweden; neither is yet standardized or mandated.
(Source - Energiforsk 2025-1088 Metodik Flexibilitet Elnät (2025))
What-if behavioral scenario method (Energiforsk 2024:1043): Rather than producing a single point estimate of the flexibility need, the report proposes publishing explicitly named EV charging behavior scenarios (direct charging / price-optimized / grid-friendly), each producing a different MW × hours/year output. Key insight: the behavioral assumption is the dominant uncertainty — for the same substation, the range can be 20–450 kW and 6–427 hours/year (Stockholm case study). Publishing scenarios enables stakeholders — municipalities, aggregators, customers — to form their own views on which is most plausible. (Source - Energiforsk 2024-1043 DNDP Analys och Flexibilitet (2024))
National top-down baseline method (Energiforsk 2026:1157): For FNA 2028 and beyond, a standardized national top-down method based on official data sources (Energimyndigheten, SCB, Trafikverket) would provide all DSOs with a common baseline scenario that can be broken down to county/municipality level. This would address the comparability problem that currently makes DNDP aggregation unreliable. Phase 1 covers rooftop solar and home EV charging; Phase 2 expands to additional load categories. The method is intended to complement (not replace) local bottom-up analysis of point loads and connection queues. (Source - Energiforsk 2026-1157 Nationell Metod Effekt och Kapacitetsprognoser (2026))
How DSOs calculate flexibility needs in practice
Webinar 7 included concrete worked examples from E.ON Energidistribution and Ellevio — the most granular picture of what “flexibility need” means operationally:
Two binding constraints per substation/connection point:
- N-1 technical capacity — max load while remaining N-1-safe (lines, transformers, cables)
- Subscription limit (abonnemangsgräns) to the overlying network — the allocated capacity from regionnät or Svk
E.ON’s method: historical load data (4 years) → load forecast at target year → compare simulated load against the binding constraint → flexibility need = the excess that doesn’t fit. Low-voltage (0.4 kV) excluded; bedömning done per station.
Ellevio’s method: same inputs, explicitly overlaying capacity at connection point to overlying network (2030 and 2035 vintages separately). Flexibility need is the gap between load forecast and the binding constraint line in the time series.
Both methods confirm that the subscription capacity indication from the overlying network (delivered 2025-12-01 from regionnät to lokalnät; 2026-01-20 from Svk to regionnät) is the critical external input — without knowing the overlying subscription limit at 2030/2035, lokalnät cannot assess their constraint-based flex need. (Source - FNA Webinar 7 (2026-03-16))
Swedish coordination
Energiföretagen Sverige‘s AG Helhet Flex task force ran seven preparatory webinars (June 2025 – March 2026) to coordinate DSO participation in the first FNA. Ei has supervisory authority — if Svk and DSOs cannot agree on a methodology decision, Ei decides. (Source - Flexibilitetsbehov FNA Energiföretagen Sverige (web, 2026))
DNDP-aggregated DSO flexibility needs (pre-FNA benchmark)
Ei‘s synthesis of the first round of DNDP submissions (Ei PM2025:03, March 2025) provides the authoritative aggregate of reported Swedish DSO flexibility needs — the primary source for the numbers below. FlexAbility Delrapport 1 (2025) subsequently cited these same figures. Coverage: 122–127 companies (of 152 DNDPs reviewed), representing ~60% of Swedish customers; ~45% of all 155 DSOs reported non-zero needs. (Source - Ei PM2025-03 DNDP Sammanställning (2025))
| Horizon (from 2025) | Combined range (consumption + production combined) |
|---|---|
| 0–2 years | 277–1,030 MW |
| 3–5 years | 640–1,883 MW |
| 6–10 years | 1,387–2,523 MW |
Three large DSOs (covering ~20% of Swedish customers) reported separately by direction (Tabell 8 in PM2025:03):
- Consumption flexibility: 301–346 → 821–1,092 → 0–1,688 MW (by horizon)
- Production flexibility: 2,462–2,572 → 2,110–2,550 → 6–2,948 MW (by horizon; the large 0–2 year production figures reflect DSOs with significant renewable generation portfolios)
The wide ranges reflect inconsistent reporting methodology across DSOs — a known issue that the FNA 2026 standardization effort (FNAM Bilaga III / Tabell 15) is designed to address. The fact that only ~45% of DSOs reported non-zero needs is itself diagnostic: either many DSOs genuinely have no short-term flexibility needs, or (more likely) methodology and reporting maturity vary substantially. Ei explicitly acknowledges in PM2025:03 that differences in reference years, accumulated vs incremental reporting, and inconsistent load diversity assumptions create “considerable uncertainty intervals” in all aggregate numbers. (Source - Ei PM2025-03 DNDP Sammanställning (2025), Source - FlexAbility Delrapport 1 (2025))
Vattenfall Eldistribution — N/A explained: Vattenfall Eldistribution reports N/A for all five areas and all three horizons in Ei’s DNDP data tool. This is not a methodology or reporting gap — it is a deliberate policy stance. Vattenfall’s DNDP explicitly states that market-based flexibility services are not viable at any of its constrained locations and that it sees no need for flexibility solutions beyond villkorade avtal with individual customers. Vattenfall’s viability threshold (supply ≥5× demand, ≥5 independent actors) is not met anywhere in its network. The FNA 2026 report will thus receive zero quantified flexibility needs from the largest Swedish DSO by network area, despite Vattenfall expecting +7,500 MW of growth requiring 22 major investments. (Source - Vattenfall Eldistribution Nätutvecklingsplan 2025-2034)
Ellevio DNDP 2025–2034 — quantified needs, intermediate position: Ellevio reports quantified flexibility needs in its DNDP — unlike Vattenfall’s N/A, but also without active markets unlike E.ON. The flexibility section (Tabell 3) covers all 17 delområden across three horizons. Key areas with non-zero needs: (Source - Ellevio Nätutvecklingsplan 2025-2034)
| Delområde | Type | 0–2 yr (MW) | 3–5 yr (MW) | 6–10 yr (MW) |
|---|---|---|---|---|
| Halland | Consumption | 0 | 0–30 | 0–50 |
| Orust-Tjörn | Consumption | 20 | 40 | 0 |
| Skaraborg | Consumption | 0 | 0–10 | 0–25 |
| Skaraborg | Production | 0–10* | 0–300* | 0–450* |
| Nynäshamn | Consumption | 0–5 | 0–10 | 0–10 |
| Ekerö | Consumption | 0–5 | 0–10 | 0–15 |
| Stockholm | Consumption | 0 | 0 | 0–130 |
| Lidingö | Consumption | 0–5 | 0–5 | 0–5 |
| Täby | Consumption | 0–25 | 0–25 | 0–40 |
| Vallentuna | Consumption | 0–5 | 0–10 | 0–10 |
| Värmland | Consumption | 0 | 0–170 | 0–320 |
| Värmland | Production | 0–100* | 0–140* | 0–240* |
| Dalarna | Production | 350* | 0* | 0* |
| Tovåsen | Production | 0 | 0 | 0–150 |
* indicative; based on current production levels; additional requests in early stages could push higher
The Stockholm dependency pattern is notable: Stockholm, Täby, Ekerö, Nynäshamn, Lidingö, and Vallentuna all have near-zero to zero consumption flex needs in the short/medium term because the binding constraint is the overlying Svk stamnät (expected to be resolved ~2031 via “Stockholm Ström” and “Storstockholm Väst” packages) rather than Ellevio’s own distribution network. Until 2031, tillfälliga abonnemang and villkorade avtal handle the residual.
Dalarna’s production flex need (350 MW, 0–2yr) is an existing need driven by hydropower/wind exceeding stamnät capacity during off-peak periods — reported as resolving by the 3–5yr horizon as stamnät investments come online (~2032). This is a currently active need that Ellevio manages with produktionsgaranti agreements.
Värmland’s dual-direction need (consumption 0→320 MW + production 0→240 MW, both indicative at longer horizons) is one of the most structurally complex needs in Ellevio’s network — high industrial consumption in the south, high hydropower/wind in the north, with the overlying stamnät as the binding constraint until 2035.
Ellevio uses the same two-constraint method described by Ellevio representatives at Source - FNA Webinar 7 (2026-03-16): historical load data from 2022 forwards → load forecast at target year → compare against the binding constraint (N-1 technical capacity OR subscription limit to overlying network, whichever is more restrictive) → flexibility need = the excess.
Other notable DSO flexibility needs from Ei’s data tool (Source - Ei Karttjänst DNDP Data (2025)):
- Göteborg Energi / delomr. A: 0–100 MW (0–2yr) → 170–230 MW (3–5yr) → 160–240 MW (6–10yr) — the largest reported need outside E.ON’s Skåne
- Luleå Energi: 10 MW/yr → 85 MW/yr → 305 MW/yr — an extraordinary trajectory for a DSO with ~246 MW base load; driven by Norrbotten’s industrial electrification (LKAB, steel, data centers)
- Ellevio / Värmland: 0 → 0–170 MW → 0–320 MW — growing production flexibility need (solar/wind)
- Mälarenergi: 16–11 MW → 20–17 MW → 33–30 MW (Västra/Östra)
This dataset is distinct from the FNA 2026 output (which uses the standardized FNAM methodology and will be published July 2026) — but provides the best available quantitative pre-FNA picture of Swedish DSO flexibility needs.
E.ON DNDP 2025–2034 — detailed county-level needs
E.ON Energidistribution‘s own DNDP provides the most detailed public breakdown of a single large DSO’s flexibility needs. The DNDP states a total need of ~700 MW / ~1 TWh per year across E.ON’s network. These figures are weather-conditional (cold-winter peak) and represent the upper bound of a 0–N range per county. (Source - E.ON Nätutvecklingsplan 2025-2034)
| County | Power 0–2 yr (MW) | Power 3–5 yr (MW) | Power 6–10 yr (MW) |
|---|---|---|---|
| Skåne | 47–240 | 30–280 | 30–290 |
| Jönköping | 0–95 | 0–100 | 0–120 |
| Kronoberg | 0–85 | 0–85 | 0–100 |
| Kalmar | 0–70 | 0–90 | 0–100 |
| Östergötland | 0–65 | 0–60 | 0–65 |
| Halland | 0–25 | 0–25 | 0–35 |
| Blekinge | 0–25 | 0–30 | 0–30 |
| Örebro | 2–16 | 2–21 | 0–21 |
| Uppsala | 5–19 | 5–36 | 0–15 |
| Stockholm | 5–14 | 0–28 | 0–10 |
| Västra Götaland | 0–5 | 0–5 | 0–5 |
| Gävleborg / Jämtland / Västerbotten / Västernorrland | 0 | 0 | 0 |
Critical caveat: pending uninvestigated connection applications would — if realized — increase stated needs substantially (Skåne +90–130%, Stockholm +100–280%, Uppsala +50–500%, Kalmar +40–80%). These represent the upside scenario for flexibility demand.
E.ON’s methodology: N-1 dimensioning at each fördelningsstation (substation where regionnät meets lokalnät). Flexibility need = gap between forecast and N-1 capacity after planned investments. Production-side (summer overproduction) flexibility not yet quantified — stated as development ambition.
These figures will feed into the standardized FNA 2026 reporting via the FNAM Tabell 15 template, though the FNA uses a narrower scope than the DNDP (see table in FNA scope section above).
Skånes Effektkommission four-step method
The “Flexibilitet nät” working group of Skånes Effektkommission (E.ON Energidistribution, Kraftringen Nät, Öresundskraft Elnät) published a practical four-step guide for DSO flexibility need calculation in 2026, calibrated to minimum FNA/NUP reporting requirements for radial grids. (Source - Skånes Effektkommission Flexibilitetsbehov Metod (2026))
The guide complements the methods described by E.ON and Ellevio at Webinar 7: the same two-constraint logic (N-1 technical capacity and subscription limit to overlying grid) is used, but with explicit guidance on standard demand factors, worked examples, and double-counting rules.
Step 1 — Define baseline: 3–5 years of historical hourly load data at all selected network points. Either use the dimensioning peak/valley (minimum reporting), or a full time series (extended analysis). Account for network restructuring and operational changes.
Step 2 — Define forecast: Identify additional installations in the planning horizon (EVs, heat pumps, new production); estimate their effect using standard demand factors from the Energiforsk lathund; integrate with baseline to form a forecast time series for the target year (2030/2035).
Standard demand factors (Energiforsk lathund):
| Installation type | Load factor |
|---|---|
| Single-family house (fjärrvärme / no electric heating) | 0.6 kW/dwelling |
| Single-family house (own electric heating) | 2.8 kW/dwelling |
| Single-family house (heat pump) | 1.3 kW/dwelling |
| Apartment building (fjärrvärme) | 0.5 kW/apartment |
| Apartment building (heat pump) | 0.8 kW/apartment |
Worked EV example: 15% → 40% EV penetration by 2030. For a feeder serving 200 households: +50 EVs × 7 kW = +350 kW.
Worked solar example: 13% → 25% PV penetration by 2030, average 18 kW per installation. For a feeder serving 200 households: +24 × 18 kW = +432 kW downward at peak solar hours.
Step 3 — Define capacity constraints: identify the binding constraint at each network point — either N-1 technical capacity (transformers, lines, cables) or subscription capacity to the overlying grid at the target year. Include planned investments confirmed for the target year. Voltage constraints and LV (0.4 kV) network may be excluded.
Step 4 — Identify flexibility need: flexibility need at each point = max(0, forecast − binding constraint). Aggregate by season (winter/summer), direction (up-regulation / down-regulation), and reason (own-grid technical constraint vs. subscription constraint to overlying grid).
Double-counting rule: lokalnät must separately report flexibility need arising from constraints in their own network versus constraints in the overlying network. This ensures that when Svk aggregates the national FNA, each MW of need is counted once.
The output format matches FNAM Tabell 15 used for both NUP and FNA reporting, making the method directly compatible with the FNA 2026 data submission requirements.
Energiforsk lathund as industry standard — Skåne DSO evidence
The Skåne NUP synthesis provides the first cross-DSO evidence of methodological practice at regional scale: at least 8 of 20 Skåne DSOs explicitly reference the Energiforsk lathund (Effektprognos — en lathund för lokalbolag, 2024:1006) as their primary forecast tool. These include Bromölla Energi, Höganäs Elnät, Kraftringen Nät, Olofströms Kraft, Olseröd, Skånska Energi Nät, Öresundskraft, and implicitly most others. The Effektkommission’s four-step method guide and Region Skåne’s municipal forecasts also use the same tool.
This makes the Energiforsk lathund the de facto regional standard for DSO flexibility need forecasting in Skåne — and likely beyond, given its development with major national DSOs. The standard demand factors documented in the Effektkommission four-step method section above (single-family 0.6–2.8 kW/dwelling; apartment 0.5–0.8 kW/apartment) are drawn from this lathund.
Regulatory dependency — SENAB finding: Skånska Energi Nät (SENAB) is documented in the NUP synthesis as explicitly conditioning its flex market participation on “regulatory development and revenue cap incentives.” This is the first public statement from a Swedish DSO directly tying its flex market participation decision to the TOTEX/lösningsneutralitet reform trajectory at Ei. The CAPEX bias is not merely a theoretical problem — it is actively cited by DSOs as a reason not to run markets yet. The FNA 2026 Bilaga V survey (question: “are there sufficient incentives for network companies to consider flexibility solutions?”) will capture this systematically.
Data gaps
- Whether Swedish DSOs will populate the downward (nedreglering) rows with substantive values or default them to 0 in the first FNA 2026 cycle
- Whether the Energiforsk lathund (2024:1006) will be formally endorsed by Ei or incorporated into EIFS 2026:4 requirements for the 2027–2036 DNDP cycle