Flexible Connection Agreements
A rules-based alternative to market bidding — the customer pre-commits upfront to being curtailable under fixed conditions, in exchange for a faster, cheaper, or larger connection, rather than bidding into a market each time the grid needs it.
FCAs and local flexibility markets can actively conflict if not co-designed — ex-post curtailment notification means a customer's day-ahead LFM bid gets double-activated by both mechanisms for the same event, exactly the design trap NC DR Art. 31(3) requires Sweden's villkorade avtal to avoid.
Flexible connection agreements (FCAs) are connection contracts between a DSO and a network user in which the user accepts, in exchange for connection or capacity benefits, that the DSO may curtail their injection or withdrawal under defined conditions. FCAs are one of three main mechanisms by which DSOs acquire flexibility from third-party resources — alongside network tariffs and local flexibility markets. The established Swedish implementation is Villkorade Avtal (conditional connection agreements) — but it isn’t the whole story: E.ON is developing a second, distinct instrument, “flexibla avtal” (flexible agreements), intended as a permanent FCA-style arrangement rather than villkorat avtal’s temporary last-resort role, aimed specifically at large batteries. It isn’t yet a finished, Ei-approved product — E.ON describes it as still under active dialogue with Ei on design — so treat villkorat avtal as the operational Swedish FCA today, with a second one taking shape alongside it.
What a flexible connection agreement does
A standard grid connection gives the customer a firm, unconditional right to inject or withdraw up to their contracted capacity at any time. Under an FCA, the customer accepts conditional access: the DSO may temporarily limit their capacity when the grid reaches defined operational thresholds. In exchange, the customer typically receives:
- A faster or cheaper connection (reduced deep connection cost, or connection at a point that would otherwise require reinforcement)
- A higher contracted capacity than an unconditional connection would permit at that location
- A compensation payment when curtailment is activated
FCAs are a rules-based flexibility mechanism: the customer pre-commits to being curtailable under defined trigger conditions, rather than bidding into a competitive market at the time of the grid event. This makes them more predictable for DSO planning but less price-efficient than market-based mechanisms.
EU regulatory framework
The Electricity Market Design Reform Directive (2024/1711, Art. 6a) requires member states to establish a framework for flexible connection agreements. Key provisions:
- The regulatory authority must develop a framework for DSOs (and TSOs) to offer FCAs in areas where network capacity for new connections is limited or unavailable
- FCAs must not unduly restrict market participation: NC DR Art. 31(3) explicitly preserves the right of FCA holders to participate in local flexibility markets
- Sweden transposed Art. 6a in Prop. 2025/26:16 (in force January 2026), mandating Ei to develop the national flexible connection framework
See Villkorade Avtal for the Swedish implementation, Electricity Market Design Reform 2024 for the broader legislative context, and Ei for the Swedish regulatory development process.
The July 2026 tariff proposal. The Commission’s proposal COM(2026) 600 would make tariff methodologies “enable the use of flexible connections, while ensuring this does not delay needed network reinforcements” (Art. 18(2)(l)), and its Art. 18d(2) would require Member States and regulators to keep flexible connection agreements under Art. 6a in place alongside any connection prioritisation in congested areas. The EU DSO Entity lists FCAs, market rules and flexibility products as tools to be used alongside tariff design, not replaced by it (DSO Entity’s reaction).
The charging principle. The Commission’s January 2026 network-charges guidance states it directly: because a flexible connection does not give unrestricted network access, “the network charges applied to users with these types of connections should reflect this.” An FCA is therefore not only a capacity instrument but a tariff one — the discount is the consideration for accepting restriction, not a subsidy. The guidance sets out the Dutch three-model implementation as the worked example: fully flexible (congested areas only; the user pays for monthly peak but not contracted capacity), minimal availability (85% guaranteed capacity, cannot increase actual peak, monthly peak charge only), and timeslot agreements (contracted access windows; part contracted-capacity charge plus monthly peak). (Source - C(2026)126 Future Proof Network Charges Guidelines)
The IEA’s September 2026 electrification report (IEA Special Report on Electrification) estimates that flexible or non-firm connections, allowing earlier connection in exchange for limited curtailment, could enable 750–900 GW of additional hosting capacity globally, and notes connection reforms replacing first-come-first-served with readiness-based requirements; the figure is a global aggregate cited to an IEA 2026 analysis not held here, not a Swedish estimate.
The ICCT and Fraunhofer ISI truck-charging study (ICCT and Fraunhofer ISI analysis) warns that without “proactive and flexible grid connections” insufficient distribution capacity may delay road-freight electrification, but it does not model flexible connections or controlled charging; it lists tariff-aware and grid-responsive charging as future work.
The ISGAN and BRIDGE discussion paper on remuneration (ISGAN and BRIDGE discussion paper) names flexible connection agreements, with market-based procurement and bilateral contracts, among the flexibility solutions that DSO remuneration schemes should not penalise; it finds that cost-of-service and hybrid schemes, used by 7 of 11 surveyed jurisdictions, disincentivise them once pilot support ends.
International benchmark — TenneT TDTR (Netherlands): the Dutch TSO offers a standardized conditional/flexible agreement, the Time-Driven Transport Right (TDTR) — contracted power guaranteed 85% of the year in exchange for a 50% network-fee discount. Analysing actual annual utilisation, TenneT identified ~9 GW of headroom allocatable to new customers willing to be limited (the source says “a few hours”, though an 85%-of-year guarantee leaves up to ~15% of the year), with firm 100%-access capacity increasingly treated as a premium “luxury good.” This is the headline contractual capacity-release example in Grid Capacity Utilization and a concrete model for standardized, predictable FCA terms. (Source - Energiforsk 2026-1190 Kapacitet för Tillväxt (2026))
⚠ Note on the Art. 6a transposition deadline: CEER’s June 2026 paper (Source - CEER Grid Connection Challenges (2026)) states the Art. 6a transposition deadline “passed on 17 January 2025” — this conflicts with the 17 July 2026 date previously used in this wiki. Checked 2026-09-20 against the Directive text (Art. 3(1)): CEER is right — the later 17 July 2026 deadline covers only Art. 2 points (2) and (5) (Art. 4 and Art. 15a energy sharing); Art. 6a follows the general 17 January 2025 deadline. Prop. 2025/26:16 does not give 17 July 2026 for Art. 6a (only for energy sharing).
EU-wide survey findings (CEER, 2025 survey of NRAs/DSOs)
CEER’s June 2026 paper (Source - CEER Grid Connection Challenges (2026)) surveyed CEER member NRAs on national FCA implementation. Key findings, useful as an EU-wide benchmark against Villkorade Avtal:
- Network charge treatment (per ACER’s March 2025 Network Tariff Report, cited by CEER): of 15 countries with FCAs, 5 give use-of-network tariff discounts (AT, BE, DK, DE, NL), 3 give reduced connection charges (DK, EE, NO), and 3 give no tariff discount at all (FI, FR, PT). Sweden is not in the 15-country sample, but the spread shows there is no EU consensus on whether FCA holders should receive a tariff discount — a live question for Ei’s pending Art. 6a framework.
- Eligible user types: more CEER member states have implemented FCAs for demand and storage than for generation — the same demand/storage-first pattern seen in Sweden’s villkorade avtal rollout (E.ON’s 2024 launch covered both directions, but most early activity is consumption-side).
- Limitation definition: beyond the static/dynamic split already covered above, CEER identifies two further FCA sub-types worth tracking: fully flexible FCAs (availability determined in the day-ahead timeframe based on network availability — effectively merges FCA and market-based dispatch logic) and time-window FCAs (capacity limited only within, or unlimited only within, a defined window).
- Queue management is the companion problem: CEER frames FCAs as one of two tools (alongside queue-management reform) for the same underlying scarcity. Its allocation-procedure taxonomy — first-come-first-served, first-ready-first-served, auction, repartition (pro-rata), gradual/milestone-based, priority lists — and anti-hoarding measures (reservation deadlines, use-it-or-lose-it, security deposits, annual penalty fees, maturity assessments) map directly onto Sweden’s anvisningssystem/mognadsgrad reforms; see DSO Connection Queue Reform — The Swedish Policy Response for the Swedish-specific application.
National case studies
EU-wide pattern — temporary dominates despite permanent being legal. An EC-commissioned comparative study (Fraunhofer ISI, August 2025) found FCA equivalents are predominantly applied as temporary solutions across all EU member states, even though the Electricity Directive (as revised by 2024/1711, which introduces flexible connection agreements as its Art. 6a) explicitly permits permanent FCAs — specifically via Art. 6a(1)(c) — where grid reinforcement is not the most efficient solution; no EU country has systematically deployed them in practice. The practical barrier is regulatory confidence: permanent FCAs require long-term capacity commitments that DSOs and NRAs are reluctant to make without an operational evidence base. Chicken-and-egg problem: confidence requires data, but without confidence the experience that generates data is never accumulated. The EC’s recommended fix is a model-based study on permanent-vs-temporary FCA costs and benefits — analytical evidence as a substitute for the operational experience that’s otherwise never accumulated. This EC study’s own Sweden factsheet lists conditional grid connection as “Not standard” and does not mention E.ON or an overbooking model at all — the 130% overbooking figure and “advanced FCA framework” characterization come from other vault sources on Villkorade Avtal, not this study; the two should not be conflated. (Source - EC Study Distribution Grid NDP Tariffs and Connections 2025)
Spain — Royal Decree-Law 7/2026 (in force 21 Mar 2026): combines monthly reservation fees for demand-installation permit holders (with a 3-month initial exemption and automatic permit expiry on non-payment), priority queues for “high-priority” demand installations, and automatic lapse of access rights on missed milestones (with judicial-injunction suspension). A comprehensive model combining reservation fees, priority lists, milestones, and FCAs in one instrument — more aggressive than any current Swedish tool.
Spain — Circular 1/2024 + Feb 2026 consultation: proposes four FCA types graded by network level and disconnection mechanism — Type 0 (time-window consumption only), Type 1 (contingency disconnection at >36 kV distribution, N met but not N-1), Type 2 (active network management with real-time DSO curtailment instructions), Type 3 (transmission-connected demand, immediate reduction on SO instruction). This N/N-1-contingency-based typology (Types 1–2) is a more granular activation-trigger framework than anything currently specified for villkorade avtal.
Finland — Energiavirasto regulation (in force 22 Jan 2026, applies from 1 Feb 2026): the clearest EU precedent for a temporary vs. permanent FCA statutory split — temporary FCAs (no permit, must not delay reinforcement) vs. permanent FCAs (permit from Energiavirasto required, only where network development is determined not the most efficient solution for the network as a whole, with an explicit genuine-consent safeguard: consent is not voluntary if no alternative connection option — firm or temporary FCA — is offered alongside the permanent option). This consent safeguard is a design detail not yet addressed in Sweden’s pending Art. 6a framework or in SOU 2025:47’s permanent-FCA investigation mandate, and is directly relevant to it.
Portugal — acesso com restrições (E-Redes): Portugal’s structural equivalent of villkorade avtal is acesso com restrições (restricted access). ERSE’s April 2025 opinion on E-Redes’ PDIRD-E 2024 explicitly recommends that E-Redes actively offer and publish restricted/flexible access capacity, framing it as necessary given the gap between renewable capacity needs and available firm network capacity — E-Redes must quantify and publish available-but-not-firm network capacity, disaggregated by time of year and day type, so producers and storage operators know what restricted access could be offered to them, with upstream TSO restrictions overlaid on top of E-Redes’ own local ones. Storage operators are the primary target: ERSE identifies standalone battery storage as potentially a “problem” (if requiring firm access for both injection and offtake) or a solution (if licensed with restricted access — enabling wholesale arbitrage, ancillary services, and local DSO flexibility procurement via FIRMe). Key difference from Sweden: ERSE is a prescriptive NRA push for E-Redes to actively offer restricted access, whereas villkorade avtal emerged bottom-up from DSO practice (particularly E.ON) with Ei standardization following after — Portugal top-down, Sweden bottom-up. ERSE is explicit that restricted access complements network investment rather than replacing it, mirroring the Swedish industry position that villkorade avtal should not delay necessary grid development. (Source - ERSE Parecer PDIRD-E 2024)
Denmark — TREFOR El-net’s capacity-ceiling pilot: TREFOR El-net’s 2025 pilot (notified jointly alongside a distinct Cerius-Radius model, both to Forsyningstilsynet) tests a fixed-price standing capacity ceiling structurally closer to an FCA than to a dispatched flexibility product: the winning bidder must not exceed an agreed capacity limit at all times during the contract period, for a price fixed at signing, with “non-delivery” defined only as breaching that ceiling — no active per-event dispatch or 15-minute activation notice, unlike Cerius-Radius’s own parallel pilot (a conventional availability-plus-activation product, closer to LFM-e). Legal basis is Elforsyningsloven §73a stk. 2, tied to EU Electricity Market Regulation Art. 18 — the same EU provision underlying Sweden’s effektavgift design requirements. Market-priced rather than Sweden’s guaranteed-capacity/curtailable-capacity split, but the underlying idea — a customer accepting a standing limit in exchange for compensation — is the same shape as villkorat avtal. See TSO-DSO Coordination — The Central Design Problem › EU taxonomy: four market coordination models for the full comparison including the Cerius-Radius model. (Source - Cerius Radius Trefor Markedsbaseret Fleksibilitet Pilot (2025-2026))
Norway — TMV for EV charging infrastructure (SINTEF/MegaCharge): Norway’s structural equivalent of villkorade avtal is tilknytning med vilkår (TMV) — voluntary acceptance of curtailment/reduction risk in exchange for faster grid access. A 2026 SINTEF study, focused specifically on charging-station operators (a fast-growing connection customer segment facing acute network-capacity constraints for heavy-transport electrification), found lack of standardization — across connection process, condition design, contract content, and technical solutions — is the single biggest barrier to scaling TMV, mirroring every DSO’s own custom terms forcing bespoke integration work from operators. Two quantified findings without a Swedish equivalent yet on this wiki: even a very low minimum supply (5–10%) after curtailment disproportionately increases operator acceptance of TMV — enough to avoid the technical/operational problems of a full disconnection — and even short advance notice (1–2 hours) carries outsized value, since it lets a charging operator redirect fleet customers elsewhere. The report explicitly frames Sweden as further along in standardization (Energiföretagen’s OpenADR recommendation) but not yet fully standardized either, and recommends Norway’s industry undertake its own holistic TMV standardization effort while explicitly drawing on Swedish experience — including the specific governance lesson that separating protocol choice from contract-terms negotiation made Swedish consensus achievable. (Source - SINTEF PN26-00117 Tilknytning Ladestasjoner Med Vilkar (2026))
Design dimensions
The Comillas/BeFlexible research (Source - DSO Service Acquisition Interaction Comillas (2024)) defines twelve key design dimensions for FCAs, organized across meta-dimensions:
Temporal
- Duration: temporary (time-limited) vs permanent (indefinite)
- Curtailment notification: day-ahead / intra-day / real-time / ex-post; critically affects ability to combine with local market participation
Locational / product
- Connection costs: deep (customer pays full reinforcement cost) / shallow (customer pays only local connection cost, system reinforcement socialized) / avoid reinforcement / defer reinforcement
- Benefit of the DSO: what grid need the FCA addresses — connecting new capacity that would otherwise require investment
Network connection criteria
- Capacity limitation — connection capacity capped below contracted maximum
- Voltage level limitation — access restricted at specific voltage thresholds
- Other security criteria (N, N-1) — activation when N-1 security margin is breached
- Short-circuit power rate — limiting fault current contribution
Activation
- Activation trigger: emergency (no advance notice) / maintenance (planned window) / congestion (real-time grid state) / peak/off-peak (time-defined windows) / seasonality
- Pre-definition of curtailment: known in advance (seasonal calendar) vs reactive (only when grid needs)
- Principle of access: how the DSO selects which customers to curtail when multiple FCAs are available
- Pro-rata: all FCA holders curtailed proportionally
- LIFO (last-in, first-out): most recently connected customers curtailed first
- Auction: DSO calls for bids; lowest-cost curtailment wins
- Congestion-created level: amount of curtailment proportional to congestion caused
Commercial
- Compensation payments: fixed (predetermined amount) / set by LFM (LFM market price determines compensation) / LFM-indexed (compensation indexed to LFM clearing price) / none
- Sell curtailed energy: whether the DSO or customer can sell the curtailed energy volume into an energy market
- Maximum curtailment: absolute limit on how much can be curtailed, defined as: duration limitation (hours) / capacity limitation (MW) / energy limitation (MWh per period) / monetary limitation (maximum compensation paid)
- Eligible customers: generation / demand / storage
Interaction with other DSO mechanisms
FCAs do not operate in isolation. Most DSOs deploy FCAs alongside network tariffs and local markets simultaneously. This multi-mechanism deployment creates interaction effects that require co-design to avoid. (Source - DSO Service Acquisition Interaction Comillas (2024))
FCAs ↔ Network tariffs
Green (compatible):
- Flat-rate tariffs generally coexist with FCAs without conflict — no price signals overlap
- When FCAs have no compensation payments, they add no double-rewarding risk to any tariff design
Orange (contextual):
- Shallow connection cost recovery + socialized tariffs risks double-charging customers — they contribute to network cost recovery through both the tariff and connection cost
- Congestion-triggered curtailment + congestion-reflecting tariff (e.g., locational pricing) risks double-rewarding; customers reduce consumption via both mechanisms for the same congestion event
- Technology-differentiated tariffs + compensation payments → risk of favouring certain technologies twice (tariff incentive + curtailment compensation)
Design principle: FCAs with no compensation payments interact cleanly with almost all tariff designs. When compensation payments are added, every tariff design should be reviewed for double-rewarding risk.
FCAs ↔ Local markets
This pair has the most interaction conflicts — particularly critical for Sweden where villkorade avtal and local flexibility markets coexist at the same DSOs.
Red (incompatible):
- Ex-post curtailment notification + day-ahead LFM: if customers receive curtailment instructions after the fact, they cannot factor this into their day-ahead market bids. Any bids they submitted assume no curtailment; ex-post curtailment then creates a double activation of the same resource.
- Emergency activation + contract lengths from daily to yearly: with no advance notice for emergencies, customers with outstanding LFM bids cannot adjust. Combined use is infeasible.
Orange (contextual):
- LIFO access principle: creates uncertainty about which customers will be curtailed — a customer’s ability to participate depends on queue position for curtailment orders, complicating reliable LFM bidding. The source paper treats this as context-dependent rather than a hard block.
Green (compatible):
- Permanent FCAs with known timelines + LFMs: customers can plan their LFM availability around known curtailment windows; if curtailment notification is day-ahead, LFM participation is unaffected for hours without curtailment
- No compensation payments in FCA + LFMs: no double-rewarding risk because no financial transaction occurs on the FCA side
- Same-type eligible customers and LFM asset direction: if the FCA requires upward generation and the LFM also requires upward generation, the two mechanisms are asking for the same thing — compatible as long as activation timing and compensation don’t overlap
The design principle for NC DR compliance in Sweden: FCAs (villkorade avtal) and LFMs must be co-designed. NC DR Art. 31(3) preserves FCA holders’ right to participate in LFMs — but this is only practically achievable if the FCA notification timing, access principles, and compensation structure are compatible with LFM participation. Emergency-trigger FCAs with ex-post notification undermine this right in practice.
The lock-in risk. The flexibility industry’s own EU outlook for 2035 warns that FCAs, tariffs and direct control give system operators an immediate safety net while “starving emerging markets of the liquidity they need”; in its most pessimistic scenario a transitional FCA regime becomes permanent (“the bridge becomes the destination”), and in its most optimistic one FCAs remain only as a justified last resort reported to regulators. The report is written for smartEn, the demand-flexibility industry association, and sponsored by a V2G and battery aggregator, so it argues from the market side (smartEn and LCP Delta 2026).
Swedish context — villkorade avtal
Sweden’s Villkorade Avtal are the national implementation of FCAs. Current characteristics:
- Activation trigger: primarily congestion-driven and emergency; no uniform notification timing across DSOs
- Compensation: some DSOs offer compensation (guaranteed capacity reduced vs guaranteed off), others do not
- Principle of access: not standardised; varies by DSO
- Interaction with LFMs: E.ON Energidistribution uses villkorade avtal as a backstop when SWITCH market procurement is insufficient; villkorade avtal activate only if market-based flexibility fails. This sequential design (market first, then FCA) is the recommended NC DR approach and avoids the red-condition double-activation problem.
Under Ei’s proposed framework following Prop. 2025/26:16, a certified effektregleringssystem (power management system) will be required for new flexible connections — this is a standardisation step that brings Swedish FCAs closer to the EU design dimension framework. See Villkorade Avtal for the full Swedish development.
At transmission level, Svk’s June 2025 pre-study treats the villkorat anslutningsavtal as a temporary measure: curtailment of the load at the connection point when an overload risk exists, activated last after market-based options and preferably automatically through a nätvärn where the cause is clear. There is no separate queue, no initial tariff or fee relief, and applicants are selected on near-term need (2026–2030) and at least two years earlier commissioning; permanent versions with a reduced tariff for lower reliability are left for later (Source - Svk Villkorade Anslutningsavtal Förstudie (2025)). For data centres, a 2026 Agora Energiewende and Deloitte study models a mandated minimum flexibility (curtailment in about 1.5 % of hours) in return for a flexible connection agreement (Source - Agora Deloitte Data Centre Flexibility in Europe (2026)); see Data Centres and Grid Flexibility.
The Source - DSO Service Acquisition Interaction Comillas (2024) interaction analysis is directly prescriptive for the Swedish NC DR T&C development: DSOs must review their villkorade avtal designs against each active mechanism to identify orange and red cross-options, then amend designs or add coordination rules to resolve conflicts.
FCAs in the three-mechanism DSO toolkit
| Mechanism | How it works | Market type | Timing | Certainty |
|---|---|---|---|---|
| Network tariffs | Price signals embedded in electricity bills | Implicit (rules-based) | Continuous; no activation | Probabilistic |
| Flexible connection agreements | Pre-committed curtailment rights | Explicit (rules-based) | On trigger; DSO-initiated | High (if permanent; emergency trigger gives certainty) |
| Local flexibility markets | Competitive procurement | Explicit (market-based) | Day-ahead / intraday bidding | Probabilistic (depends on market clearing) |
FCAs and LFMs are complementary: FCAs provide operational certainty (the DSO has a committed right to curtail when needed), LFMs provide economic efficiency (competitive pricing and resource diversity). The NC DR establishes LFMs as the default procurement mechanism with FCAs as the backstop — but their interaction requires careful design.
Swedish framework trajectory
What NC DR and Directive 2024/1711 have already locked
Three things are structurally fixed for Sweden before any national Ei regulation is written:
- Art. 31.1 (FNA counting rule): villkorade avtal must be treated as firm connections when DSOs assess flexibility needs. The underlying grid constraint must be reported in full — VA coverage does not reduce the stated need in the FNA/DNDP. Exception: permanent FCAs under Art. 6a.1.c. (Source - NC DR Amended Text (ACER Recommendation 01-2025 Annex 1))
- Art. 31.2 (market coordination): activation must coordinate with any existing local flexibility market through a mechanism specified in the market procurement rules; day-ahead gate closure triggers a TSO imbalance adjustment for any subsequent activation. This locks in the market-first principle as EU-level statute — it was already Swedish practice per Ei2025:01, but is now non-negotiable. (Source - NC DR Amended Text (ACER Recommendation 01-2025 Annex 1))
- Art. 31.3 (market participation rights): FCA holders cannot be prevented from participating in balancing or local services markets. This is the right already recognized in E.ON’s SWITCH queue-jumping model but must now apply across all Swedish DSOs. (Source - NC DR Amended Text (ACER Recommendation 01-2025 Annex 1))
Additionally, Directive 2024/1711 Art. 6a requires a formal national framework (transposition deadline 17 January 2025, not 17 July 2026) and explicitly permits permanent FCAs where reinforcement is not economically efficient — including for storage. The ellag amendment (4 kap. 4a §, in force 2026-01-01) creates the enabling authority; EIFS regulations are pending. (Source - Electricity Market Design Reform Directive (EU 2024-1711))
The Ei method-approval model and its limits
Sweden’s current approach — Ei approves each DSO’s methods before contracts are signed (ellag 4 kap. 46 §, operationalized in Ei2025:01) — works for large DSOs that have the resources to develop and submit a method. E.ON received its first approval in March 2024. But Sweden has 168 DSOs: most have not developed a villkorade avtal method and are effectively blocked from using the tool at all, or are operating informally without Ei approval.
The Art. 6a transposition obligation forces Ei to produce formal EIFS regulations — not just ställningstaganden — specifying what a compliant national framework looks like. The most likely outcome is EIFS that sets binding framework rules (notification timing requirements for LFM coordination; activation-as-last-resort obligations; Art. 31 coordination mechanism) while leaving individual trigger thresholds and compensation structures to per-DSO method approvals. This is consistent with how Ei has regulated LFM products (Förordning §§10–12: prescribe the product category; DSOs design within it). (Source - Ei Ställningstagande Ei2025-01 Villkorade avtal (2025), Source - Ei Godkänner Marknadsprodukter Flexibilitetstjänster (2026))
Responsibility layers — settled vs. open
| Design dimension | Who owns it | Status |
|---|---|---|
| When FCAs can be used (Art. 13 exceptions + Art. 6a conditions) | Ei (EIFS) | Transitioning from ställningstaganden to binding regulation |
| Market coordination requirements (Art. 31.2) | Ei (EIFS) + Svk BSP/BRP terms | NC DR locks principle; implementation rules pending |
| Notification timing (for LFM compatibility) | Ei (method approval, likely → EIFS floor) | Open — currently DSO-specific, creates LFM compatibility risk |
| Compensation design | DSO within Ei approval | Open |
| Activation trigger and overbooking level | DSO within Ei approval | Open; E.ON 130% overbooking is the benchmark practice |
| Permanent FCAs | Ei (new EIFS required) | Not yet; Art. 6a creates the legal basis |
| Existing customers opting in | Ei (investigation mandated by SOU 2025:47) | Open |
| Cascading across network levels | Ei (investigation mandated by SOU 2025:47) | Open; requires cross-operator data infrastructure |
Permanent FCAs — the key structural question
SOU 2025:47 mandated Ei to investigate whether permanent FCAs should be allowed in Sweden. The EC comparative study (Fraunhofer ISI, 2025) found no EU country has systematically deployed permanent FCAs despite the legal authority having existed since 2024. Nordic momentum is building: in the June 2026 joint Nordic TSO statement, Fingrid explicitly argued that making flexible connection agreements a permanent tool would significantly enhance TSOs’ ability to connect customers — a peer position that strengthens the case for Sweden’s pending decision. (Source - Nordic TSOs Grid Connection Requests Statement (2026)) The structural barrier is regulatory confidence: confidence requires operational data, but data requires deployment at scale. The recommended approach is an analytical model-based study rather than waiting for operational experience that never accumulates without the policy push.
In practice, permanent FCAs are most compatible with storage business models: a battery co-located with solar that agrees to restricted grid access in exchange for a faster/cheaper connection and lower ongoing capacity fee can build a revenue model around the restriction — using on-site charging and accepting curtailment risk — but this is not friction-free. Sonnedix’s own live experience with one of Portugal’s first utility-scale batteries is that FCAs are “becoming standard” there but impose revenue-model adjustments many BESS developers did not anticipate in their original business cases, against a backdrop of grid-charging restrictions and a still-lagging grid code for batteries (Source - Powernaut Flex Trends Report (2026)) — the same restricted-access opportunity ERSE recommended E-Redes offer proactively to storage operators, arriving with real integration cost. This use case is where Swedish permanent FCAs are most likely to appear first.
International example — dynamic operating envelopes at a New Zealand DSO
Counties Energy, a New Zealand distributor, launched the Gridex orchestration platform on 8 September 2026. It issues dynamic operating envelopes either to devices directly or through aggregators and already offers flexible connections to commercial and industrial customers, where a connection that responds to real-time network conditions replaces the fixed export and charging limits of a standard connection. The company’s own, preliminary examples are a rural facility with a traditional upgrade of about $80,000 against an estimated $45,000 with a flexible connection and a battery, and a school project where an upgrade of about $138,000 becomes a $600 connection charge. It reports nearly 40 MW of flexible capacity connected or being integrated, mostly hot-water control, and says it started without waiting for a mature flexibility market. The evidence is a company announcement, not an evaluation, and the release does not say what conditions bind the customer or how curtailment is compensated (Source - Counties Energy Gridex (2026)).
Data gaps
- Ei’s national framework EIFS for Art. 6a flexible connections — content and whether notification timing will be prescribed as a binding floor or left to method approval. The EU transposition deadline (17 January 2025 per Directive 2024/1711 Art. 3(1); not 17 July 2026) has long passed; a web search in August 2026 found no confirmed Ei publication of the framework itself — worth a direct check of ei.se’s “Effektiva anslutningar till elnäten” page for a possible quiet release, or flagging this as an overdue deliverable if none is found
- Ei’s outcome on permanent FCAs (SOU 2025:47 investigation proposal) — no decision date published in sources reviewed; E.ON’s “flexibla avtal,” under active dialogue with Ei as of its 2027–2036 preliminary DNDP, is a concrete DSO-side instrument already anticipating this outcome, not yet itself approved
- Whether Ei will prescribe a standard notification timing requirement (day-ahead gate closure as minimum) to enable Art. 31.2 compliance for all DSOs
- Whether existing customers can opt into villkorade avtal — investigation mandated but no outcome
Sources
- DSO Service Acquisition Interaction Comillas (2024)
- NC DR Amended Text (ACER Recommendation 01-2025 Annex 1)
- Electricity Market Design Reform Directive (EU 2024-1711)
- EC LFM Specification and Design Criteria (VITO, 2025)
- Ei Ställningstagande Ei2025-01 Villkorade avtal (2025)
- Ei Godkänner Marknadsprodukter Flexibilitetstjänster (2026)
- SOU 2025-47 Elmarknadsutredningen (2025)
- EC Study Distribution Grid NDP Tariffs and Connections 2025
- Powernaut Flex Trends Report (2026)
- CEER Grid Connection Challenges (2026)
- SINTEF PN26-00117 Tilknytning Ladestasjoner Med Vilkar (2026)
- E.ON Nätutvecklingsplan 2027-2036 (Preliminär)
- C(2026)126 Future Proof Network Charges Guidelines
- Energiforsk 2026-1190 Kapacitet för Tillväxt (2026)
- ERSE Parecer PDIRD-E 2024
- Cerius Radius Trefor Markedsbaseret Fleksibilitet Pilot (2025-2026)
- Nordic TSOs Grid Connection Requests Statement (2026)
- COM(2026)600 Future-Proofing Electricity Bills (2026)
- DSO Entity Reaction to Future-Proofing Electricity Bills (2026)
- IEA Special Report on Electrification (2026)
- ICCT Spatiotemporal Analysis of Electric Truck Charging Demand in Europe (2026)
- ISGAN BRIDGE Distribution Remuneration and Flexibility (2026)
- Comillas Regulatory Roadmap for Distribution Remuneration (IIT WP, 2026)
- smartEn LCP Delta Reflecting on the Future (2026)
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- Anslutningsplikt
- Capacity Maps
- Data Centres
- European LFM Landscape
- Flexibility Market
- Grid Capacity Utilization
- Grid Security & Resilience
- Market vs Rules-Based Flex
- Source - Agora Deloitte Data Centre Flexibility in Europe (2026)
- Source - C(2026)126 Future Proof Network Charges Guidelines
- Source - CEER Grid Connection Challenges (2026)
- Source - COM(2026)600 Future-Proofing Electricity Bills (2026)
- Source - Counties Energy Gridex (2026)
- Source - DSO Entity Reaction to Future-Proofing Electricity Bills (2026)
- Source - DSO Service Acquisition Interaction Comillas (2024)
- Source - E.ON Nätutvecklingsplan 2027-2036 (Preliminär)
- Source - Energiateollisuus Statement on Draft Finnish FNA Report (2026)
- Source - Energiforsk 2026-1190 Kapacitet för Tillväxt (2026)
- Source - European Grids Package COM2025-1005
- Source - ICCT Spatiotemporal Analysis of Electric Truck Charging Demand in Europe (2026)
- Source - IEA Special Report on Electrification (2026)
- Source - ISGAN BRIDGE Distribution Remuneration and Flexibility (2026)
- Source - Nordic TSOs Grid Connection Requests Statement (2026)
- Source - Powernaut Flex Trends Report (2026)
- Source - SINTEF PN26-00117 Tilknytning Ladestasjoner Med Vilkar (2026)
- Source - smartEn LCP Delta Reflecting on the Future (2026)
- Source - Svensk Solenergi Remissvar Elmarknadsutredningen (2025)
- Source - Svk Villkorade Anslutningsavtal Förstudie (2025)
- Tariffs and Batteries
- The Signal Stack
- Villkorade Avtal