Source - ACER CEER DNDP Guidance (2025)

Metadata

What this source is

Joint guidance by ACER and CEER addressing distribution network planning across the EU. Explicitly complements the DSO Entity good practices document (2024) by adding a regulatory perspective. Provides a set of recommendations organized around: NRA role, transparency and stakeholder engagement, coordination, and key DNDP elements (time horizon, planning process, scenarios, grid capacity needs, flexibility). Based on the most comprehensive NRA survey of DNDP practices to date.

Context and scale

• ~3,000 DSOs in the EU (NRAs reported 2,606 in survey)
• Annual distribution investment need to 2050: ~€50B (two-thirds of total €75–100B for T&D)
• 6 MS have >100 DSOs: Czech Republic (271), Germany (866), Spain (326), Austria, France, Italy, Poland, Slovakia — and Sweden
• Sweden operates distribution grids up to 220 kV (second only to Austria’s 380 kV)
• ~957 DNDPs required across EU after exemptions applied (small DSOs <100,000 customers exempt under Directive Art. 32(5))

Recommendations summary

Key findings by section

1. Introduction

Investment context: €75–100B/year total T&D investment needed 2025–2050; ~€50B/year at distribution level. Traditional reactive planning is “no longer fit for purpose.”

Challenges (from NRA survey):

• Varying detail, clarity, and transparency in submitted plans
• Inconsistent data and assumptions
• Difficult DSO-TSO scenario alignment
• Limited DSO capacity for long-term planning
• Short consultation periods; evolving legal frameworks
• DSO challenges: permitting delays, supply chain disruptions, workforce shortage, lack of financing, absence of structured planning methodology until recently

Remuneration alignment: DNDPs must align with remuneration frameworks — without proper incentives, DSOs have limited scope for non-wire alternative solutions. Connection queues are under pressure from first-come-first-served principle.

2. NRA role

Scrutiny powers: All but 5 MS have already given NRAs at least the right to request DNDP amendments. 12 NRAs can approve; 3 can amend. Several have additional powers.

Sweden-specific (from footnotes): Ei has power to request amendments; Sweden applies a common template; Sweden has guidelines; monitoring is planned but not yet carried out.

Harmonization: Common templates already used in Austria, Flemish/Walloon Belgium, Denmark, Finland, Spain, Sweden. Minimum content requirements in Germany, Hungary, Italy, Netherlands, Poland, Romania, Slovakia. Guidelines in Walloon Belgium, Luxembourg, and Sweden.

3. Transparency and stakeholder engagement

Publication practices: DNDPs published in all but 2 MS (Denmark, Spain). Centrally collected in 7 MS — on NRA website in Belgium (Flemish), Estonia, Greece, Slovakia, and Sweden; on DSO platform in Austria and Germany.

Investment cost publication: Project-specific costs public in 16 MS. For Sweden: “investment costs made public in the revenue cap, i.e. outside the DNDP” — meaning costs are available but not within the DNDP itself.

Capacity maps: Published in Austria, Belgium, Czech Republic, Cyprus, Denmark, Finland, Germany, Italy, Latvia, the Netherlands, Slovenia, Spain, and Sweden.

Consultation: Minimum 6 weeks recommended (citing NC DR). Most MS consult public drafts; 5 MS hold separate earlier consultations on scenarios (Flemish Belgium, Croatia, Hungary, Luxembourg, Malta). Sweden: public consultation practiced.

4. Coordination

TSO-DSO alignment: Three MS prepare joint plans (Flemish Belgium, Estonia, Hungary). In all others, each DSO prepares individually. Common scenarios with TSOs in some MS.

FNAM delegation: DSOs may delegate FNA responsibilities to other DSOs or the TSO — “goes beyond exchange of information, enabling one DSO to conduct analyses on behalf of another.” This is relevant to Sweden’s regionnät-level aggregation in the FNA.

Sector coordination: DNDPs should align with gas (Dir. 2024/1788 Art. 57), hydrogen (Art. 56), and heating/cooling (Dir. 2023/1791 Art. 25(6)) plans.

5. Key DNDP elements

Time horizon: Most MS apply at least 10 years. Recommendation: at least 10 years. Sweden: 10-year horizon applied.

Three pillars (§5.2.2):

1. Scenario development — project possible demand/supply evolution; basis for capacity needs
2. Grid capacity needs identification — determine where/when additional capacity is needed; build on existing grid + scenarios
3. Project identification and selection — develop optimal solution (reinforcement or non-wire alternative)

Scenarios:

• Aligned with NECPs (mandatory in most MS, incl. Sweden)
• Aligned with TSO scenarios (common scenarios in Germany, Italy, Netherlands; DSOs advised to build on and translate)
• Coordinated with scenarios across other sectors (gas, hydrogen, heating)
• Based on publicly available scenarios with documented methodology

Grid capacity needs identification:

• Most MS: load flow simulation (Belgium, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Germany, Greece, Hungary, Italy, Latvia, Lithuania, Netherlands, Portugal, Romania, Slovenia, Spain, Sweden)
• Connection request data published in some MS (Austria, Belgium, Croatia, Cyprus, Netherlands, Portugal, Romania, Slovenia, Spain)
• Capacity maps published with varying granularity — some show forecasted future saturation, not just current

Flexibility in DNDPs (§5.5.1 — most important section for wiki):

Current state: Only 4 EU countries have quantified flexibility needs in DNDPs: Denmark, Portugal, Slovenia, and Sweden — but Sweden specifies only one direction (not both upward and downward). All other three provide both directions. Portugal cited as most advanced: probabilistic analysis + cost-benefit comparing flexibility vs. reinforcement.

Required DNDP content for flexibility (ACER/CEER recommendation):

• Direction (upward or downward) of planned use
• Expected area/location and corresponding voltage levels
• Expected time of use (preferably hourly time-blocks; minimum yearly values)
• Expected contractual arrangements: market-based flexibility OR flexible connection agreements
• Competing alternative reinforcement solution and cost-effectiveness analysis

FNAM alignment: “DNDPs are the primary source of DSOs’ data and analyses” for the biennial FNA under FNAM. Tabell 15 (from FNAM Annex 2) is explicitly cited as the template DNDPs should comply with. This directly links to Source - FNA Bilagor I-V (2025-2026) which contains Tabell 15.

Cost methodology for permanent flexibility solutions:

• Costs of flexibility solutions AND the network alternative (including potential loss of revenue for generators with flexible connection agreements)
• Benefits of flexibility AND network alternative (including potential revenues for consumers providing flexibility)
• How uncertainties are accounted for

Project categories:

• Include smart grids, SCADA, digital twins, cybersecurity/ICT, reactive compensation devices, and where relevant, DSO-operated storage (without prejudice to Directive Art. 36)
• HV projects: full detail (description, location, technical spec, status, commissioning date, costs, progress update)
• MV: aggregated is sufficient; more detail adds value
• LV: aggregated
• Worksheet format recommended; unique project coding nationally standardized (already done in Denmark and Spain)
• Common project stage terminology aligned with TSO NDP planning stages

Sweden — consolidated picture from survey

Relevance to wiki

Directly informs: Distribution Network Development Plan, Flexibility Need Assessment, Villkorade Avtal, Ei, Network Code on Demand Response

Key new information vs prior wiki:

• Sweden confirmed as 1 of only 4 EU countries with quantified DNDP flexibility needs — but one direction only
• Tabell 15 (from FNA Bilagor) explicitly named as the FNAM-DNDP bridge template
• “DNDPs are the primary source of DSO data for FNA” — confirms and strengthens the three-way FNA-DNDP-NC DR linkage
• Flexible connection agreements listed as a contractual arrangement type DSOs must specify in DNDP flexibility sections
• Ei’s DNDP governance role documented: template, guidelines, central publication, monitoring planned
• Three-pillar planning framework as organizing concept for DNDP structure
• €50B/year distribution investment figure
• Portugal most advanced on DNDP flexibility quantification (benchmark for Sweden to learn from)