CEER Grid Connection Challenges (2026)

CEER Paper on Grid Connection Challenges — Ref: C25-DS-100-06, published 24 June 2026 by CEER’s Distribution Working Group. Follows up on the 2023 CEER Alternative Connection Agreements paper with a focus on queue management and flexible connection agreements (FCAs), based on a CEER survey of NRAs/DSOs circulated June–July 2025 (“Grid connection challenges deliverable survey”).

Structure

Two-part paper: (1) a taxonomy of grid connection queue management allocation procedures and complementary anti-hoarding measures, and (2) a national-implementation survey of FCAs under Article 6a of the Electricity Directive, with three country case studies in Annex 2.

Queue management — allocation procedures taxonomy

• First-come, first-served — date of complete application determines order; risk of a single early applicant blocking all capacity
• First-ready, first-served — proven project maturity by a given date determines allocation, not submission date; discourages speculative applications
• Auction — capacity auctioned
• Repartition — pooled capacity divided pro rata/pro capita among applicants; may under-allocate vs. requested capacity to avoid overdimensioning
• Gradual — capacity granted incrementally as milestone criteria are met
• Priority lists — specific project categories (social benefit, congestion-reducing, renewables, maturity) expedited; CEER flags this as in tension with non-discrimination principles despite practical value
• Combinations of the above are common where national law allows

Complementary anti-hoarding measures (used alongside an allocation procedure): limited reservation time/deadlines (with possible extension and reservation fee/bond), use-it-or-lose-it (capacity reclaimed after a period of non-use, e.g. 12 months), security deposits/financial guarantees, annual fees/penalty payments for unused contracted capacity, maturity assessments.

Survey finding: first-come-first-served remains the dominant approach across CEER member states; some countries (not “most”) have additionally layered on auctions, tenders, security deposits, or priority lists, especially in high-demand areas. Priority-list categories named in the raw survey include contribution to national security, alongside congestion-reduction, maturity, and renewables.

FCA national implementation survey

• Confirms the EU legal definition and Art. 6a’s three framework requirements (the raw text quotes the FCA legal definition via a footnote but does not itself cite a specific “Art. 2(24c)” article number — that pinpoint citation is not traceable to this raw source and needs independent verification): (a) FCAs as a rule must not delay reinforcement, (b) automatic flex→firm conversion once the network is developed, (c) FCAs may be a permanent solution where the NRA deems reinforcement not the most efficient solution.
• Of 15 surveyed countries with FCAs, network charge treatment (per ACER’s March 2025 Network Tariff Report, cited here): 5 give use-of-network tariff discounts (AT, BE, DK, DE, NL); 3 give reduced connection charges (DK, EE, NO); 3 give no tariff discount at all (FI, FR, PT).
• National FCA matrix (by user type — DSO/TSO, all users, storage, consumers, producers — and limitation type: permanent/non-permanent, static/dynamic) covers DE, ES, FR, PT, HU, LV, NO, IT, NL, CZ, IE, EE, SI among respondents. More countries have implemented FCAs for demand and storage than for generation.
• Limitations can be expressed as a percentage of annual generation/demand, a time basis (e.g. ≤876 hours/10% of a year), fully or partially, and as static / partly dynamic / fully dynamic. CEER also identifies fully flexible FCAs (day-ahead network-availability-determined) and time-window FCAs.
• Discusses interaction with market-based flexibility: dynamic, near-real-time FCA curtailment can operationally resemble congestion management, but the contractual basis (connection agreement vs. market-based service contract) remains distinct for regulatory classification and Art. 32 compliance purposes.

Case studies (Annex 2)

Spain — Royal Decree-Law 7/2026 (adopted 20 Mar 2026, in force 21 Mar 2026): enacted in response to the Middle East crisis’s economic/energy impacts; introduces monthly reservation fees for demand-installation access/connection permit holders (3-month initial exemption; non-payment triggers automatic permit expiry; fee is an advance payment of network tariffs, non-refundable if rights are forfeited); priority queues for “high-priority” demand installations (suspends competing applications at the same node); automatic lapse of rights on missed milestones, with judicial-injunction suspension of milestone deadlines.

Spain — Circular 1/2024 + Feb 2026 consultation: introduces FCAs as a queue-management tool; defines flexible network access for demand as a situation where supply guarantee is not met at all hours. Feb 2026 draft resolution proposes four FCA types: Type 0 (time-window consumption only), Type 1 (contingency disconnection, >36 kV, N met but not N-1, expected availability above 90%, DSO remote disconnect), Type 2 (active network management, real-time DSO curtailment instructions), Type 3 (transmission-connected demand, immediate reduction on SO instruction).

Finland — Energiavirasto regulation (Määräys 3510/000002/2025): in force 22 Jan 2026, applies to FCA contracts from 1 Feb 2026, under the Electricity Market Act (588/2013). Distinguishes temporary FCAs (Section 20b — no permit needed, must not delay reinforcement) from permanent FCAs (Section 20c — permit required from Energiavirasto, only where network development is determined not the most efficient solution network-wide; permit specifies the binding network constraint). Permanent FCAs require genuine, voluntary consent — not voluntary if no alternative connection option is offered. Energiavirasto may revoke/adjust permits if underlying conditions change. No official boundary yet established between flexibility services and flexible connections in Finnish law.

⚠ Second discrepancy: this CEER paper’s own text vs. the actual EU legislative proposal

This raw source states twice, unambiguously, that the Directive Proposal component of the European Grids Package “amends the current Article 17 of the Electricity Directive” and references “Article 6a of Directive (EU) 2019/944.” Taken at face value, that would mean Article 17 of the Electricity Directive (2019/944), not RED III.

However, checking the actual primary legislative text — Raw/Clippings/EUR-Lex - 52025PC1007 - EN.md, the Commission’s own proposal — directly contradicts this: Art. 1(10) states “Articles 17 of Directive (EU) 2018/2001 is amended to consolidate all provision on grid connection, expand their scope and introduce clear rules regarding the procedures for grid connection permits…” — i.e. Article 17 of RED III (Directive (EU) 2018/2001), confirmed also on Source - European Grids Package COM2025-1005 (which cites the proposal directly). The Electricity Directive amendments in this same proposal instead target Article 8 (permitting procedure for grid infrastructure) and introduce Articles 8a and 40a — not Article 17.

This CEER paper’s own text therefore appears to misstate which directive Article 17 belongs to — a case where the raw source being summarized is itself inaccurate relative to the primary legislative text it describes. Rather than “correct” this page to match either the CEER paper’s wording or the primary legislative text without flagging the conflict (as two prior edit passes on this page have each done, in opposite directions), this is now flagged explicitly: treat Source - European Grids Package COM2025-1005 — which cites the proposal text directly — as authoritative on which directive Article 17 belongs to; treat this CEER paper only as a (seemingly imprecise) secondary description.

Per the raw legislative text (Art. 17(3), as reproduced on the European Grids Package source page), where grid capacity is insufficient, the system operator shall, on justified grounds of safety concerns or technical incompatibility of the system components, propose an alternative grid connection point, an alternative provisional date for the grid connection, or — if not possible — reject the connection request. This “shall” is the headline change: the proposal tightens Art. 6a of the Electricity Directive (which the RED III Art. 17 procedure cross-references for the flexible-connection-agreement offer) from a discretionary NRA-framework provision toward a mandatory per-application offer obligation. Status: in co-legislator process (Parliament/Council) as of this paper’s publication — no adoption timeline yet.

Date discrepancy with existing wiki content — resolved 2026-09-23

This paper states (Ch. 2.2, p.17) that “Article 6a … the transposition deadline of which passed on 17 January 2025.” An earlier version of this note flagged that as conflicting with the wiki’s then-stated 17 July 2026 date and provisionally retained 17 July 2026 as authoritative. That was backwards: 17 July 2026 applies only to Art. 4 and Art. 15a (energy sharing) under Art. 3(1) of Directive (EU) 2024/1711 — Art. 6a follows the Directive’s general 17 January 2025 transposition deadline. This CEER paper’s statement is correct. See Source - Electricity Market Design Reform Directive (EU 2024-1711) (corrected 2026-09-20/23) and Source - Prop. 2025-26-16 Forbattrad utformning av EUs elmarknad (2025) (confirms energy sharing/Art. 15a alone carries the 17 July 2026 deadline).

Relevance to existing wiki

• Flexible Connection Agreements — adds EU-wide survey data (network charge discounts, FCA type taxonomy, design choices) and the Spain/Finland case studies as concrete national implementations alongside Sweden’s villkorade avtal
• DSO Connection Queue Reform — The Swedish Policy Response — the CEER allocation-procedure taxonomy is the general EU framework that Sweden’s anvisningssystem/mognadsgrad reforms sit within; adds the Art. 17 mandatory-FCA-offer proposal as a new EU-level development since the European Grids Package’s initial December 2025 publication
• Source - European Grids Package COM2025-1005 — this paper is a direct sequel covering the Art. 17 amendment in the package’s Directive Proposal component in more detail than the original package source page
• Congestion Management — queue management and FCA interaction with market-based congestion management