DRESG 3rd Meeting (2026-10-06)

The agenda and slides of the 3rd meeting of the Demand Response European Stakeholder Group (DRESG), Tuesday 6 October 2026, 10:00-17:15 CET at ENTSO-E’s premises. The slides are ACER’s and the ENTSO-E/EU DSO Entity joint working group’s material for discussion, not endorsed positions. No minutes had been found by 8 October 2026. The European Commission’s update on the demand response network code was an oral item, so there is no text on the NC DR’s adoption status (Network Code on Demand Response).

Reading scope: the agenda and the barriers (TOP 3) and baselining (TOP 6) slides were read in full; the aggregation slides (TOP 5) through the stakeholder-feedback and classification slides; the congestion-management monitoring plan (TOP 7) and the data-exchange reference model (TOP 4) for their structure and key statements only.

Agenda

Opening and minutes; general updates (oral, including ACER’s decision on harmonising prequalification rules for balancing service providers); the NC DR (EC update, oral); monitoring of barriers to non-fossil flexibility (ACER); data exchange (ENTSO-E/DSO Entity joint working group’s reference model, and SolarPower Europe on fragmented national interoperability requirements, no slides published); aggregation models (ACER); baselining methods (ACER); monitoring of market-based procurement of congestion management (ACER).

TOP 3: barriers in the national FNAs (ACER)

• Coverage. “13 FNAs available, 15 missing” as of 14 September 2026 (CY, CZ, DK, HR, LT, LV, PL, PT, SE, SI, SK, EE, IE; a separate report is expected for Northern Ireland). The barrier chapters range from short qualitative descriptions to more detailed analysis; only three FNAs (SI, LT, PT) gave annexes with data covering almost all of ACER’s 24 indicators. ACER’s conclusion: the picture “lacks systematic, comparable overview of MS barriers on an equal basis” and an almost complete data collection is needed for many FNAs.
• Sweden’s flags in the preliminary overview (ACER calls it “preliminary, simplified high-level”, based only on the FNAs): legal provisions not fully implemented or not consistently interpreted (with CY, CZ, LT, IE); restrictive prequalification, i.e. aggregation and duration (with PT, HR); reliance on flexible connection agreements over local flexibility markets (with SI, HR, DK); administrative barriers to local market access (with IE); regulatory and tariff design that favours grid expansion (with DK, EE, HR, PL, SK, LT). Among additional barriers raised at member-state level: lack of technical or digital infrastructure for independent aggregation (SE), TSO-DSO governance and coordination gaps (EE, SE, SI), financial incentives through long-term contracts (SE, PL), and lack of liquidity and predictability of local flexibility markets (SE, SI).
• Timeline. ACER Recommendation on barrier reporting in March 2026; FNAs submitted July 2026; additional data collection by December 2026; ACER summary report of the FNAs in January 2027; ACER’s full report on flexibility needs and barriers, with data analysis, in July 2027.
• No quantitative need figures appear in these slides. The “preliminary FNA results” in the lead cover the barrier sections only.

TOP 4: reference model for data exchange (ENTSO-E/DSO Entity joint working group)

The proposed implementing regulation on data interoperability for demand response derives from Art. 24 of Directive 2019/944. It sets a reference model of roles, information flows (procedures) and minimum information objects, with an obligation on member states to map their own models against it; the mapping is to be published in a repository kept by the DSO Entity and ENTSO-E.

TOP 5 and 6: ACER’s monitoring of aggregation models and baselining

• Process. On 3 August ACER sent DRESG a confidential first draft; seven members gave feedback (EUROPEX, All NEMO Committee, Eurelectric, ESMIG, SmartEn, EU DSO Entity, ENTSO-E). The slides list each comment and ACER’s response.
• Aggregation. The draft’s classification of models (integrated, split supply, independent with or without correction and central settlement) drew many corrections for individual countries, and comments that counting implementations says little without data on actual use. ESMIG: a device that qualifies as a demand-management device for flexibility should not automatically count as equivalent to a utility-grade meter for supply or settlement.
• Baselining: why a baseline is needed. ACER proposes to state that, in the market participant to system operator relationship, a baseline is needed mainly for two purposes: (1) imbalance settlement, to allocate responsibility between balance responsible parties at the same metering point, and (2) service settlement, where the activated volume is based on metered values. It is particularly relevant for aggregators without a supplier agreement where an imbalance correction applies, and for any metered service provision; where an aggregator and supplier have an agreement, the need depends on the agreement’s scope.
• Market schedules as baselines. ACER argues that day-ahead and intraday market schedules are an appropriate baseline for balancing and other post-market actions because they reflect the committed commercial position, are less open to manipulation than physical schedules, are comparable across technologies and fit imbalance settlement. For conventional generation a physical schedule may be workable, but for demand response, whose behaviour is more variable, physical schedules “would be inappropriate and could deter participation”. In the report, market schedules are not a separate baselining method; they may count as declarative baselines in the integrated model and where supplier and aggregator agree to share them.
• “Declarative” baselines. ACER’s working definition: the market participant decides the calculation method or the data forming the baseline given to the system operator; it asks whether “subjective forecast of the activation event” is clearer, contrasting methods where method and data are agreed with the system operator so that anyone can verify the result.
• Four stages where a baseline or meter data may be used (ENTSO-E’s framing): at prequalification, at bidding, during delivery, and to validate delivery.
• Sweden and the Nordics. SmartEn notes that only Norway shows six baselining methods although Sweden, Belgium and Finland have the same methods through the same platform (NODES), and that only Norway and Finland reported declarative methods for DSO congestion management; ACER says it is checking with the regulators. ENTSO-E says the Swedish entry is incorrect in that all methods are marked as pilot while some are now business as usual and some pilots have ended, to be checked with Ei. Eurelectric asks that Finland’s “full freedom to choose” a baselining method be qualified as subject to approval.

TOP 7: monitoring market-based procurement of congestion management

The monitoring runs one focus topic per year: aggregation models (2025-2026), market-based congestion management (2026-2027) and prequalification (2027-2028, postponed because prequalification of standard balancing products is already under discussion with the TSOs). For the congestion-management topic the plan is a questionnaire for national regulators, then ACER’s processing and DRESG input on cases and good practice, and a report endorsed and published in September-December, with the slide giving months but not the year (implied 2027).

Relevance to existing wiki topics

• Baseline Methods — ACER’s two-purpose framing, the market-schedule and declarative definitions
• Flexibility Need Assessment — Sweden’s FNA among the 13 ACER holds, and the ACER reporting timeline to July 2027
• Aggregation — ACER’s reading of aggregation models and what remains disputed
• NC DR Implementation in Sweden — What Changes and for Whom — the data-exchange reference model and the monitoring that precedes the code