DSO Entity Reaction to Future-Proofing Electricity Bills (2026)

Source Updated 2026-09-26 Cited by 10 pages

Source details

Type: Report
Publisher: EU DSO Entity
Published: 2026-09-22
Pages: 21

EU DSO Entity’s reaction (dated 22 September 2026) to the Commission’s proposal on future-proofing electricity bills, COM(2026) 600. A 21-page position paper: a short summary, ten numbered recommendations, a detailed assessment per topic and an annex table. The DSO Entity describes itself as the legally mandated body of EU distribution system operators, established in June 2021 under the Electricity Regulation, representing more than 800 DSOs across all 27 Member States. Article numbers below are the proposal’s; the wording of each was checked against the proposal text on 2026-09-26.

Position in one paragraph

The DSO Entity welcomes the aims (lower bills, electrification, digitalisation) and three elements: recognition of anticipatory investment as a legitimate cost, EU guiding principles on cost-reflective tariff methodology, and the voluntary grid data exchange framework it would set up with ENTSO-E. Its central objection is that the proposal gives operators no secure basis to recover the investment that resilience, security and timely connections need, and that parts of it move national decisions into EU delegated and implementing acts. Its message: “Grid investment creates value now and lowers electricity commodity prices over time. Deferring it would only raise the cost later.”

The ten recommendations

#	Topic (article)	DSO Entity’s ask
1	Investment-oriented regulation (Art. 18(1), 18(2)(a),(c), 18(4))	Add timely and anticipatory grid development, resilience, security and digitalisation as cost-allowance objectives alongside cost-efficiency; write the “appropriate return on investment” and “sufficient investment” language of recitals 8 and 11 into the binding cost-reflectivity criterion in 18(2)(a); ensure state-fund payments (18(4)) do not cut DSOs’ regulated revenue and that DSOs bear no collection risk
2	Tariff principles (Art. 18(1)–(2), 61(5a))	Cost recovery and stable investment signals stay the core objective; add “simple” next to “transparency”; keep criteria (d), (e), (g), (h), (i); support EU guiding principles but oppose harmonisation by delegated or implementing act
3	Subsidiarity (Art. 61(5a))	Delete the delegated-act empowerment. Reasons: scope of “tariff methodology” undefined against a detailed Art. 18; encroaches on national regulators; DSO tariff design too diverse; legal uncertainty and litigation risk that investors price into the cost of capital
4	Definitions (Art. 18(2), 18(5), 61(5a))	One definition separating revenue regulation (allowed revenue), tariff methodology (allocation among users) and network charges (what each user pays); keep access, use-of-network and reinforcement charges distinct
5	Benchmarking (Art. 18(7))	Make DSO efficiency comparison optional and national (“may”); require enough DSOs for statistical robustness, de minimis thresholds and more than one method. Arguments: six Member States have a single DSO, Germany more than 800; some countries run five-year periods against the four-year cycle; results feed allowed revenue through X-factors
6	Smart grid indicators (Art. 18(2)(a), 18a(2)–(3), 61(5a))	Do not fold SGIs into efficiency benchmarking (technology adoption is not efficiency); delete the SGI implementing-act power; keep SGIs national under Art. 59(1)(l) of Directive 2019/944; send data from DSOs to regulators only, never directly to ACER; give the DSO Entity the same consultative role in the triennial ACER report (18a(3)) that it has in 18a(2)
7	Non-wire solutions in DNDPs (Art. 18a(1))	Delete the reference to Arts. 32 and 51 of Directive 2019/944, or replace “with priority” by “duly considered”. Reasons: DNDPs have a fixed five-to-ten-year horizon and a consultation process, and “priority” could favour non-wire over a cheaper wire option, contrary to Art. 18(2)(c)
8	Reporting duties (Art. 18(5)–(6), 18a(2))	Limit publication to what is necessary, proportionate and not already public; require an evidenced cost-benefit case. The paper notes the proposal itself admits added burden and that no impact assessment was carried out
9	Grid data (Art. 18a(4)–(5), 61(5b))	Align 18a(4) with the existing network codes (SO GL, RfG, DCC, “soon” NC DR), clarify Chapter III of the Data Act and ensure cost recovery; for the voluntary framework, allow more time than 12 months, clarify coordination with parallel EU initiatives and merge the 18a(5) framework and Art. 61(5b) implementing-act stages
10	Connection prioritisation (Art. 18d)	Delete it: it overlaps Member States’ competence under Art. 6 of Directive 2019/944, several are already legislating priority categories, and the Commission’s own connection-queue guidance already gives orientation. The real fix for queues is investment ahead of demand

Tariff design points that matter for flexibility

Implicit over explicit flexibility. The paper says network tariffs should mainly deliver implicit flexibility through price signals such as time-of-use tariffs, not reward participation in flexibility markets; explicit flexibility is better handled by market-based mechanisms, contracts and flexible connection agreements, “used alongside tariff design rather than as substitutes”.
Delete Art. 18(2)(k) and (n). (k), on integrating renewables through non-fossil flexibility, is said to duplicate 18(2)(c) and to risk inconsistency with the Network Code on Demand Response, the more specific instrument for demand-response facilitation. (n), on storage charges reflecting network benefits, should go because tariffs should stay cost-reflective and flexibility be paid through the relevant market, “clashing with the forthcoming” NC DR.
Locational signals through connection charges only. Reword 18(2)(f) to “provide locational investment signals through connection charges” and keep connection and use-of-network charges separate.
Special regimes. Delete the named user groups in Art. 18(3) (energy-intensive industries, data centres, energy communities): entitlement regardless of actual network impact could shift costs onto others.

Relevance to existing wiki topics

Swedish DSO Tariff Reform — Three Parallel Tracks (2025–2027) — a counter-position to the push in the Commission’s guidelines and Art. 18(2) for tariffs to reward flexibility; the paper takes no position on any Member State, and the vault holds no Swedish source on the harmonisation question.
DSO Connection Queue Reform — The Swedish Policy Response and Flexible Connection Agreements — the Art. 18d objection and its “invest ahead of demand” argument.
Distribution System Operator — the EU-level DSO voice on remuneration, benchmarking and reporting.
Digitalization and Smart Grid — the SGI and data-exchange objections.
Network Code on Demand Response — the paper’s overlap argument on 18(2)(k) and (n).

Limits of this source

An advocacy paper by the regulated industry’s own body: it states what DSOs want and why, and its factual claims (for example the counts of DSOs per Member State, or that some countries use five-year regulatory periods) are the paper’s own, not checked against other sources. No date for Parliament or Council handling appears in it.

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