Ei R2025-08 Klimatprestanda och Flexibla Resurser (2025)

Information om klimatprestanda och flexibla resurser — Förslag till genomförande av artikel 20a i det reviderade förnybartdirektivet. Ei report R2025:08, Eskilstuna, March 2025. Authors: Johan Anderson (projektledare), Anna Carlén, Rebecka Fischer, Linn Sjöström.

Bibliographic details and mandate

Ei received a government commission on 26 September 2024 (ärendenummer KN2024/01854) to prepare proposals for implementing Article 20a.1 and 20a.2 of the revised Renewable Energy Directive — Directive (EU) 2023/2413, which amended Directive (EU) 2018/2001 (RED II). The commission was due 31 March 2025; Ei calls the amended directive “det reviderade förnybartdirektivet” throughout. Article 20a itself enters into force on 21 May 2025, but Sweden’s implementing legislation (via the separate promemoria Förbättrad utformning av EU:s elmarknad) was only proposed to enter into force 1 November 2025 — i.e. already expected to be late against the EU deadline.

What Article 20a requires

• 20a.1: TSOs (transmission system operators) — and DSOs too, if the data is available to them — must make available, per bidding zone (elområde), the share of renewable electricity and the greenhouse-gas emissions associated with delivered electricity, as precisely as possible at an interval matching settlement frequency but at most hourly, including forecasts where available. Member states must also incentivize smart-grid upgrades so grid balance can be better monitored and real-time data made available.
• 20a.1, second paragraph: if technically possible, DSOs must additionally make available anonymized, aggregated data on (a) the potential for demand-side flexibility in their grid, and (b) renewable electricity fed in by self-consumers (egenanvändare) and renewable energy communities (energigemenskaper).
• 20a.2: all this data must be published digitally in an interoperable way, using harmonized data formats and standardized datasets, usable by market actors, aggregators, consumers and end users, and readable via smart metering systems, EV charge points, heating/cooling systems and building energy management systems.

Ei’s central legal proposal

A new 3 kap. 48a § ellagen (1997:857) — a bemyndigande (delegation) letting the government or an appointed authority (Ei) issue föreskrifter requiring nätföretag to make available: (1) renewable share of delivered electricity, (2) associated GHG emissions, (3) forecasts of (1)–(2), (4) demand-flexibility potential, and (5) renewable electricity produced and fed into the grid. New 26a–26d §§ are proposed in förordning (2022:585) om elnätsverksamhet to flesh this out: 26a assigns TSOs (Svenska kraftnät) responsibility for calculating renewable-share/GHG-emissions data per bidding zone; 26b requires DSOs to link to that TSO-published data and to publish anonymized/aggregated flexibility-potential data for their own grid; 26c sets a standardized digital format requirement; 26d gives Ei authority to issue further detailed förescrifter on calculation, timing, interval and format.

The key distinction: two different “technically infeasible” findings, not one

The report draws a sharp line between two separate DSO-facing obligations under 20a.1’s second paragraph — only one of which Ei found infeasible:

• NOT technically feasible (deferred): DSOs publishing data on renewable electricity fed in by self-consumers and energy communities. Sweden has no metering-data hub (mätdatahubb), and Swedish smart meters’ customer interfaces aren’t connected to DSOs’ own metering-data systems (they exist only for the customer’s own equipment to pull near-real-time readings). Meeting this requirement would mean replacing meters, redesigning DSO data systems, or building a data hub — all estimated to cost several billion SEK and unrealistic to have in place before the transposition deadline. Ei therefore proposes no specific requirement for this piece — only the general information duty written into 3 kap. 48a § point 5 of the law, to be filled in by future föreskrifter once/if it becomes technically feasible (e.g. if a national data hub is built).
• Found technically feasible (an actual proposal): DSOs publishing anonymized, aggregated data on installations with demand-flexibility potential — explicitly not based on real-time or historical measurement data, but on installation records (anläggningsuppgifter) DSOs already hold, such as the battery-storage capacity data DSOs have been required to report to Ei since 2024 under EIFS 2022:5 (rapportering om utvecklingen av smarta elnät). Ei proposes an actual, live requirement for this (26b § point 2), to be detailed further via föreskrifter (which installation types qualify is left to that later work), published via DSO websites.

This means a claim that “Ei found publishing demand-flexibility-potential data technically infeasible” is incorrect — that finding applies only to the self-consumer/energy-community renewable-injection data, a different data category entirely. The flexibility-potential-publication requirement is one of this report’s actual, affirmative proposals, not something deferred pending feasibility.

Renewable-share/GHG data: who calculates it and how

• Cannot be based on ursprungsgarantier (guarantees of origin): these are allocated/cancelled annually, in 1 MWh standard units — far too coarse for the sub-hourly precision Article 20a.1 requires.
• DSOs (region- and lokalnätsföretag) only have metering data for installations connected within their own concession area, so they can’t calculate a bidding-zone-wide renewable share themselves. Only Svenska kraftnät has the necessary data (reported via eSett for balansavräkning, production/consumption plans, and data already reported to Entso-E’s transparency platform), so Ei assigns Svk sole responsibility for the calculation. DSOs need only link to Svk’s published data from their own websites.
• Svk already publishes related data via Kontrollrummet (production-type breakdown, corrected for “dold produktion” — unmetered production/consumption outside the concessioned grid, estimated at ~350–400 MW as of December 2014) and via the Mimer balance-settlement platform.
• Entso-E plans to establish a working group under its market committee to develop an EU-common calculation methodology; a decision on establishing the group was expected spring 2025 (per Svk, as relayed to Ei). If no EU-common solution emerges, Svk would need to develop its own method under Ei’s föreskrifter.
• Ei expects data to be published via websites (an Excel file or an open-source API on Svk’s site are floated as options) rather than via smart-meter customer interfaces (Swedish meters have no such technical capability) or a data hub (Sweden has none).

Why Ei judges the underlying benefit limited

Ei repeatedly notes that because Sweden’s electricity mix is already highly renewable and low-carbon with relatively low hour-to-hour variation, the renewable-share/GHG information itself is expected to have limited practical effect — the electricity price is already the dominant signal steering consumption toward high-renewable, low-price hours, so the new information mostly adds a second, weaker signal on top of an existing one. This judgment doesn’t extend to the flexibility-potential-publication piece, which Ei frames as useful for DSOs/energitjänsteföretag to identify where flexible resources exist and target services accordingly.

Smart-grid incentives (Article 20a.1’s incentive requirement)

Ei concludes the existing revenue-cap regulation (intäktsramsreglering) already gives adequate incentives — via its two existing sub-incentives (reduced grid losses, and jämn belastning mot överliggande nät) plus the quality incentive on leveranssäkerhet — once the 5 kap. ellagen replacement proposed in SOU 2023:64 (Ett förändrat regelverk för framtidens el- och gasnät) is enacted, since that reform would let Ei add a broader incentive to minimize total costs (not just capital costs), which indirectly favors smart-grid solutions over pure capex. Ei considered and rejected adding a new, dedicated smart-grid-specific incentive to ellagen, reasoning that a single-purpose incentive risks favoring particular technical solutions over others that could integrate renewables just as effectively, and that regulation should stay technology-neutral.

Costs (consequence analysis)

• Svenska kraftnät: development cost for calculation/publication systems estimated at 130,000–5,000,000 SEK (low end = one engineer’s part-time participation in an Entso-E working group for ~1 year; high end = building fully automated in-house systems and an API), plus ongoing maintenance of roughly 250,000 SEK/year if no EU-common solution emerges. Funded via statlig anslag (Ei recommends against tariff-funding, since this serves renewable-energy promotion, not core nätverksamhet), plus a proposed 5 million SEK appropriation increase for Svk.
• Ei: absorbed within existing budget; the föreskrifter drafting work is estimated at roughly half a full-time-equivalent (~0.6 million SEK).
• DSOs (170 region- and lokalnätsföretag total; 3 companies have ~800,000 uttagsabonnemang each, 7 more have 100,000–300,000, together >3.3 million; the ten smallest have <7,000 combined; mean ~36,000, median ~11,000 per company): linking to Svk’s renewable-share data — a one-time link added to the company website by a communicator, estimated at ~2,500 SEK per company. Publishing flexibility-potential data — same ~2,500 SEK if simply linking to a page Ei might publish centrally instead, or up to ~30,000 SEK/company/year if the DSO must publish and monthly-update the data on its own site (this alternative is not decided; Ei may end up centralizing DSO flexibility-potential publication itself).
• Households/consumers: no direct costs; costs pass through via tax/nätavgift, estimated at under 50 öre per taxpayer (Sweden has just over 10 million taxpayers).
• Energitjänsteföretag: no costs — using the published data is optional.
• No-implementation risk: EU infringement proceedings and potential fines; Ei cites Sweden’s actual 5-year-late transposition of the EU weapons directive as a reference point — an €8.5 million fine plus legal costs, with the Commission having sought a daily penalty of roughly €50,000/day pending compliance.

Consultation (samråd)

Ei consulted mainly with Svenska kraftnät and, to a lesser extent, Energimyndigheten, plus one energitjänsteföretag, and invited written comments on preliminary conclusions. Most feedback concerned the DSO flexibility-potential-publication requirement specifically: concerns that data collection would need a different method than today’s, that customer privacy/integrity issues would arise, and that data quality would be weaker for small customers. Ei did not specify in this report exactly which data must be published — that is left to the future föreskrifter work. Companies were otherwise broadly positive about Ei’s proposed regulatory design.

Relevance to wiki topics

Data gaps

• Which installation types will qualify for the DSO flexibility-potential-publication requirement is left to future föreskrifter — not yet resolved as of this report
• Whether Entso-E’s working group on EU-common renewable-share/GHG calculation methodology was actually established in spring 2025 as expected is unconfirmed
• Whether DSO flexibility-potential data ends up centrally published by Ei or individually by each DSO (the cost estimate leaves both alternatives open) is unresolved