Source - Ei Ställningstaganden Anslutningsprocessen (Ei2025-02 till 05)

Ei’s ställningstaganden (position statements) on the connection process — Ei2025:02, 03, 04, and 05. Published as part of Ei’s new ställningstaganden series (introduced 2025) to clarify how Ei interprets and applies the regulatory framework. All four documents address different aspects of how DSOs must handle connection obligations and the financing of grid extensions.

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Ei2025:02 — Anslutningsprocessen (the connection process)

Core statement: DSOs have a duty to connect on objective, non-discriminatory, reasonable terms within a maximum of two years (4 kap. 1 §, 4 kap. 5 § ellagen). When a connection takes longer, the DSO must have evaluated all tools at its disposal — including flexible resources as alternatives or supplements to grid expansion.

Ei will check flexible resources in prövning: If a customer appeals to Ei under 4 kap. 13 § ellagen that their connection time is unreasonably long, Ei states it will verify that the DSO has investigated whether flexible resources could free up grid capacity to enable a faster connection. This is a direct enforcement signal: Ei treats the flexibility assessment (4 kap. 2 § ellagen — flexibility and demand response as alternatives to reinforcement) as a prerequisite for justifying connection delays. Citing the government proposition (prop. 2021/22:153), Ei notes that DSOs should generally not cite capacity shortage as grounds for refusing a connection if the shortage can be addressed by flexibility without building new lines.

Standardized routines for all installation types: Current law requires standardized connection routines for electricity production facilities and energy storage. Ei asserts that all electrical installations should be covered by standardized routines — not just production/storage. Ei has proposed regulatory amendments to this effect and encourages DSOs to implement and publicly disclose standardized routines for all types now, without waiting for legislation.

Connection timeline: DSOs must provide connection timelines for production facilities (4 kap. 8 § ellagen). Ei has proposed extending this obligation to all facility types. DSOs are encouraged to provide timelines for all connection types immediately.

Mognadsgrad (maturity grade): Ei endorses use of mognadsgrad (project maturity assessment, as developed by Svk and Energiföretagen) as a queue management tool. DSOs using mognadsgrad must ensure non-discrimination. Connection agreements must be updated if contracted capacity is incorrectly stated.

Active management of applications: DSOs must actively manage all pending applications against the submitted timeline. This includes dialogue on updated project status, revised capacity needs, and load profile matching — enabling the DSO to identify positive aggregation effects and accommodate more customers within existing capacity.

Ei2025:03 — Bygga på prognos (build on forecasts)

Core statement: Proactive (anticipatory) grid investment is a legal obligation, not a discretionary option.

The legal basis is the combination of:

• 3 kap. 1 § ellagen — DSOs must ensure the grid is operated efficiently, safely, and reliably
• 4 kap. 1 § ellagen — connection obligation
• 4 kap. 5 § ellagen — connection within a reasonable time (max two years)

Together, these require DSOs to plan for foreseeable future needs — not just to react to individual connection applications. A DSO that waits for formal applications before investing in grid capacity may fail to meet the two-year connection obligation as applications arrive.

DNDP is the vehicle: Network development plans (nätutvecklingsplaner) are the mechanism through which anticipatory planning is operationalized. DSOs must forecast capacity needs and incorporate anticipated future demand into investment decisions. The DNDP obligation flows from the same statutory chain that underpins anticipatory investment.

Cost recovery conditionality: Capital expenditure is included in the capital base only if the asset is “used” by the DSO during the supervisory period (Förordning (2018:1520) om intäktsram för elnätsverksamhet, 2 § and 6 §). An asset built ahead of demand that has not yet entered service is not included until it is used. This creates tension between anticipatory investment (build early) and capital base inclusion (only recover costs when in service).

5 kap. 7 § as safety valve: Ei acknowledges the cost recovery risk for genuinely anticipatory investments and notes that 5 kap. 7 § ellagen provides a skälighetsbedömning (reasonableness assessment) mechanism through which Ei can allow inclusion in the capital base even before full use, if circumstances justify it. This is the escape valve for investments that are clearly needed but where customer demand has not yet fully materialized at the time of Ei review.

Ei2025:04 — Finansiering av elnätsutbyggnad (external financing)

Core statement: There are no regulatory barriers to an external party (such as a connecting customer) financing, or purchasing on behalf of, grid components needed for an electricity grid extension — even before a connection agreement has been signed or a concession application resolved.

The question this addresses: can a connecting customer pre-purchase grid equipment (transformers, cables, switchgear) during the long lead-time period before formal network concession and connection agreement are in place, to shorten the build phase?

Ei’s position: Nothing in the existing regulatory framework prohibits this. Practical questions (who obtains better prices, contractual structure between parties) are for the parties to resolve.

Capital base reporting under EIFS 2023:4: When the DSO and a connecting party agree that the latter has financed a grid asset, the asset must be entered into the capital base at commissioning with a rådighet (stewardship/ownership indicator) reflecting the actual ownership structure:

• Ägd (owned): DSO fully owns the asset → 100% in capital base as owned
• Hyrd (leased): External party owns the asset, DSO uses it → entered as leased; running lease costs (excl. O&M) separately reported as löpande kostnader
• Partial ownership: split between owned and leased portions, each entered proportionally

Only assets actually used by the DSO (nätkoncessionshavaren) during the supervisory period may be included. An externally financed asset that is never transferred to the DSO’s operational control cannot appear in the capital base.

Ei2025:05 — Hänvisning till underliggande nät (referral to lower grid level)

Core statement: A grid operator (DSO or TSO) may refer a connection application to a lower grid level if there are special reasons (4 kap. 2 § ellagen). However, Ei recommends that applicants first apply to the lowest suitable grid level — referrals are permitted rather than required.

Legal context: Under 4 kap. 3 § ellagen, a regional or transmission grid may only connect a facility if the local grid owner consents, or if Ei grants permission. This protects the local grid’s area concession monopoly. However, once local grid consent is given, the customer may apply to either the regional or transmission level directly — there is no corresponding requirement for regional grid consent before applying to the transmission level.

Transmission cannot automatically refuse: Svenska kraftnät‘s transmission grid can become obligated to connect a customer who never applied to the regional grid, under the general connection obligation (4 kap. 1 § ellagen). Svk cannot automatically redirect such applicants to the regional grid without a specific justification.

Special reasons for referral: A TSO or regional DSO can refer downward if accepting the connection would create inefficiency or adversely affect operational safety (3 kap. 1 § ellagen). These reasons must be stated and can be reviewed by Ei in case of dispute.

Concession and connection prövning are separate: Ei’s concession assessment (nätkoncessionsprövning) does not include the question of which grid level the applicant should connect to. Connection prövning and concession prövning are parallel processes.

Ei’s recommendation — apply first to lowest suitable level: While not legally required, Ei recommends that applicants apply to the lowest suitable voltage level first and have applications reviewed in hierarchical order. This maximizes utilization of existing infrastructure and reduces inefficient investment.

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