Energiavirasto Finnish FNA Process Documents (2025-2026)

The four public documents that set out how Finland runs its first national Flexibility Need Assessment (FNA): Energiavirasto’s launch notice (29 Oct 2025), its reporting guidance for network operators (final version 4 Dec 2025, published 9 Dec 2025), its FAQ (published 17 Dec 2025, PDF version 12 Feb 2026) and Fingrid’s presentation to its grid committee (4 Dec 2025). All are in Finnish. They describe the process, not results; the draft report itself is not public (see Source - Energiateollisuus Statement on Draft Finnish FNA Report (2026) for what is known of it).

Reading scope: the three Energiavirasto documents were read in full. Of the 68-page Fingrid committee deck, only the FNA slides were read; the rest covers unrelated agenda items.

Key findings

• Roles. Fingrid (the TSO) is being designated as the body that compiles the national FNA report, assesses system-level needs and analyses transmission-grid needs. Distribution network operators assess needs in their own networks and send them to Fingrid; Energiavirasto approves the final report and forwards it to ACER and the Commission. (Launch notice; guidance, p. 1)
• Scope. Study years 2030 and 2035; system-level needs assessed on ERAA 2024, using DSO data and analyses built on their development plans (guidance, pp. 1-2). The report also covers barriers to using flexibility and digitalisation (Art. 15 of the methodology).
• Timeline. Nov 2025 scope and data agreed; DSOs report to Fingrid at 1 Apr 2026 (preliminary) and 25 May 2026 (final); Fingrid submits to Energiavirasto by 25 Jul 2026; Energiavirasto may require corrections before approval (guidance, p. 2). The launch notice states “July 2026” for completion and approval. The assessment repeats every two years: the next cycle starts July 2027 and the report is ready in summer 2028 (launch notice).
• Baseline: the development plan, not today’s grid. DSOs base their assessment primarily on the latest kehittämissuunnitelma (KESU, the Finnish network development plan), which for this round means the 2026 KESU draft, even though it had not yet been through consultation. The FAQ states the baseline is neither “current grid capacity” nor “no investments”; it is the future picture in the KESU, in which flexibility services are already one of the development solutions to consider (FAQ 2.2, 3.1). Deviating assumptions need agreement with Fingrid and, where needed, Energiavirasto (methodology Art. 6(7)).
• What DSOs report. Local needs from overload and voltage problems, up and down, as MW and, where possible, MWh, either for representative days or time blocks or as annual totals; location and voltage-level detail is voluntary. Qualitative reporting is allowed where quantification is not possible, but qualitative input is then not used in Fingrid’s fine-tuning. DSOs must also estimate how much of their down-regulation need stems from curtailment of renewable generation. Needs arising from N-1 or security-of-supply obligations may be reported as a separate class (FAQ 5.2, 6.1-6.3, 7.1). Data go to Fingrid by e-mail in an Excel template (guidance, p. 2).
• Exclusions and confidentiality. Rationing under the preparedness act is authority-directed load management, not market-based flexibility, and is not normally mixed into the FNA (FAQ 6.5). Results in the national report are always aggregated so that no company or customer can be identified (FAQ 9.1).
• Barriers (Art. 15). TSO and DSOs report where they see barriers: hard market access for new or small actors, missing incentives, requirements that restrict reserve participation, conditions that block flexibility in congestion management, complex or slow administrative procedures, and insufficient regulatory incentives for network operators to consider flexibility as an alternative to reinforcement (FAQ 8.1).
• Cost treatment. FNA work is a statutory duty; its costs fall under the efficiency incentive in network regulation with no separate compensation, and the flexibility incentive in the regulatory methods covers only concrete flexibility solutions, not FNA reporting (FAQ 10.1).
• What FNA feeds. The results are the basis of national non-fossil flexibility objectives, i.e. how much flexibility should come from demand response and storage; if market investment falls short, states may introduce non-fossil flexibility support schemes. They also support updating the national energy and climate plan (launch notice). Fingrid’s deck adds that Fingrid was in 2025 already running an analysis “according to the method” for the Ministry of Economic Affairs and Employment (TEM) in support of state-aid treatment of a non-fossil flexibility support mechanism.
• Consultation on the guidance. The draft guidance was consulted on 13-20 Nov 2025 with a webinar on 25 Nov 2025; revisions extended deadlines and clarified that the DSO assessment rests primarily on the latest development plan (guidance notice).

Date discrepancy to be aware of

The launch notice gives ACER’s approval of the methodology as 28 Jul 2025. The guidance document and Fingrid’s deck both give 25 Jul 2025, which is the date used in Source - ACER Decision 05-2025 FNAM Annex I (2025). This wiki uses 25 July 2025.

Relevance to existing wiki topics

• Flexibility Need Assessment — the Finnish first cycle compared with Sweden’s: TSO-led compilation, a development-plan baseline and MWh reporting where Sweden deferred MWh to FNA 2028
• Electricity Market Design Reform 2024 — Art. 19e national implementation, and the Art. 19f non-fossil flexibility objectives that FNA results feed
• TSO-DSO Coordination — The Central Design Problem — Fingrid compiling DSO needs in a single national report
• Source - Svk FNA 2026 Slutrapport (2026) — Sweden’s published counterpart