Energiföretagen Energigemenskaper och Energidelning Position (2025)

Summary

Energiföretagen’s (the Swedish DSO/utility trade association) standing industry position on energy communities and energy sharing. Published 26 September 2025 — before the Commission’s C(2026)2850 Recommendation (30 April 2026) and before Prop. 2025/26:240’s energidelning rules — so this is not a formal Swedish response to either, but it is the clearest public industry stance found on the same substantive terrain: how sharing should be taxed, who pays network fees, and what regulatory gaps remain. Overlaps with, and gives institutional (trade-association) backing to, the tax-avoidance critique raised individually by Per Everhill (Tekniska verken) in Source - Second Opinion Parallella Nät Skatt (2026).

Key claims

Overall stance: Positive toward energy communities/sharing where they reduce total energy use and peak-load demand, and can boost customer engagement — but conditional on a “helhetsperspektiv” (whole-system view) and on not creating unfairness for the broader customer collective (kundkollektivet).

Generella synpunkter (both energy communities and energy sharing):

• No energy-tax exemption: Energiskatt on electricity is a consumption tax tied to volume withdrawn from the concession grid, not to how the electricity was produced or the commercial relationship behind it. Energiföretagen opposes tax exemption as a way to stimulate energy communities — it would work against Sweden’s EU energy-efficiency savings obligation and lacks a socioeconomic rationale for narrowing the tax base. Energiföretagen supports the Electricity Market Directive’s framing that shared energy should carry the same tax/fees as electricity bought from a supplier.
• Everyone who uses the grid pays a network fee: both physical energy-community members and virtual energy-sharing participants should pay nätavgift reflecting infrastructure use; any grid benefit the community provides should also be valued and compensated. Also says the public-law fees (elberedskap, nätövervakning, elsäkerhet) should be paid by the whole customer collective, and notes that users within an IKN network today pay only one such fee regardless of the number of actual users, which it says can be questioned. Grid companies should also be able to charge for administering virtual sharing.
• Customer protection framework needed: deeper analysis of contract terms and consumer protection is required — e.g., what obligations the community/sharing arrangement owes members vs. the electricity/grid company, and exit rights. Flags that two consumers sharing electricity between themselves are not protected by consumer-protection legislation vis-à-vis each other (no statutory notice period, no ångerrätt, information asymmetry, risk if agreed production volumes aren’t met) — and that neither the supplier nor the grid company can be expected to resolve such disputes.
• Avoid parallel infrastructure: where existing grid infrastructure already exists, virtual sharing should be considered as an alternative to building new physical cabling.

Physical energy communities specifically:

• Responsibility for drift, underhåll, and säkerhet (incl. cybersecurity) should sit with the infrastructure owner; suggests a certification scheme covering things like a designated elansvarig and a maintenance/renewal fund.
• The IKN-förordningen (internal-net exemption from nätkoncession) needs review — the current application of §22c has produced outcomes that likely weren’t the legislator’s intent when Sweden implemented the Clean Energy Package via IKN. Recommends the ordinance’s motive text be updated to clarify intent, including considering the size of a community’s own production relative to its use (since §22c was primarily meant to enable sharing of own production).

Energy sharing specifically:

• Ursprungsgarantier/elcertifikat costs should be allocated equally regardless of whether sharing is used.
• Warns that growing bilateral energidelning contracts could reduce liquidity and price transparency on the open wholesale market over the longer term, disproportionately harming end-customers who lack the market access to negotiate outside transparent pricing.
• Costs of administering the settlement between supplier-purchased and shared electricity should fall on the customers using that service.
• Recommends a phased rollout to assess interest and system impact before wide implementation — citing that basic processes (data-flow handling, sharing contract-information between parties) don’t yet exist and complexity increases exponentially with the number of customers and actors (its wording); limiting geographic scope eases settlement and reporting for virtual sharing. Says the end goal could be elområde but that a stepwise introduction is better and initially limiting to nätområde may be appropriate (the position predates, and is not a response to, the scope Prop. 2025/26:240 adopted).
• States it currently sees no clear economic benefit to energidelning: a bilateral deal only beats exchange-based trading if the seller voluntarily accepts a below-market price or the buyer voluntarily pays above-market (e.g., for lower return requirements or environmental value) — and counterparty risk changes under bilateral arrangements, so no straightforward economic advantage can be assumed.
• Opposes extending energy-sharing eligibility to companies with large trading volumes, on grounds that their participation could distort market-wide price transparency and dampen investment incentive for new generation; large actors already have tools to manage their own consumption efficiently without a sharing structure.

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