Energimyndigheten ER 2025-35 Förbättra Flexibiliteten (2025)

Document: ER 2025:35, Energimyndigheten (Swedish Energy Agency), final report on government assignment KN2024/01432 “Förbättra flexibiliteten i elsystemet” (Improve flexibility in the electricity system). Published November 2025. RISE was technical consultant for Chapter 3. Reference: Regeringsbeslut KN2024/01432. Checked against the raw copy on 2026-09-24.

Document structure

Two-part structure:

• Chapter 2: Target-audience information outreach — agency roles, ongoing initiatives, consumer campaigns
• Chapter 3: Robustness, resilience, preparedness — substantive technical content on risks, communication protocols, and synchronisation

Chapter 2 — Agency roles and information initiatives

Mandates and roles (comprehensive official description)

• Energimyndigheten: strategic and coordinating role; new instruction (regleringsbrev) gives it an explicit mandate for flexibility and efficient power use
• Svenska kraftnät (Svk): system responsibility for transmission, balancing, ancillary services, and elberedskap (electricity emergency preparedness)
• Ei (Energimarknadsinspektionen): promotes efterfrågeflexibilitet (demand flexibility); 2024 strategy update; runs EFFEKT-dialogen forum; developing Elpriskollen upgrade for smart steering/DR product comparison; new föreskrifter for DSO customer information requirements (references to Ei’s flexibility info page on electricity invoices already in effect; regulations for network companies under development); Ei innovationscenter launched 2024 as first contact point for innovative actors
• Konsumentverket: consumer protection in emerging flexibility markets
• Swedac: metering rules; flexibility market measurements may require metrological requirements

Projekt Industriflex

Energimyndigheten project with five industrial companies (paper/pulp, steel, mining, and manufacturing sectors) plus their respective DSOs, with RISE as technical consultant. Focus: developing industrial demand flexibility in practice. Completing spring 2026. The project aimed at three to five industries; five take part (paper and pulp, iron and steel, mining, manufacturing), each with its own grid company. Earlier work found industry holds roughly 5–15% of its electricity use as near-term shiftable potential, largely unused.

Chapter 3 — Robustness, resilience, preparedness

§3.1 Risks and opportunities

Beredskapsflexibilitet (preparedness flexibility)

A formally defined concept: flexibility resources that are activated only under crisis conditions that would be too costly or disruptive for normal commercial use. Examples include:

• Heat pump comfort reduction (users pre-agree to accept a reduced indoor temperature in a crisis — the raw text doesn’t specify a magnitude) — users agree to accept this pre-emptively
• Industrial process disruption at levels normally considered unacceptable
• Ö-drift (island operation): DERs (solar + batteries + EVs) operating microgrids independently from the transmission grid during major outages
• Dödnätsstart (black start): batteries + renewables restarting the grid from a dead state — traditionally required specific hydro plants; DER-based black start now technically feasible
• Synthetic inertia (syntetisk rotationsenergi/svängmassa): batteries with special inverter control can contribute inertia to stabilise grid frequency. Svk explicitly identifies growing need for this capability. (The FCR/FFR-vs-inertia distinction stated here is this wiki’s own domain-knowledge elaboration, not something the raw report itself draws.)
• Distributed redundancy: geographically spread DERs mean no single point of failure

Reference incident: Berlin, September 2025 — arson attack on two high-voltage lines (voltage level not specified in the raw report) caused a 60-hour outage affecting 50,000 customers; recovery required temporary lines and illustrated the systemic risk of centralized critical infrastructure.

System operating states

The report maps beredskapsflexibilitet onto the formal system state hierarchy:

Cybersecurity risk

RISE conducted simulations on the Nordic32 test system. Key findings:

• Sweden had approximately 300,000 internet-connected heat pumps (vätskeburna värmepumpar) as of 2022 per the report’s own cited estimate, and the report notes the number is growing as older systems are replaced — treat as a 2022 baseline, not a current count
• Sweden had about 1.6 GWh of installed battery capacity at the end of 2024, roughly 1 GW (“nästan 1 GW”) of power
• These are approaching critical mass (not yet reached, per the report’s own wording — “närmar sig”): a coordinated cyberattack could cause grid frequency deviations outside normal limits at system level — not just individual device damage
• Threat model: devices infected silently (malware), then activated simultaneously on command. The risk is “not just that individual units become unusable, but that many devices simultaneously can be infected silently and then activated in a coordinated way to disrupt the grid” (translated from Swedish, not a verbatim English quote — approaching critical mass, per the report, not yet reached)
• This risk is framed as generic across ALL internet-connected DERs, not only heat pumps
• Open communication protocols are cited as a risk-reducer: they reduce attack surface compared to proprietary protocols (which concentrate vulnerability in one vendor’s codebase)

Other identified risks:

• Complexity risk: more actors, more coordination requirements, more failure modes; end-users lose ability to manage their own systems when automation fails
• Implicit flex synchronisation: many resources responding simultaneously to the same price signal → unpredictable aggregate load shifts (also identified in Source - FlexAbility Delrapport 5 (2025))

§3.2 Open communication protocols

RISE produced a comprehensive mapping of all protocols relevant to the flexibility protocol stack. The full treatment is in Flexibility Communication Protocols.

Four-layer structure:

Layer 1 — Market and aggregation: OpenADR (IEC 62746-10-1; Energiföretagen recommended it as the Swedish industry standard in 2023), S2 (EN 50491-12-2; semantic interoperability; limited Swedish use), IEEE 2030.5/Smart Energy Profile (two-way DER ↔ aggregator ↔ DSO; limited Swedish use)

Layer 2 — DER protocols: OCPP (Open Charge Point Protocol; Swedish national standard SS-EN IEC 63110; extensive use; enables V2G), ISO 15118 (EV-charger communication; Plug & Charge; V2G bidirectional; expected to grow), SunSpec Modbus (solar, batteries, DER local monitoring; integrated in IEEE 1547-2018), Matter 1.3/1.4 (smart home; energy management added in versions 1.3/1.4; emerging in Sweden)

Layer 3 — Local automation: EEBus (Germany-focused; heat pumps, EV chargers, HEMS; §14a EnWG Germany since 2024; limited outside Germany), SG Ready (German heat pump DR signalling; Swedish usage level not stated in this report), PowerMatcher (Netherlands)

Layer 4 — Grid/critical infrastructure: IEC 61850 (substation automation, SCADA, DSO/TSO operations), DNP3, IEC 60870-5-104

EU regulatory pipeline: NC DR defines market rules but explicitly does NOT define technical protocols. Protocols and data formats are mandated separately via an Implementing Act under EMD Art. 24. Expected 2026. This is the second regulatory pillar: NC DR = market rules; Art. 24 Implementing Act = mandatory protocols/data formats. A first Implementing Act (covering metering data) was already adopted in 2023; the DR-specific one is next.

Swedish challenges: heterogeneous systems across grid companies (the report gives no DSO count — “~170” is the wiki’s own figure); regulatory uncertainty (Energiföretagen sent its proposal for standardised flexibility-market products to Ei in March 2025 under 10 § förordning 2022:585, and the work was still ongoing when the report was written; the LFM-h/p/e names are not in the report); skills shortage; proprietary lock-in from legacy investments; open protocols recommended to reduce both fragmentation and cybersecurity risk.

Standardization bodies active: IEC TC 57 (extending IEC 61850 for DER), IEC TC 69 (finalizing ISO 15118 for V2G), EDNA (IEA 4E program; device flexibility mapping; Energimyndigheten participates; results early 2026), CEN/CENELEC/ETSI COG SG (EU smart grid standards coordination).

§3.3 Random startup delay (slumpvis uppstartsfördröjning)

Problem: When many EVs or other resources respond to the same price signal simultaneously and start charging at the same instant → transformer overload, frequency deviation. Risk grows with EV penetration.

15-minute pricing context: Sweden switched from hourly to 15-minute electricity pricing in October 2025. Effect on synchronisation patterns is unknown; could soften transitions (smaller differences between adjacent intervals) or create new patterns. Explicit monitoring flag.

Definition: A short random delay (0–100 seconds) applied before an EV charger starts, distributing load across time to avoid simultaneous starts. Distinct from scheduled charging (fixed time) — both reduce peaks but different implementation.

UK reference case: Electric Vehicles (Smart Charge Points) Regulations 2021 — mandates random delay up to 600 seconds for all private EV charge points sold after 30 June 2022. Delay applied to nearest second, applied every time a charging session starts or charging rate changes.

Compatibility requirement: Random delay must be opt-out compatible for grid balancing services. Svk requires activation within the minute for FCR/FFR — a charge point participating in an FCR activation cannot have a random delay that prevents immediate response. The UK regulation includes this carve-out explicitly.

Nordic status: No mandate in any Nordic country. Smart charging promoted nationally in Sweden, Norway, Denmark, Finland but no random delay requirement. Sweden already experiencing local overloading from synchronous charging.

NC DR provision (as stated by the report): the report says the proposed NC DR has no requirement on random start-up delay for specific devices, but that TSOs and aggregators may not send a start command to all their controlled devices at the same time, to avoid a load peak when the devices restart after a control action (a restart command after control, not an activation command). The report’s only source for this is a personal communication (Laure Meljac, Nibe, 2025-10-02); it gives no article number. No such provision was found in the amended NC DR text (ACER Recommendation 01-2025 Annex 1) in Raw/, so it remains unverified against the text itself.

Emerging parallel risk: After tax reduction for microproduction solar sales ended in Sweden (January 2026), many solar+battery systems may switch to self-consumption mode. When the electricity price is 60 öre/kWh or lower, controlled systems may switch to covering the household’s own load or charging their own battery instead of exporting, so large volumes of load can fall and then rise abruptly together when the price changes (the report notes this was identified late in the work).

Relevance to wiki topics