Swedish DSO Tariff Reform — Three Parallel Tracks (2025–2027)

For what these tracks mean for the customer paying the bill — and why it has risen faster than inflation in the first place — see Elnätsavgift — What Determines Your Bill.

Three distinct regulatory processes are simultaneously reshaping how Swedish DSOs design and set tariffs, all converging on a 2027–2028 implementation window. They address different dimensions of the same underlying problem — DSO tariffs that are structurally misaligned with the demands of the energy transition — and they interact. Understanding them as a system is more useful than reading any one in isolation.

The three tracks

Track 1 — TOTEX and the CAPEX bias

The problem: Under current revenue cap regulation, Ei benchmarks DSO efficiency on operating costs only. Capital expenditure earns a regulated return that is not subject to the same efficiency test. The result is the CAPEX bias: a DSO that builds new grid earns a regulated return on the investment; a DSO that instead procures flexibility services to defer that investment incurs opex that is benchmarked and subject to an efficiency requirement. The regulatory framework systematically favours building over buying.

The legislative foundation (decided October 2025): Track 1 depends on statutory authority Ei did not previously have to regulate capital-cost calculation purely by föreskrifter. This was resolved by Prop. 2025/26:26, the government’s response to a Tysklandsdomen-driven inquiry (SOU 2023:64, following Dir. 2022:20): it removes the term “kapitalbas” from ellagen entirely and delegates capital-cost calculation detail to Ei’s own föreskrifter — the enabling step Ei’s RP5 methodology (below) depends on. In force 1 January 2027, timed to apply from RP5 (2028–2031) decisions onward. Notably, the government rejected the same inquiry’s proposals to repeal the särskilt investeringsutrymme law and extend överrullning to two periods — see RP5 Revenue Cap Methodology (2028–2031) › Capital base valuation — normvärdering for the full legal history.

The reform: Ei’s RP5 methodology introduces TOTEX benchmarking — total expenditure including both capex and opex — and with it lösningsneutralitet (solution neutrality): the efficiency incentive applies equally regardless of whether a DSO addresses a capacity problem by reinforcing the grid (CAPEX) or procuring flexibility (OPEX). The statutory basis is ellagen 5 kap. 12a § (Lag 2022:596), which requires that “when the revenue frame is determined, account shall be taken of the extent to which flexibility services are used and improve the efficiency of grid operations.” This is not a discretionary Ei policy choice — it is a statutory obligation.

In December 2025, Ei confirmed enstegsmetoden as the TOTEX method. In May 2026, three additional design decisions: (1) no general efficiency requirement applied — actual cost outturns already embed productivity improvement; (2) full cost coverage at the third quartile (Q3), with a relative (moving) threshold following UK practice; (3) 8-year realiseringstid retained. (Source - Ei Effektiviseringsincitament Webb (2026-05-12))

The efficiency incentive splits by network tier: lokalnät use DEA benchmarking (May 2026, four structural corrections), while regionnät — too few for reliable peer benchmarking — use multifaktorproduktivitet (MTFP), each firm’s individual productivity development on total costs (announced June 2026). Both are TOTEX-based and lösningsneutrala; Svk follows the same small-N MTFP logic as regionnät. See RP5 Revenue Cap Methodology (2028–2031) › RP5 efficiency incentive for regionnät — MTFP (announced June 2026). (Source - Ei Effektiviseringsincitament Regionnät MTFP (2026))

Timeline: Full methodology published 2026; calculation föreskrifter in force H1 2027; revenue frame decisions by 31 October 2027; RP5 begins 2028.

What changes for flexibility: Before RP5, DSO procurement of flexibility services earns no regulated return — it competes on unequal terms with grid investment. After RP5, TOTEX benchmarking creates genuine economic symmetry. FlexAbility interviews rate this as the correct structural direction; the risk flag is that a purely cost-efficiency benchmark might penalize proactive grid building that the energy transition requires — Ei is investigating this adjustment. (Source - Ei Inriktning intäktsramar 2028-2031 (2025))

An outside view on Track 1. ISGAN, BRIDGE and Comillas researchers (ISGAN and BRIDGE discussion paper) describe the same CAPEX bias and recommend ex-ante revenue caps with profit-sharing, decoupling revenue from investment plans and adaptable planning ahead of any OPEX/CAPEX neutralisation; they caution that TOTEX with a fixed capitalisation rate can create an OPEX bias. Whether that applies to Ei’s TOTEX benchmark is not settled by the sources held here (see RP5 Revenue Cap Methodology (2028–2031)).

Track 2 — Effektavgift redesign

The problem: Capacity-based network tariffs (effektavgifter) are a key instrument for transmitting price signals that incentivize demand shifting — implicit Demand Response. About 30 Swedish DSOs have introduced effektavgifter, but their designs are heterogeneous: different timing windows, different level-setting methodologies, different customer-size thresholds. Ei has identified potential design deficiencies in some. Ei division head Tommy Johansson explicitly named this fragmentation as the barrier to standardised automatic steering services — the software-layer DR products that require uniform tariff structures to develop at scale. (Source - Ei Effektavgifter Uppdrag (2026))

The regulatory reversal: EIFS 2022:1 required all Swedish DSOs (168) to implement time-differentiated capacity tariffs by 1 January 2027. In March 2026, the government reversed course: Ei is tasked to repeal EIFS 2022:1 by 30 June 2026 and propose a new effektavgift model by 12 April 2027. The mandatory deadline is cancelled before it arrives.

After repeal: Effektavgifter remain permissible — neither required nor prohibited. The legal basis shifts to the general standards: ellagen (skäliga, objektiva, icke-diskriminerande) and Art. 18 EU Electricity Market Regulation (cost-reflective, transparent, considering customer usage patterns). Existing DSO contracts are unaffected. This is a regulatory vacuum pending the new model.

Repeal executed (2026-06-17): Ei formally decided to repeal EIFS 2022:1, which ceases to apply at the end of June 2026 — removing the binding requirement that tariffs include an effektavgift from 1 Jan 2027. As a direct consequence, Ei also repealed its ställningstagande Ei2025:06 (utformning av tariffer för överföring av el), which was grounded in EIFS 2022:1, and removed the related website vägledning. The new-model deliverable (due 12 April 2027) is unaffected. Note this removes a piece of interpretive guidance the wiki had relied on — Ei2025:06’s aggregate-load principle for effektavgift time-differentiation is no longer a live Ei position, though its substance is expected to inform the new model. (Source - Ei Effektavgifter webb (2026))

The reversal ran directly against EU guidance published five months earlier. C/2026/126 (9 January 2026) recommends exactly this instrument — a capacity element reflecting peak load, combined with a time-of-use energy element — and cites Sweden twice as the exemplar: the April 2025 four-component tariff plan with its time-differentiated capacity charge, and “all DSOs will move to dynamic time-of-use network tariffs from 2027”. The Commission put comparative evidence behind the recommendation (Flanders’ 2023 capacity tariff cut peak load 1–3%, mostly via changed EV charging; Belgian transmission charges cut the industrial synchronous peak 4% from 2019–2024 while volumes rose 10%; Spain’s six-period structure cut network charges 5.6% in one year). Sweden withdrew the mandate before it took effect.

This does not make the repeal wrong. The Swedish objection is to fragmentation across ~30 heterogeneous DSO designs, which the Commission’s guidance also warns about when it insists tariffs be “understandable and predictable” enough for consumers to react. But it does mean the April 2027 model is now carrying the weight of two separate expectations at once: the domestic one (a uniform, comprehensible design) and the EU one (a cost-reflective time-differentiated signal that Art. 18 is read as already requiring). Between June 2026 and that model, Sweden has weaker tariff-side flexibility signals than the EU guidance describes it as having. (Source - C(2026)126 Future Proof Network Charges Guidelines)

Parallel tillsyn: In April 2026, Ei opened a formal supervisory investigation of effektavgifter design at five DSOs: Ellevio, Göteborg Energi Nät, Bergs Tingslags, Södra Hallands, and Tekniska verken Linköping. Ei is examining whether existing designs comply with ellagen and Art. 18 EMR — independently of the mandate to develop a new model. (Source - Ei Tillsyn Elnätsavgifter (2026)) The five were selected partly on customer complaints, partly for variation in size and geography. The tillsyn is a stopgap: it can force correction of non-compliant designs after the fact, but it cannot prevent non-compliant designs from being deployed — which is precisely what Track 3 would address.

Tillsyn outcome (PM2026:07): Ei’s supervisory review of the five named DSOs (Ei PM2026:07) concluded that all five models comply with current regulations — no orders were issued. The review documented significant variation in design:

Key takeaways from the review:

• Two companies retreating: Ellevio dropped effektavgift from 1 June 2026 (revenue-neutral); SHK will drop from 1 October 2026 (revenue-neutral); both cite the changed regulatory context
• Behavior effects noted but limited: TVL reported reduced peak demand and some load shifting after introduction; revenue from the ≤63 A segment was lower than expected in the first period
• Customer complexity confirmed: predictability challenges especially for single-hour billing; initial customer questions centered on understanding the mechanism; later questions on operational use
• Core Ei conclusion: the current broad interpretive latitude means similar customer groups face different tariffs depending on which DSO they are served by, without clear justification from local grid conditions

Ei states a significant need for clearer framework rules and has begun work on the new model in dialogue with DSOs, customer representatives, and others.

A longer-running example outside the five-DSO tillsyn: Telge Nät (Södertälje-area DSO) has run an effektavgift since 2022 — several years’ more live operating history than most of the tillsyn cohort. Its own customer guidance mirrors the same load-shifting logic (avoid simultaneous high-power use, shift to before 07:00/after 20:00 in winter). Customer friction there tracked the same “customer complexity confirmed” pattern Ei found in PM2026:07 — an organised customer complaint (a local allotment-garden association reporting a ~95% fee increase despite seasonal-only facility use) targeted the tariff’s flat treatment of very different usage patterns, not the capacity-pricing principle itself. No quantified customer load-shifting data was found publicly — the same behavioural-evidence gap Track 2’s own review has. Update (19 May 2026): Telge Nät announced it is keeping its effektavgift but changing the calculation from the single highest hour in a month to the average of the five highest hours — reducing the impact of one-off usage spikes, directly responsive to the criticism above. (Source - Telge Nät Effektavgift Customer Experience (2022-2026))

The new model criteria: transparent, non-discriminatory, proportional to customer size and needs, designed to give customers correct incentives for consumption adaptation. The specific design — whether to mandate harmonization of timing windows, set level-setting methodology, or specify measurement approaches — remains open. Ei’s proposal is due April 2027.

Consumer-side debate opens: within a month of the repeal decision, two DEBATT pieces staked out opposite structural positions on what the new model should look like — abolish the capacity charge in favour of a pure time-of-use energy tariff, versus keep it but make it dynamic and locational using DSOs’ own nätstation-level metering. See Demand Response › Household voices — the case for and against static effektavgifter for the detail.

Industry raises the same bluntness concern from the business side: Svenskt Näringsliv’s 2026 flexibility policy program warns that effektavgifter, while aimed at more efficient grid use, risk being too bluntly designed — customers who cannot technically be flexible must not be penalised with cost increases they have no way to avoid, and market price signals should reach customers undistorted by tariff-design artefacts. The same structural worry as the household DEBATT pieces above, from the opposite side of the table. (Source - Svenskt Naringsliv Startprogram Flexibilitet (2026))

State of play at repeal (konsekvensutredning, ärendenummer 2026-101721): As of January 2026, approximately 30 DSOs had already implemented household effektavgifter (of which ~20 had adopted a model specifically following EIFS 2022:1 since its 2022 introduction; the rest predate the regulation), with significant variation in design: different timing windows, level-setting methodologies (monthly peak, mean of N highest hours, time-varying, winter högbelastningsavgift), customer-size thresholds, and measurement periods. Several DSOs paused or reversed plans to introduce effektavgifter when the government assignment was announced — a direct short-term consequence of the regulatory reversal. SVK’s transmission tariff reform (four-component model from 2027-01-01) is a separate track unaffected by this repeal. Cost of the repeal process: ~300,000–600,000 SEK for Ei; ~2–3 årsarbetskrafter per DSO for tariff development work (mostly sunk). (Source - Ei Konsekvensutredning EIFS 2022-1 Upphävande (2026))

The consumer-information complement — EIFS 2026:8: Decided 2026-05-21, in force 1 January 2027, EIFS 2026:8 is the information-layer response to the same effektavgift problem this track addresses. Because EIFS 2022:1’s mandatory 4-component split was being repealed mid-drafting, the föreskrift had to redefine effektavgift and energiavgift generically — about the form of the charge, with no link to DSO costs — and make every effektavgift-specific duty conditional (“om nätföretaget tillämpar en effektavgift”). Its second konsekvensutredning (dnr 2025-101516) supplies the sharpest quantification of the backlash driving all of Track 2: as of spring 2025 ~13% of households had an effektavgift; by early 2026 drygt 30 DSOs applied one (säkring ≤25 A); and complaints to Ei about the grid rose from 67% of all complaints (2024) to 80% (2025) — of those 2025 grid complaints, 53% (1,309) concerned elnätsavgifter, and of those, 64% (837 cases) concerned tariff design/effektavgifter specifically (i.e. 837 cases is ~34% of all 2025 grid complaints, not 64% of them). Ei names the comprehension failure precisely — users cannot reconcile the effektavgift (grid) signal with the spotprice (energy) signal. EIFS 2026:8 forces transparency (purpose/design explained, effektavgiftsgrundande mätvärden shown on mina sidor, weighted-average pricing on invoices) and pushes consumer DR (mandatory links to ei.se/kundflex; duty to inform about automated steering services and any LFM the DSO trades on). Notably, the KU records DSOs exploring dynamic per-quarter network pricing (a day-ahead grid-load forecast setting a price per kvart), enabled by the 30 Sep 2025 move to kvart trading — a concrete future direction for what the new effektavgift model could standardise.

Efficiency evidence base for the new model (Energiforsk 2026): two June-2026 Energiforsk studies scrutinise effektavgift designs on exactly the criterion Ei’s original mandate rested on — effektivt nätutnyttjande. The simulation study 2026:1197 (Sweco/Merlin & Metis; four tariffs, 200 battery villas, real 2025 prices) found demand charges change behaviour strongly but give limited grid benefit once sammanlagring is counted, can suppress customers’ spot-market response, and can create new peaks — concluding incentives should be more precise in time and space and that the network tariff cannot do the job alone. The UniFlex study 2026:1193 proposes a “unison” hourly capacity tariff reflecting both grid and market value (Sala-Heby case), and exposes the locational design tension — nätstation-level pricing gives sharp, dispersed spikes while a single grid-wide price reads as unfair to customers with no local shortage. Together they frame the live design choice for the April 2027 model: how dynamic, and how geographically granular, to make the signal — analysed through the arbitration-architecture lens in The Signal Stack — Price Signal Collisions at the Customer DER. (Source - Energiforsk 2026-1197 Konkurrensen om Efterfrågeflexibilitet Simulering (2026), Source - Energiforsk 2026-1193 Unison Prissignal Timeffektavgift (2026))

Field evidence for a location-specific alternative — Gotland Tariff 2.0 (June 2026): a 12-month pilot on eastern Gotland (ten pilots, seven active) tested a dynamic, per-substation, symmetric network price combined with spot into one signal, plus a budget-neutral flexkompensation to avoid location unfairness. Users preferred it to peak-based effekttariffer and found the composite signal easy to follow, but day-ahead forecasts missed the most critical load hours, effects on the grid were limited in a lightly loaded network, and the pilot needed a regulatory sandbox because location signals were not allowed in local grids (Source - Energicentrum Gotland Tariff 2.0 Slutrapport (2026)).

Phase 1 complete, deadline unchanged (1 September 2026): Ei closed the input-gathering phase of the effektavgift-redesign assignment — spring/summer 2026 DSO/service-provider/customer-representative meetings, public and DSO surveys, reference-group sessions, now led by project lead Gustav Janeling. Six recurring stakeholder themes emerged regardless of actor type: the effektavgift’s purpose needs clarifying; DSO models need more harmonization; the charge should track actual load/congestion moments more closely; forward-looking cost calculation/allocation needs clearer guidance; the model must be comprehensible, predictable, influenceable, and clearly justified; and optional/selectable models should be considered — directly echoing GENAB’s existing valbar/ordinarie split (see Göteborg Energi Nät). Phase 2 (analysis of how design options affect users, DSOs, and the grid) is now underway; the 12 April 2027 deadline for Ei’s proposal to government is explicitly restated, unchanged. (Source - Ei Effektavgifter Nästa Fas (2026))

A concrete instance of the vacuum window described above: GENAB’s own planned mandatory rollout of time-differentiated effektavgifter (autumn 2026) was itself halted by the same regulatory reversal — the same KN2026/00582 decision that drove the EIFS 2022:1 repeal — leaving roughly 16M SEK of rollout-preparation cost sunk. Its voluntary valbar model, unaffected, shows real season-one results: ~2,700 enrolled customers, 1,500–2,000 SEK/year average savings, 15–20% of usage shifted to lågpristid, ~90% renewal. See Göteborg Energi Nät for detail. (Source - Göteborg Energi Tidsindelade Effektavgifter Stoppas (2026))

Disclosure of the tariffs themselves (2026). Alongside the redesign, Ei began work in April 2026 to amend EIFS 2024:5, which today only requires a grid company to publish its fees on its website 14 days before they apply. The central new element is publication in a machine-readable format so that users, Ei and service companies can use tariff data for statistics, analysis and control and information services; Ei welcomes the industry’s common API in RISE’s “Dynamiska nättariffer” project and says it is not writing a standard of its own. The work runs in parallel with the effektavgift assignment, because Ei sees the need for closer disclosure rules whatever happens to the design rules. The same problem was described in Ei R2023:04 (measure d, 2023): information on about 170 grid companies’ tariffs was hard to reach and unusable as a basis for services. No consultation or decision date is given. (Source - Ei Offentliggörande av Elnätsavgifter (2026))

Track 3 — Förhandsprövning

The problem: Sweden applies ex-post oversight only. After a DSO introduces a tariff methodology, Ei can review it via tillsyn and require corrections going forward — but cannot prevent a deficient methodology from entering force, and cannot retroactively remedy its effects. This is the oversight gap that allows the ~30 DSO effektavgift design deficiencies to persist until Ei investigates and orders changes.

This gap is longstanding and an EU compliance failure. Arts. 59.1a and 59.7a of Directive 2019/944 have required NRAs to pre-approve tariff methods since the predecessor directive in 2003. Sweden was taken to the EU Court (C-274/08, Commission v. Sweden, 2009), lost, and addressed the ruling by introducing revenue cap pre-approval (intäktsramar) — but never extended pre-approval to the underlying tariff methodologies. ACER’s 2025 report (Getting the signals right) confirms Sweden and Finland remain the only two EU member states where the NRA neither decides nor pre-approves DSO tariff methods.

The proposal: In February 2026, Ei submitted a hemställan (formal legislative proposal) to the government to amend ellagen 4 kap. 46–47 §§ and add § 36a to Förordning (2022:585). The amended ellagen 4 kap. 46 § would require Ei to pre-approve (or set) DSO methods for connection and transfer charges before they enter into force, covering both the conditions and the methodologies for calculating them. (Source - Ei R2026-04 Förhandsprövning Avgifter (2026))

The NRA independence constraint: Per C-718/18 (Commission v. Germany, 2021), regulation of how a NRA exercises tariff-setting authority must live in the NRA’s own föreskrifter — not in statute. The current ellagen 4 kap. 46 § contains a material criterion (“objective and non-discriminatory”) that Ei argues is an impermissible statutory constraint on its discretion. The proposed new text removes this substantive content and delegates the detail to Ei’s föreskrifter — satisfying the Germany judgment while enabling pre-approval.

Two-step implementation:

• Step 1: amend ellagen/Förordning (target: 1 January 2027, pending government adoption)
• Step 2: Ei develops föreskrifter for the actual pre-approval process — estimated 2–4 FTE + consultants, 1–2 additional years after Step 1

Actual pre-approval of DSO tariff methods therefore will not begin until 2028 at earliest — and only if the government adopts the proposal in time for Step 1 in 2027.

As of May 2026, government adoption is pending. There is no published timeline.

The empirical case — Ei R2026:05 (2026)

In June 2026 Ei delivered R2026:05 “Utfallet av regleringen av elnätsavgifter” (Source - Ei R2026-05 Utfallet av Regleringen av Elnätsavgifter (2026)), a government-commissioned (29 Jan 2026) factual report on the outcome of the current tariff regulation. It supplies the empirical justification underneath all three tracks — particularly Track 1 (TOTEX) and Track 3 (förhandsprövning) — and Ei will republish the figures annually on its website, with named “top-10” lists of DSOs on dividends, internal-loan costs, and profit margins.

The headline numbers:

• Tariffs have far outpaced inflation: household network fees +115% (2005→2026), larger fuse customers +85%, against CPI +49%. Non-household fees rose considerably more in Sweden than in Denmark, Finland, or Norway.
• DSO finances are strong: soliditet 46–51%, profit margin 16–23%, return on equity 9–13%, return on total capital 5–7% (median, 2020–2024) — all above the more market-risk-exposed elhandel/elproduktion sectors. Ei explicitly reads this as confirming that “the intäktsram review Ei is conducting is needed” (välbehövlig).
• Value transfers are routine: ~80 DSOs/yr net givers of koncernbidrag; ~20 bn kr cumulative (2020–2024); ~10% of net turnover for participants. Ellevio’s internal-loan costs alone reached 15.9% of net turnover.

This is the politically salient evidence base: it converts the abstract “CAPEX bias / oversight gap” argument into concrete numbers (excess returns, above-CPI fee growth, profit extraction via koncernbidrag/internlån) that motivate both the TOTEX reform and the call for ex-ante tariff oversight. The report’s own conclusion endorses the new intäktsramsmetod (changed valuation, risk-adjusted kalkylränta, connection-fee handling, TOTEX) as the remedy.

A fourth pressure: competition-law scrutiny (2026)

In July 2026, Konkurrensverket (the Competition Authority — not a sector regulator) published its own review of the same tariff data from a competition-law angle: Analys i korthet 2026:3. It does not add a fourth formal reform track, but it adds mechanism-level pressure reinforcing Track 1 (TOTEX) and Track 3 (förhandsprövning): Konkurrensverket argues the current kapacitetsbevarande capital valuation (nuanskaffningsvärde, indexed to construction-cost inflation BKI) may systematically overcompensate DSOs, because BKI has risen almost twice as fast as general inflation (KPI) since 2012, while capital financing actually competes in a broader capital market that KPI tracks better. Ei’s own kalkylränta for local networks rose from 3.39% to 4.53% between the 2020–2023 and 2024–2027 periods, compounding the effect. Total revenue caps for local+regional networks rose 168→270 bn SEK (2020–23 → 2024–27), of which capital costs were the largest driver (+97% local, +127% regional).

The report also surfaces a legal-history detail relevant to Track 1’s timeline: Ei’s first attempt (pre-2024) to compel DSO data for a förmögenhetsbevarande (historical-cost) method change was struck down by Kammarrätten i Jönköping (20 June 2023), forcing Ei to pause and revert to essentially the 2020–2023 method for the current period — context for why the förmögenhetsbevarande switch is still pending for RP5 (2028) rather than already in force. Energiföretagen Sverige publicly disputed Konkurrensverket’s reasoning, arguing pricing within ellagen’s revenue-cap limits should not be separately “unreasonable” under competition law, and flagging that the 168→270 bn SEK comparison uses preliminary figures in different money values. (Source - Konkurrensverket Analys i Korthet 2026-3 Prisbildningen på Elnätsmarknaden (2026), Source - Energiföretagen Kommentar Konkurrensverkets Granskning (2026))

The EU legislative backdrop — COM(2026) 600 (July 2026)

The Commission’s proposal, received by the Council on 17 July 2026, would replace Art. 18 of the Electricity Regulation and add Arts. 18a–18d (COM(2026) 600). It is a proposal only: no source held here shows Parliament or Council action or an entry-into-force date, so nothing below changes Swedish obligations yet. What it would mean for the three tracks:

• Track 2 (effektavgift): Art. 18(2)(g) and (h) name a capacity element and time-of-use elements among the design criteria for network charges, and Art. 18(3) allows special regimes for categories such as energy-intensive industry, data centres and energy communities where the regulator shows a different network-cost impact.
• Track 1 (TOTEX): Art. 18(2)(a) and (c) put anticipatory investment costs inside the recognised cost base and require incentives for optimising existing grids through flexibility services, non-wire solutions and smart grids. Art. 18(7) would oblige regulators to compare DSOs’ efficiency and publish a report every four years (first at entry into force plus 37 months). Ei already benchmarks DSOs with DEA (see RP5 Revenue Cap Methodology (2028–2031)), so the new element is mainly the EU-set cycle and reporting, not benchmarking as such.
• Transparency: Art. 18(5)–(6) would require publication of cost data, tariff values per user group and the assessment behind tariff methodologies, and a public consultation before a methodology is fixed or approved.
• Harmonisation: Art. 61(5a) would let the Commission adopt a delegated act on a common tariff structure and methodology. The EU DSO Entity opposes this and mandatory DSO benchmarking, and argues tariffs should mainly drive implicit flexibility (time-of-use) rather than reward explicit flexibility, and that the flexibility-related criteria (k) and (n) should be deleted (DSO Entity’s reaction).

This sits against the Commission’s earlier, non-binding guidelines, which push in the opposite direction on flexibility signals in tariffs.

How the three tracks interact

Track 3 constrains Track 2: Once förhandsprövning is operational, Ei can block non-compliant effektavgift designs before they enter force — making the Track 2 tillsyn enforcement mechanism redundant for future designs. The tillsyn of the five DSOs (April 2026) is a direct consequence of lacking the Track 3 tool: without pre-approval, Ei must identify deficiencies post-hoc.

Track 1 affects the economic incentive to use effektavgifter: TOTEX benchmarking rewards DSOs that efficiently use grid capacity. A well-designed effektavgift that shifts peaks and improves the utnyttjningsgrads-incitament is a TOTEX efficiency lever. If Track 2 produces a harmonised, well-designed effektavgift standard, and Track 1 creates the incentive to use it, the two reforms compound each other’s effect.

Track 2’s fragmentation problem is the concrete driver for Track 3: Tommy Johansson’s statement linking heterogeneous effektavgifter to the demand response automation barrier articulates exactly why ex-post correction is insufficient — by the time Ei identifies and corrects a design deficiency, the automated services that would have standardised on that DSO’s tariff structure have already been forced to adapt or exclude it.

All three share the 2027 target date, but none deliver in 2027:

• Track 1 (TOTEX) enters force H1 2027 as föreskrifter; revenue frame decisions October 2027; actual impact from RP5 start 2028
• Track 2 (effektavgift) delivers a model proposal April 2027; implementation timing undefined thereafter
• Track 3 (förhandsprövning) could become law in 2027 if the government acts; Ei’s föreskrifter for the actual process require an estimated 2–4 FTE-years + consultants and, per Ei, drafting a föreskrift of this scope can generally take “months to years” — no firm calendar estimate is given, but pre-approval is unlikely to be operational before ~2028–2029

The window of regulatory vacuum: Between EIFS 2022:1 repeal (June 2026) and the new effektavgift model (post April 2027) and operational förhandsprövning (~2028+), Swedish DSOs face a period with only general legal standards governing tariff design. DSOs that already have effektavgifter live under ongoing tillsyn risk; new entrants can design freely within the ellagen/Art. 18 EMR standards, with no standardisation requirement and no ex-ante check.

Implications for flexibility market participants

For DSOs: The TOTEX reform is the most structurally important change — it aligns the revenue cap with flexibility procurement in a way that no product approval or tariff design mandate does. DSOs should begin modelling RP5 TOTEX impacts now; the flexibility service costs already classified as opåverkbar opex (1:1 recovery) under §9.5.8 will interact with the TOTEX benchmark.

For aggregators and demand response providers: The effektavgift redesign (Track 2) is the short-term critical development. Tommy Johansson’s automation barrier statement is an official validation of what FlexAbility (2025) had documented qualitatively — tariff heterogeneity is a structural barrier to standardised automated DR — and is consistent with AFRY (2023)‘s separate finding that only one consumer steering service takes network tariffs into account at all (AFRY does not itself discuss DSO tariff fragmentation). The new model design process (April 2026–April 2027) is the window for market participants to shape what standardisation looks like in practice. EC C(2025) 4010 final reinforces the same direction from Brussels: tariff methodologies must be transparent, predictable, and set or approved by the NRA.

For energy service companies: The period 2026–2028 is a regulatory transition period for tariff-dependent products. Any product whose automated control logic assumes specific effektavgift timing windows or measurement periods carries revision risk as Track 2 plays out.

Relationship to other wiki pages

• Ei — institutional actor for all three tracks; TOTEX, effektavgifter, förhandsprövning roles
• Distribution System Operator — DSOs are the regulated entities in all three tracks
• Demand Response — effektavgifter as the implicit DR price signal; Tommy Johansson’s automation barrier statement
• Flexibility Market — TOTEX lösningsneutralitet is the economic underpinning for DSO market participation
• Natural Monopoly — förhandsprövning strengthens the oversight rationale for monopoly grid operators
• Source - Ei R2026-04 Förhandsprövning Avgifter (2026) — primary source for Track 3
• ACER — ACER 2025 report confirms Sweden/Finland as EU outliers on tariff pre-approval
• COM(2026) 600 and DSO Entity’s reaction — the EU proposal that would rewrite Art. 18 network-charge rules, and the DSO sector’s objections
• Konkurrensverket — competition-law scrutiny of the capital-cost valuation mechanism (2026), reinforcing Tracks 1 and 3
• RP5 Revenue Cap Methodology (2028–2031) — the detailed Track 1 methodology reference (capital valuation, DEA/MTFP benchmarking, consultant inputs)