Villkorade Avtal

Villkorade avtal (conditional connection agreements) are a Swedish DSO mechanism for managing distribution grid congestion. A customer’s connection is split into a guaranteed capacity and a controllable portion that the DSO can curtail during congestion events. The customer gets faster grid access; the DSO avoids having to refuse or delay the connection until grid reinforcement is complete.

Villkorade avtal are the Swedish national implementation of the EU concept of flexible connection agreements (FCAs) — see Flexible Connection Agreements for the EU-generic framework, the 10-dimension design taxonomy, and the interaction analysis with network tariffs and local flexibility markets.

How it works

A villkorat avtal specifies:

• Garanterad överföringskapacitet — the power level always available to the customer
• Villkorad kapacitet / styrbar effekt — additional capacity the customer may use when the grid allows, but must curtail within 15 minutes when the DSO sends a control signal

When congestion is forecast, the DSO first tries to resolve it via a local Flexibility Market (if one exists in the area). Villkorade avtal are activated only if market-based flexibility is insufficient. Non-compliance results in overuse charges and potential fines; repeated failure can lead to disconnection.

Villkorade avtal holders can also participate in the flexibility market (“queue-jumping”). A customer holding a villkorat avtal is controlled as a last resort. But if they also choose to participate in a local Flexibility Market, they move up the dispatch order: their bid competes on the market alongside any other FSP. If their bid wins, they receive normal market compensation. If market-based flexibility is insufficient and the DSO must activate non-market curtailment, the villkorat avtal holder who did not bid into the market is activated last — without payment. This creates a clear incentive for villkorade avtal holders to also engage with the flexibility market, and it expands the FSP pool, increasing competition and lowering DSO procurement costs. The bid does not need to match the villkorad kapacitet amount exactly; it competes on its own terms. (Source - BeFlexible D5.1 Demo Planning and Deployment (2024))

Where it sits in the flexibility taxonomy

Villkorade avtal are an interesting hybrid. They involve explicit, DSO-dispatched curtailment (like market-based Demand Response), but they are embedded in the connection agreement itself — making them a rules-based mechanism rather than a market transaction. The customer doesn’t bid into a market; curtailment is a contractual obligation tied to the connection.

In the Flexibility taxonomy:

This makes villkorade avtal a complement to flexibility markets: the market handles congestion through price incentives, while the villkorat avtal provides a backstop when the market doesn’t clear enough volume.

Practical context

• Offered by E.ON Energidistribution across all network areas using a single approved method (as of 19 March 2024); pilots ran since 2020
• Primary use case: businesses wanting to connect large loads (EV charging depots, data centers, industrial facilities) in areas with congestion, without waiting years for grid reinforcement
• Steerable resources: EV charging infrastructure, heat pumps, batteries, ventilation, industrial processes
• Technical integration required: real-time metering (Modbus), API/IEC 60870-5-104 communication, OpenADR 3.0.x for automated signal handling
• In SWITCH, the DSO acts as VTN (Virtual Top Node): control signals are published as OpenADR events when a monitored threshold is exceeded. Customers implement VEN (Virtual End Node) clients that receive signals via webhooks or polling. Each event specifies resource ID, start time, delivery period (15 minutes), direction (consumption/production), and maximum permitted power level. Customers send acknowledgement reports; SWITCH validates delivery using metering data from the customer installation. (Source - SWITCH User Documentation (2026))
• Curtailment order in SWITCH: LIFO (last in first out — the most recently connected customer is curtailed first). Alternative: all connected customers curtailed simultaneously
• Dynamic load-splitting: SWITCH distributes the required power reduction across multiple customer installations, curtailing only as much as needed at each — minimising unnecessary impact on individual customers
• Grid tariff is the same as a standard connection — no tariff penalty for being villkorad

Swedish portfolio — Ei SGI data

Ei’s mandatory SGI reporting (No_ba_cons indicator, EIFS 2022:5) provides the first Sweden-wide count of bilateral consumer agreements as of 2023–2024:

The No_ba_cons indicator covers bilateral agreements with consumers broadly under EIFS 2022:5 — it includes villkorade avtal but may also include other connection agreements with interruptibility or flexibility clauses depending on each DSO’s reporting interpretation.

Ellevio’s lokalnät figures are not directly comparable to other DSOs. 311 × 22.3 MW = 6,935 MW — equal to 110% of Ellevio’s total network peak demand (~6,295 MW from DNDP 2025), which is structurally impossible for individual villkorade avtal customers. Most likely Ellevio counts all major network connection/delivery points (sub-DSOs, large delivery nodes) or all subscription agreements containing any conditional clause — covering essentially the full network load. All other SGI reporters average 0.03–11 MW per agreement; Ellevio’s 22.3 MW average confirms a different methodology. The regionnät unit (14 agreements, avg 34.1 MW, min 2.5 / max 45 MW) is plausible for large industrials at regional voltage. Zero activations (No_ba_cons_proc = 0) in both units in 2024.

C4 Elnät grew from 2 to 37 agreements in one year — a notable expansion suggesting active new connection uptake under villkorade avtal in the Kristianstad area. E.ON’s low count (5 agreements) reflects that E.ON relies primarily on the SWITCH flex market rather than bilateral contracts as its activation mechanism. (Source - Ei SGI Data 2023-2024)

Significance

Villkorade avtal represent the DSO’s emerging active role in managing grid constraints. They are a pragmatic, near-term solution that:

1. Unlocks grid capacity that would otherwise sit idle most of the year
2. Enables faster electrification (EVs, heat pumps, industry) without waiting for slow grid buildout
3. Creates a bridge to more mature flexibility markets

They also illustrate the digital/software layer forming on top of the physical grid: the integration requirements (APIs, OpenADR, real-time metering) are essentially a software interface between the DSO’s grid management systems and the customer’s energy management.

Swedish legal basis

The primary statutory authority for villkorade avtal flows from three sources:

• Ellag (1997:857) 4 kap. 4a § (Lag 2025:1330): “Flexibel nätanslutning” — explicit authority for Ei to issue regulations on requirements for power control systems and other technical requirements for connections “som innefattar villkor för att begränsa och kontrollera inmatning eller uttag av el” (flexible connection agreements). Entered force 2026-01-01.
• Ellag 4 kap. 46 § (Lag 2023:238): “Förhandsprövning av villkor” — no network company may enter into connection or power transfer agreements before the methods used to design the contract terms have been pre-approved by Ei (nätmyndigheten). This is the statutory basis for the method pre-approval requirement in Ei2025:01.
• Ellag 4 kap. 47 §: Ei shall approve the method if it can be expected to lead to “objektiva och icke-diskriminerande” (objective and non-discriminatory) contract terms. Decisions take effect immediately.

(Source - Ellag (1997-857))

Ei’s regulatory classification

Ei conducted a comprehensive legal analysis of villkorade avtal in 2023 (Source - Ei Villkorade avtal (2023)). The core finding:

Villkorade avtal are a form of non-market-based redispatching (icke-marknadsbaserad omdirigering) under Article 13 of the Electricity Market Regulation.

Ei’s reasoning: a market-based mechanism requires openness to all actors, competition-based pricing, voluntary participation, and non-discriminatory product definitions. Villkorade avtal fail these tests — the DSO connects the next customer in queue (not competitive selection) and sets the price itself (not supply and demand).

When villkorade avtal may be used

Since they are non-market-based, villkorade avtal may only be used when one of four Art. 13(3) exceptions applies:

1. No market-based alternative available
2. All market-based resources already used (villkorade avtal as backstop)
3. Too few providers for effective competition in the area
4. Congestion so regular/predictable that market-based redispatching would cause strategic bidding

Burden of proof is on the DSO — must be demonstrated in annual redispatching reports to Ei.

Key regulatory constraints

• Not permanent: DSOs must annually reassess whether market-based alternatives have become viable. If markets develop, villkorade avtal must be phased out for those situations.
• Market first: where both villkorade avtal and a Flexibility Market coexist, market-based activation goes first. Villkorade avtal only as backstop when market volume is insufficient.
• No avbrottsersättning: curtailment ≠ outage (avbrott) if voltage is maintained at the connection point — so no outage compensation obligation.
• Pricing by DSO: Art. 13(7) states that producers who “accepted a connection agreement where secure delivery of energy is not guaranteed” are not entitled to compensation for non-market redispatching. Ei extends this to consumers.

Ei2025:01 — four clarifications (ställningstagande)

In 2025 Ei published its first ställningstagande (Ei2025:01), a new publication format providing formal regulatory guidance. Four positions were set out:

1. The DSO with the physical constraint bears the obligation. When a local DSO’s customers are blocked by congestion in the overlying regional or transmission grid, it is the overlying operator — not the local DSO — that must resolve the constraint. The local DSO cannot sign villkorade avtal on behalf of a bottleneck it does not control. The local DSO should instead request raised subscription capacity from the overlying grid, and report to Ei if resolution is unreasonably delayed (4 kap. 13 § ellagen). The local DSO can still use tariff design, procure flexible resources in its own grid, and help administer flexibility procurement on behalf of the overlying operator — but financial responsibility stays with the operator that has the physical constraint.

E.ON operational transition: E.ON received Ei’s approval for its villkorade avtal methodology on 19 March 2024, at which point it exited the pilot phase and entered fully operational status with standardized processes and routines for handling customer requests. (Source - E.ON Nätutvecklingsplan 2025-2034) Despite having an active villkorade avtal portfolio, E.ON has had zero activations since the framework was introduced — the SWITCH flex market has in practice always resolved congestion events before reaching the backstop threshold. This is the clearest operational evidence of the market-first principle working as intended, though it also means the backstop has never been tested against a scenario where market volume was genuinely insufficient.

Vattenfall Eldistribution uses villkorade avtal as its primary and sole flexibility tool — unlike E.ON which uses them only as a backstop to market-based procurement. Vattenfall applies villkorade avtal in its Uppsala area (Mellan) and Stockholm local grids, and uses bilateral agreements with large industrial customers in Norr (steel, mining) and Väst (petrochem) where stamnät subscription has not yet been granted. Vattenfall has explicitly stated it sees no conditions for market-based flexibility anywhere in its network, making villkorade avtal the operative grid management tool for all constrained locations. (Source - Vattenfall Eldistribution Nätutvecklingsplan 2025-2034)

Ellevio uses villkorade avtal as its primary current flexibility tool across all constrained delområden — in the same intermediate-tool role as Vattenfall, but with an explicit openness to market development. Ellevio’s DNDP explicitly states: “villkorade avtal en passande lösning i samtliga delområden där det finns ett behov” as long as market-based alternatives are absent. Ellevio uses the OpenADR SIMPLE variant with binary Curtail/Restore events (PT20M, pre-agreed power limits not transmitted in event payload, no real-time metering required) — distinct from E.ON’s more dynamic CONSUMPTION_POWER_LIMIT approach. (Source - Ellevio Nätutvecklingsplan 2025-2034, Source - Energiföretagen Supplement Conditional Grid Connections (2025))

Produktionsgaranti — Ellevio-specific tool: contracted agreements with large generation facilities within delområden that guarantee a certain production volume available for dispatch (avropas) when forecast consumption risks exceeding Ellevio’s subscription limit against the overlying network. This is a production-side variant of the flexible connection agreement concept: the generator commits to making production available (upward flexibility) rather than the consumer committing to curtail (downward flexibility). Used primarily in Värmland (hydropower, notably in the Höljes area) and Dalarna. The 350 MW production curtailment need reported in Dalarna (Tabell 3, 0–2yr horizon) is managed via a combination of produktionsgaranti agreements and Ellevio’s subscription management tools. Unlike standard villkorade avtal (which have consumers curtail consumption to reduce import demand), the produktionsgaranti ensures that local generation is available to meet demand on-call — reducing Ellevio’s net import need and thereby preventing subscription limit overruns. In Värmland, where significant hydropower capacity exists, this is a practical backstop: dispatch guaranteed production volumes during peak consumption hours to avoid exceeding the stamnät subscription. (Source - Ellevio Nätutvecklingsplan 2025-2034)

Göteborg Energi Nät (GENAB) introduced villkorade avtal in 2023 for all new connections above 1 MW. GENAB’s design is distinctive for its explicit philosophy:

• Threshold: All customers requesting or expanding to ≥1 MW receive 1 MW as guaranteed capacity (garanterad effekt); remaining capacity above 1 MW is villkorad
• Trigger hierarchy: Villkorade avtal are activated only after GENAB’s short-term forecast projects a shortfall and all other resources (grid reconfiguration, market-based flexibility via Effekthandel Väst, plannable production) are exhausted — the last step in GENAB’s Kapacitetsprogrammet’s operational framework
• Philosophy: “Vi ser detta som en sista åtgärd och inte som en aktiv flexresurs där målet är att de villkorade avtalen aldrig kommer aktiveras” — explicitly framed as last resort, not an active flexibility resource; the stated goal is that they are never activated

This “never activated” philosophy is notably different from E.ON’s overbooking model (where activation is part of the operating design) and Vattenfall’s active use. GENAB’s approach reflects the city grid context: customer disruption in a dense urban area is costly, and market-based alternatives are well-developed. (Source - GENAB Nätutvecklingsplan 2025-2034 (2024))

2. Ei must approve the method for contract terms before any villkorat avtal is signed. Under 4 kap. 46 § ellagen, no connection agreement may be entered into before Ei has approved the methods used to design its terms. A standard connection agreement method approval does not cover villkorade avtal — the terms regulating when and how transmission may be limited require their own separate approval. DSOs that have been signing villkorade avtal without approved methods for those specific terms are in breach of this requirement.

3. Activation is last resort; fresh assessment required before each dispatch. Non-market activation is only permitted after trading for the operating quarter has closed (gate closure) and all market-based alternatives are exhausted. Crucially: the assessment must be made before each individual activation — standing pre-authorizations are not valid. DSOs may communicate in advance that activation might be needed (e.g., after day-ahead market results), but the formal activation decision must wait until gate closure. Ei notes that the forthcoming Network Code on Demand Response will provide more detailed regulation on this.

4. Villkorade avtal may only be signed where actual capacity shortage exists. Preemptive use for potential future risk or general operational flexibility is prohibited. Terms implying broader curtailment rights than the DSO actually holds are deemed “oskäliga” (unreasonable) under ellagen. Ei also clarifies that if a DSO and customer want an ongoing voluntary flexibility arrangement, it cannot be embedded in the connection agreement — it must be procured as a separate service under open, non-discriminatory procedures (3 kap. 4 § ellagen or LUF).

Pending national framework: The amended Electricity Market Directive (new Art. 6a, introduced by Directive (EU) 2024/1711) requires Sweden to establish a national framework specifying when flexible connection agreements (conditional connection agreements) may be signed in areas with limited/no grid capacity. Transposition deadline: 17 July 2026. Art. 6a requires the framework to ensure: (a) flexible connections do not as a general rule delay network reinforcement; (b) conversion from flexible to firm connection is guaranteed when the network is ready; (c) flexible connections may be a permanent solution where reinforcement is not efficient, including for energy storage. (Source - Electricity Market Design Reform Directive (EU 2024-1711))

Ei R2024:14 confirms that Sweden’s existing villkorade avtal framework (EIFS 2022:1, updated per Ei2025:01) is in substance compatible with Art. 6a requirements — but is currently an Ei ställningstagande (position statement), not a formal statutory framework. Art. 6a will require transposition into Swedish electricity law (ellagen) or Ei regulations. The ellagen amendment (4 kap. 4a §, in force 2026-01-01) begins this process but the full regulatory framework remains pending. (Source - Ei R2024-14 Outnyttjad Kapacitet (2024))

Extension to energy communities: Commission Recommendation C(2026)2850, Rec 12, explicitly states that Energy Communities and final customers participating in energy sharing schemes should be able to enter into flexible grid connection agreements when operating storage or achieving high local self-consumption. This is the first Commission document to explicitly name energy communities as eligible parties for Art. 6a flexible connections — not just individual customers. (Source - Commission Recommendation C(2026)2850 Energy Communities)

Complementary to market procurement: Energiforsk’s methodology study (2025:1088) explicitly positions villkorade avtal and market-based mechanisms as complementary, not competing: villkorade avtal establish long-term capacity reservation and provide the contractual backstop, while the market procures the actual activation signal on a short-term competitive basis. A holder of a villkorat avtal can simultaneously participate in a flexibility market — winning a market bid means the market compensates them; the villkorat avtal activates only as backstop when market volume is insufficient. (Source - Energiforsk 2025-1088 Metodik Flexibilitet Elnät (2025))

E.ON overbooking model: The DSO Entity report (2026) describes E.ON Energy Networks’ Swedish practice as a European best-practice example: E.ON operates its grid at 130% capacity, using FCAs (villkorade avtal) to connect the additional 30% on a curtailment-risk basis, with the SWITCH flex market as the primary activation mechanism when the 100% threshold is approached. E.ON has signed flex contracts until 2029 with its large industrial customers and major aggregators. (Source - DSO Entity Distributed Flexibility Practices (2026))

EU and NC DR framework

The Clean Energy Package establishes the market-first principle: the Electricity Market Directive Art. 32(1) requires market-based flexibility procurement; rules-based approaches are permitted only where markets are uneconomic or would cause distortions.

The forthcoming Network Code on Demand Response (NC DR) goes further: Art. 51 of the ENTSO-E/EU DSO Entity proposal explicitly recognizes “flexible connection agreements” — the EU-level equivalent of villkorade avtal — but requires coordination with local services markets. This formalizes Ei’s position: villkorade avtal are legitimate, but must not undermine market-based flexibility. (Source - Ei Villkorade avtal (2023), Source - Ei Flexibility in Distribution Grids (2023))

EU comparative landscape for FCAs

An EC-commissioned comparative study (Fraunhofer ISI, August 2025) found that FCAs / villkorade avtal equivalents are predominantly applied as temporary solutions across all EU member states:

• Directive 2024/1711 Art. 6a explicitly permits FCAs to be permanent solutions where grid reinforcement is not efficient — but no EU country has systematically deployed permanent FCAs in practice
• The dominant pattern across all countries reviewed is temporary use (bridge to reinforcement), even where regulators have the legal authority for permanent agreements
• The practical barrier is regulatory confidence: permanent FCAs require long-term capacity commitments that DSOs and NRAs are reluctant to make without an operational evidence base

Chicken-and-egg problem: the study identifies a structural barrier: confidence requires data, but without confidence the experience that generates data is never accumulated. DSOs are reluctant to offer permanent FCAs without evidence they work well at scale; they cannot accumulate that evidence without deploying permanent FCAs at scale. The EC’s recommended approach is a model-based study on the costs and benefits of permanent vs. temporary FCA designs — analytical evidence as a substitute for operational experience where the latter is absent.

Sweden is identified as having one of the more advanced FCA frameworks in the EU (E.ON’s 130% overbooking model is among the most operational implementations in Europe), but remains in the temporary-dominant pattern. The Art. 6a national framework (transposition deadline 17 July 2026) will be Sweden’s first formal statutory basis for FCAs including the permanent option. (Source - EC Study Distribution Grid NDP Tariffs and Connections 2025)

Portuguese parallel — acesso com restrições

Portugal’s structural equivalent of villkorade avtal is acesso com restrições (restricted access). ERSE’s April 2025 opinion on E-Redes’ PDIRD-E 2024 explicitly recommends that E-Redes actively offer and publish restricted/flexible access capacity, framing it as a necessary tool given the gap between renewable capacity needs and available firm network capacity. (Source - ERSE Parecer PDIRD-E 2024)

ERSE’s recommended approach:

• E-Redes must quantify and publish available-but-not-firm network capacity, disaggregated by time of year and day type (weekdays/weekends) — i.e., capacity that could be offered on a restricted basis, excluding upstream TSO constraints
• This time-disaggregated figure shows what restricted access E-Redes could actively offer to producers and storage operators
• Restrictions from the TSO (upstream, high-voltage network) can be overlaid on top of E-Redes’ own local restrictions

Storage operators are the primary target: ERSE explicitly identifies standalone battery storage as potentially a “problem” (if requiring firm access for both injection and offtake) or a solution (if licensed with restricted access — enabling wholesale market arbitrage, ancillary services, and local DSO flexibility procurement via FIRMe). Storage operators should choose locations compatible with restricted capacity availability and develop their business model around it, rather than waiting for firm access.

Key difference from Sweden: ERSE is recommending E-Redes begin actively publishing and offering acesso com restrições — a prescriptive NRA push for active use. In Sweden, villkorade avtal emerged from DSO practice (particularly E.ON), with Ei standardization following after. Portugal is taking a top-down regulatory approach; Sweden was bottom-up.

FCA as complement, not substitute: ERSE is explicit that restricted access is a complement to network investment, not a replacement for it. This mirrors the Swedish industry position that villkorade avtal should not delay necessary grid development.

NC DR Art. 31 — three binding rules for flexible connection agreements:

Art. 31.1 — treated as firm connections in needs assessment: When a DSO assesses its flexibility needs (for FNA and DNDP purposes), flexible connection agreements / villkorade avtal shall be treated as firm connection agreements. The contracted villkorad kapacitet must be counted as if it were always-available capacity — meaning the DSO must report the full underlying grid constraint, not a reduced need because some of it is already covered by villkorade avtal. Exception: permanent solutions under Art. 6a.1.c. This ensures the FNA reflects true infrastructure gaps rather than procurement coverage. (Source - FNA Webinar 7 (2026-03-16))

Art. 31.2 — activation must coordinate with markets: When a Flexibility Market for local services exists, activation of flexible CAs must be coordinated through a mechanism specified in the market procurement rules. Additionally, if activation occurs after the day-ahead gate closure, the TSO must calculate an imbalance adjustment to the concerned balance responsible parties. This formalizes the market-first principle at EU level with more precision than previous guidance.

Art. 31.3 — market participation rights preserved: System operators shall not limit system users holding flexible CAs from:

• Providing balancing and local services in relevant markets (exception: grid prequalification limits and temporary limits)
• Participating in other electricity markets

This is a significant right: holding a villkorat avtal does not disqualify a resource from also bidding into SWITCH or other local flexibility markets. The CA governs curtailment as a contractual backstop; market participation remains open alongside it. (Source - NC DR Amended Text (ACER Recommendation 01-2025 Annex 1))

DNDP reporting requirement: DSOs must specify their planned contractual arrangements — including flexible connection agreements — in the DNDP flexibility section. This means each villkorat avtal portfolio is not only a grid management tool but also a planning data point that must appear in the DNDP and, through the FNAM Tabell 15 template, in the FNA. ACER/CEER (2025) explicitly lists “flexible connection agreements” as one of the contractual arrangement types DSOs must document in their DNDP flexibility sections, alongside market-based procurement options. (Source - ACER CEER DNDP Guidance (2025))

When are villkorade avtal appropriate? (industry workshop evidence)

A workshop with 42 participants (18 representing DSOs) in September 2024 rated tool suitability for different grid situations on a 1–10 scale. (Source - FlexAbility Delrapport 2 (2025))

For flexible resources (EVs, batteries, heat pumps): voluntary flex markets scored 8.7/10 — highest of any tool; villkorade avtal without compensation scored 4.7/10 — lowest. This is the starkest finding: villkorade avtal are widely seen as an unsuitable tool for managing inherently flexible resources where market signals should be the primary mechanism.

For variable production (solar/wind): villkorade avtal with economic compensation scored 7.1/10 — tied for highest alongside price signals. The mandatory nature is less objectionable when compensation is provided.

For additional consumption (new EV/heat pump connections): voluntary markets scored 7.1/10 and villkorade avtal with compensation 7.0/10 — essentially tied at the top.

Most appropriate situations for villkorade avtal (7.8/10):

1. Grid reinforcement arriving within 3–5 years — appropriate bridge tool
2. Areas where N-1 redundancy cannot be guaranteed after a fault

Least appropriate: areas with many similarly-sized customers (3.2/10) — competitive market conditions make markets clearly preferable.

Workshop consensus on overall role: supporting, alongside other measures. Only 4 of 42 participants considered villkorade avtal the primary solution.

Flex vs villkorade avtal: delivery reliability in practice

Sweco’s 2025 interview study provides an important calibration on how market actors actually perceive the two tools (Source - Sweco Kartläggning av lokala flexibilitetsmarknader (Ei, 2025)):

• Flex market delivery rate: ~80% of contracted flexibility is actually delivered, per DSO interviews. Gaps occur due to resource availability, forecast errors, or operational issues on the FSP side.
• Villkorade avtal delivery: perceived as near-100% reliable by DSOs, especially for production resources and battery storage that are already automated and connected to control centers.
• Practical implication: DSOs that must guarantee grid security prefer villkorade avtal as the backstop precisely because of this reliability gap. Markets are used for economic optimization and regulatory compliance, but the contractual safety net is villkorade avtal.

Production vs consumption asymmetry: villkorade avtal are used primarily on the production side (solar parks, batteries, wind) where activation is straightforward (automatic, clear alternative cost = lost production revenue). Consumption-side villkorade avtal are more complex: the customer’s opportunity cost is tied to their core operations and is difficult to assess.

The regulatory market-first principle means flex markets must be given the opportunity to clear before villkorade avtal are activated. In practice, the flex market handles what it can and villkorade avtal cover the residual — meaning the two tools are complementary, not competing.

OpenADR communication protocol

OpenADR is the industry-recommended protocol for DSO-to-customer communication for villkorade avtal. Adopted as a voluntary standard by Energiföretagen Sverige in October 2023 following a market evaluation by a joint DSO/CPO working group. The primary driver was standardization across DSO territories: CPOs (Charge Point Operators) with installations under conditional agreements at multiple grid companies would otherwise face the complexity of supporting different proprietary protocols for each DSO. (Source - Energiföretagen Branschrekommendation Conditional Grid Connections (2023))

In the OpenADR model: the DSO operates a VTN (Virtual Top Node — the server); the customer runs a VEN (Virtual End Node — the client). Events are published by the VTN when a grid threshold is exceeded; the VEN receives them via polling or webhooks and executes the required curtailment.

Two Swedish DSOs had live production implementations as of April 2025, with different technical approaches: E.ON uses dynamic CONSUMPTION_POWER_LIMIT events (PT15M, power limit included in each event, real-time metering required); Ellevio uses binary SIMPLE Curtail/Restore events (PT20M, limit pre-agreed, no real-time metering required). Full parameter comparison, heartbeat monitoring pattern, and CPO context at OpenADR › Swedish production implementations. (Source - Energiföretagen Supplement Conditional Grid Connections (2025))

SOU 2025:47 reform proposals

The Elmarknadsutredningen (SOU 2025:47) proposed a set of targeted reforms to the Swedish villkorade avtal framework, directed at Ei to investigate and implement:

1. Fee structure review — Ei should investigate how the fee structure for villkorade avtal should be designed, including whether a cost reduction in connection fees is appropriate where a conditional connection avoids a grid reinforcement cost

2. Permanent conditional agreements — Several neighboring countries (Netherlands, Denmark, Norway) distinguish between temporary conditional agreements (to expedite new connections during a congestion period) and permanent ones (an ongoing fee structure for the entire customer collective). The SOU asks Ei to assess whether Sweden should allow permanent agreements. Permanent agreements typically involve a reduced capacity fee — which directly increases incentives for flexible resources such as EVs and batteries to also participate on Balancing Markets, since their grid connection becomes cheaper when they agree to be curtailable

3. Existing customers — Under current Swedish rules, only new connections can receive a villkorat avtal. The SOU proposes investigating whether existing customers should be able to opt in, potentially significantly expanding the pool of available flexibility

4. Cascading between network levels — Ei should review whether villkorade avtal can be passed down between network levels: a bottleneck arising in the transmission network could be managed using conditional agreements in the underlying distribution network. This addresses the current situation where congestion at one level cannot be resolved using resources contracted at another level

These proposals were directed to Ei; they are assessments and mandates rather than legislative proposals. The legislative changes enacted through Prop. 2025/26:240 focus primarily on the BSP/BRP and default supply chapters rather than villkorade avtal specifically.

Regional and transmission grid level — essentially unused

Ei PM2026:05 (2026) provides the first systematic survey of whether villkorade avtal and other non-reinforcement alternatives have been used at the regional and transmission grid level (regionnät and stamnät). The finding is unambiguous: they have not.

Ei asked the seven companies covered (Ellevio, E.ON Energidistribution, Jämtkraft Elnät, Skellefteå Kraft Elnät, Vattenfall Eldistribution, Öresundskraft Elnät, Svenska kraftnät) how many cases of capacity shortage involved investigation or implementation of alternatives to grid reinforcement. In all cases where delays occurred, no alternatives were investigated or implemented. The reported reasons:

• Physical constraints dominate: three companies said that the facilities requiring connection were too large for existing grid, that no regional grid existed in the area, or that there were no physical conditions for power exchange — making market-based or contractual alternatives physically inapplicable
• Rules perceived as unclear: one company explicitly stated that the regulatory framework for villkorade avtal is “bedöms otydligt” (perceived as unclear), and that the company therefore does not apply such agreements to any significant extent at regional level
• Customer reluctance: one company (E.ON Energidistribution, which operates live flex markets at distribution level) noted that customers have shown limited willingness to enter villkorade avtal at regional level due to the increased risk of curtailment
• No method to evaluate alternatives: four of the seven companies have no established methodology to evaluate costs and benefits of non-reinforcement measures

This contrasts sharply with the distribution grid, where villkorade avtal are increasingly operational. The finding supports the underlying policy logic of Ei2025:02 (which requires DSOs to demonstrate flexibility alternatives were assessed before citing capacity shortage in connection delay cases) — precisely because the survey reveals they are not currently being assessed.

The PM also highlights that connection times at regional/transmission level are extreme: Svk’s 400 kV nätförstärkning connections averaged 7.8–8.4 years to complete, with one reaching 16.3 years. These timescales make the practical relevance of villkorade avtal as a bridge solution more complicated — but also more valuable if alternative pathways exist.

TSO-level equivalent and the anvisningssystem

Svenska kraftnät has explored conditional connection agreements at the transmission level — conceptually similar but applied to large generation/consumption connections to the stamnät rather than distribution-level customers. However, Svk’s feasibility study concluded that “managing full-scale implementation proved to be impossible with the systems and tools available today.” This highlights that the digital infrastructure challenge for conditional connections is even more acute at TSO scale, where the grid is more complex and the systems less mature for this type of operational flexibility. (Source - Svk Network Development Plan 2026-2035)

Svk’s April 2026 government assignment report introduces a related but upstream concept: the Anvisningssystem with kapacitetszoner. Rather than managing congestion operationally through curtailment (as villkorade avtal do), the anvisningssystem addresses congestion prevention upstream by shaping which customer categories connect where. Zone entry conditions can require flexibility commitments or production matching, embedding demand response capability as a precondition of connection rather than a post-connection tool. The two mechanisms are complementary: anvisningssystem conditions can include commitments to operate under a conditional connection regime once connected. (Source - Svk Anslutningsprocessen Rapport (2026))

(Source - E.ON Guide villkorade avtal (2025))