Guidance on the Implementation of Energy Sharing - Eurelectric Position Paper

Executive Summary 

Key issues to address 

Energy sharing, including peer-to-peer energy trading, collective self-consumption and energy communities, is a positive opportunity for small customers to participate more concretely in the energy transition in their local community. It will foster individual involvement and awareness on energy topics while providing an opportunity for new decarbonisation solutions for the energy system.  

Proper implementation is key to unlock all the potential benefits that energy sharing has to offer. An inadequate and overly complex framework risks causing serious consequences to the electricity market and system and undermine the advantages energy sharing provides. Energy sharing should not endanger local power grid and supply security, which would in turn put customers at increased risk. 

Eurelectric has identified some key issues that Member States and the Commission should address while transposing the changes in the Directive 2019/944 on common rules for the internal market for electricity and drafting implementing acts, namely: 

• The impact of energy sharing on retailers’ activity, especially in terms of costs allocation, responsibilities and information sharing 

• The impact of energy sharing on wholesale and retail markets, as well as network distribution tariffs, as more customers are able to participate more directly in these markets 

• The impact on customers regarding service quality, energy prices, and customer protection for both customers participating in energy sharing as well as those benefitting only from traditional supply 

• Impact on system operators’ activity, including concerns on data management and sharing, investments needed to support the rapid onboarding of energy sharing assets and possible increased congestion on the network 

5 asks for implementation 

Eurelectric expresses 5 key asks for a fair and functional implementation of energy sharing: 

1. Devise a fair cost, tax and network charge allocation and compensation scheme to avoid discrimination among market actors, distortion of competition and cross-subsidisation associated with energy sharing 

1. For the same reasons listed above, provide a clear definition of individual parties’ rights and obligations while mitigating the administrative burden 

1. Ensure the existing consumer protection framework is fit for purpose so that the implementation of energy sharing does not put active customers at increased risk 

1. Support investments and create structures so that energy sharing can lead to greater alignment of energy supply and demand in terms of time and location, and thus contribute to more efficient use of the local electricity grid 

1. The regulatory framework must take into account what energy sharing has to offer in terms of flexibility, but as indicated in the first point, in a way that does not lead to discrimination among market actors, distortion of competition or cross-subsidisation of costs. This consideration should include a thorough impact assessment looking into how energy sharing can contribute flexibility services to the system