Changes in the regulation of invoices and how the lack of transparency affects electricity users, and the market was discussed when participants from the Nordic Energy Regulators (NRAs) met in Helsinki to exchange experiences.

The Danish, Finnish, Norwegian and Swedish NRAs all recognise that the high energy prices of the last two years have affected the retail electricity market in many ways, which for example, manifests itself in a greater variety of contract types and separate national electricity compensation schemes. According to the participants in the workshop, clearer invoices in combination with more transparent price information are of great importance to the customers. How information is communicated to customers was also recognised as a key factor.

The participants from the Nordic NRAs in the 6th Annual Monitoring Workshop arranged by NordREG, also shared their experience from national monitoring cases, compared possible remedial actions and learned from each other´s experiences. Among other things the participants discussed the challenges involved in monitoring suppliers who are reluctant or unwilling to co-operate with the regulators as well as market players who are either not covered by current legislation or new to the market. Companies that go bankrupt after only a short time on the market and then re-emerge in a different form were also discussed.

Furthermore, the price comparison tools and the possibility of automatic checks with the help of robots, were also an interesting and topic of the lively discussion.

Another enriching day of insightful presentations and discussions at the yearly NordREG Wholesale and Transmission Developments Seminar, which the Danish Utility Regulator, Forsyningstilsynet, hosted Thursday 23rd  of November at the Hotel Park Inn by Radisson, Copenhagen Airport.

Kicking off the event, Director Birgitta Bundgaard from the Danish Utility Regulator, which holds the current chairmanship of NordREG extended a warm welcome to the participants and speakers. Birgitta highlighted NordREG’s significant efforts throughout 2023, including collaborative work on a paper outlining NordREG’s positions on the European Commission’s proposed reforms for the electricity market.

The day unfolded with presentations updating us on regulatory processes by various NordREG task forces. Under the theme “well-functioning future Nordic markets,” speakers from ACER, EEX, Nord Pool, Nordic TSOs, and Green Power Denmark then shared their insightful perspectives. A recurring topic was the forward market, with speakers offering interesting and fruitful insights on how to enhance its functionality.

The seminar was concluded with a thorough summary made by Director Antti Paananen from the Finnish Utility Regulator, which is poised to take over the chairmanship for the NordREG Presidency in 2024. He expressed gratitude to all presenters and participants, emphasizing their shared commitment to key topics surrounding wholesale and transmission developments in the electricity markets.

NordREG would also like to extend a heartfelt thank you to all presenters and participants for valuable contributions. We are looking forward to our continued collaboration and progress.

The agenda and presentations can be found below:

1. Agenda NordREG W&T Seminar 2023

2. NordREG presentation

3. ACER presentation

4. EEX presentation

5. NordPool presentation

6. Nordic TSOs presentation

7. Green Power Denmark presentation

NordREG invites you to join us for the annual NordREG Seminar on Wholesale and Transmission Developments. This year’s chairmanship has been held by the Danish Utility Regulator (DUR) who will be the hosts of the seminar.

This year, the program is divided into two blocks. The first block will include presentations on updates on regulatory processes from the Chairs of the NordREG task forces on electricity balancing, capacity and system operation. In the second block the theme is well-functioning future Nordic markets where ACER will give a presentation on their discussions followed by the Nordic TSOs as well as presentations from other market actors.

Registration

Please register at the following e-mail address: nordregsecretariat@forsyningstilsynet.dk stating your full name, affiliation, and mark your email: “NordREG-seminar”.

Note that it is a physical seminar with in-person participation only.

If you wish to attend the seminar you are kindly requested to register as soon as possible and no later than 13th November 2023. The registration is on a first come, first serve basis.

When

23rd of November from 10:00 – 15:30, breakfast will be served between 09:00-10:00.

Where

The seminar will be held at Hotel Park Inn by Radisson Copenhagen Airport, Engvej 171 Copenhagen

We hope to see you in November!

Each year NordREG arranges a joint seminar on wholesale and transmission developments. This year the seminar will be held physically in Copenhagen, Denmark on 23 November 2023.

The purpose of the seminar is to inform market participants, by providing regulatory input and oversight, in current topics handled by NordREG as well as encouraging discussions on topics related to the current market developments.

NordREG aims at having the Nordic transmission system operators as well as market participants and other stakeholders as presenters and panelists at the seminar.

We expect to publish a registration form later with more information about specific time and agenda and hope that you will already now save the date for the event.

We look forward to meeting you in Copenhagen.

The Nordic NRAs find that the Nordic TSOs in the external parallel runs (EPR) report have demonstrated that the flow-based (FB) capacity calculation works sufficient in operational terms, given the current state of development. However, the Nordic NRAs conclude that there are still open issues beyond the key performance indicators (KPIs), and the Nordic NRAs request the TSOs to investigate and elaborate on those issues in more details during the upcoming 6-months of EPRs.

On June 12, 2023, the Nordic NRAs received from the Nordic TSOs a report on the results and elaborations from the EPRs of the FB capacity calculation methodology.

Background

The EPR report is part of the process of implementing a FB capacity calculation methodology, which, in accordance with the CACM Regulation, was proposed by the Nordic TSOs in 2017. The Nordic NRAs approved the methodology in 2018, and it was amended in both 2019 and 2020. As part of the approval process in 2020, the Nordic NRAs decided to have a checkpoint, before the remaining 6 months of EPRs will take place.

The purpose of this EPR report is to provide the Nordic NRAs with information to facilitate the implementation process of the approved methodology. This checkpoint is intended as a tool for the NRAs to ensure that the FB capacity calculation is working sufficiently well at an operational level in accordance with the approved methodology. The EPR report has also the purpose to keep relevant stakeholders informed on the implementation processes ahead of the go live. To do so, the Nordic NRAs established a set of KPIs, which the TSOs were obliged to follow in the EPR report.

Remarks to the June 2023 EPR report

In order to ensure a successful implementation and further improve the understanding of the methodology, the Nordic NRAs note that the TSOs should provide clear communication and full transparency on the results of the EPRs.

Nordic NRAs note that there are still many questions from the stakeholders, which have not yet been fully answered. The Nordic NRAs emphasize the importance for the TSOs to follow up on all stakeholders’ FB related questions and remarks.

The results in the EPR report show that the FB methodology produces results that differ notably compared to the current application of NTC in several aspects. The change from NTC to the FB methodology will therefore affect all stakeholders in the Nordic market as well as import and export capacities from the Nordic region and other countries. The level of impact the change from NTC to the FB methodology seems to have on final consumers’ electricity bills further imply that the TSOs must continue to be cautious and examine all details in the months to come.

To provide increased learning about the concrete impact of the transition to the FB methodology, NRAs expect TSOs to provide clarification and explanation of the EPR results on an hourly basis as outlined below:

• What results relate to the TSOs’ current NTC practice and what relate to the features of the new methodology?  This issue applies to the ATCE results in the intraday market as well as to the FB results in the day ahead.
• Hours of particular interest should be highlighted, and the results explained in light of specific conditions within the operational hour, where relevant.
• In order to provide increased understanding of the comparison of welfare during the EPRs, the TSOs should elaborate on their costs of countertrading or redispatching, which they have incurred by the current NTC practice, and which would not apply to the new methodology.
• TSOs should clarify to what extent the EPR results relate to issues in the concrete modelling of FB or of ATCE.
• NRAs have noted concerns from the stakeholders regarding the handling of the ATCE capacities at go live on some borders given non-intuitive flows in DA. More clarification is needed by complementing the EPR results with additional analysis that looks specifically at these concerns.

Moreover, NRAs have taken note of the unanimous stakeholder concern about the lack of transparency related to CNEs in SvKs’ network throughout the EPR process as well as in their comments to the EPR report. This transparency issue is due to SvK’s practice of anonymization of CNEs, without stable identifier.  NRAs’ foresee that SvK will see to that their practice on publication of CNEs will be compatible with art. 25(5) in the CCM.

Further implementation process

The upcoming EPRs will be important in providing both TSOs and stakeholders with additional necessary information and learning before going live. Given the substantial changes seen in the price formation on the day ahead market, the Nordic NRAs find it important that TSOs continually and transparently, evaluate the outcome of the operational implementation process with the approved methodology. Furthermore, the Nordic NRAs request the TSOs to extensively communicate the progress to the Nordic NRAs and the stakeholders during the upcoming months of EPRs, both via regular stakeholder seminars and in meetings with the Nordic NRAs.

Thus, the upcoming months of EPRs shall provide the stakeholders and Nordic NRAs confirmation that the FB capacity calculation methodology and ATCE is ready to go live.

Furthermore, the Nordic NRAs emphasize that the Nordic CCM will be further amended in the years to come. We foresee that amendment processes on the CCM will be one of TSOs and NRAs’ regular tasks. Stakeholders’ comments will be valuable inputs to these processes. Finally, the Nordic NRAs stress that the analyses of the FB methodology itself should continue during the process of FB implementation to detect improvements to the methodology. The Nordic NRAs recognize the importance of stakeholder involvement in this process.

Read the full EPR report published by the TSOs

The implementation of the independent aggregator role is on its way in the Nordic countries, and we expect that allowing for independent aggregation will help unleash the potential of demand side flexibility, distributed production, and energy storage.

NordREG has previously made the assessment (Nordic Regulatory Framework for Independent Aggregation) that in cases where a central settlement model is applied a compensation for the transfer of energy in accordance with Article 17(4) of the Electricity Markets Directive may be important in order to avoid market distortion. However, the design of the compensation mechanism is important since a too high or a too low compensation can lead to market distortion and an inefficient use of resources. The goal should be to find a level of compensation that leads to the most efficient outcome.

NordREG has commissioned a study

To learn more about how different levels of compensation may affect the independent aggregators and the suppliers NordREG has commissioned a study from Compass Lexecon. The study provides insights on how different levels of compensation may impact the independent aggregator’s prospects to participating in the different markets (DA-, ID- and balancing markets) and also how the level of compensation may impact the revenues of suppliers.

Consultant report – study from Compass Lexecon: Finding an adequate level of compensation for demand-side flexibility

Next step

The report gives input to the discussion on how a compensation mechanism might be organized. NordREG will continue to discuss this and other aspects related to the implementation of the independent aggregation role in the the Nordics.

Nordic energy regulators (NordREG) have together responded to the European Commission’s public consultation on the Electricity Market Design. In addition to the consultation response, NordREG has also published and submitted to the European Commission a joint position paper highlighting the fundamental principles which in NordREG’s view should guide the upcoming work on how to address the issues of the electricity market and how to reshape the current market design.

In the response to the European Commission’s public consultation NordREG is positive towards the short-term market as it delivers efficient price and dispatch signals as well as efficient investment incentives. NordREG finds that marginal pricing remains the best choice for encouraging correct bidding behaviour. Also, NordREG is positive towards the forward market, and has highlighted positive experience with virtual hubs in the Nordic region.

On the other hand, NordREG does not support CfDs*. NordREG finds CfDs creates distortionary incentives, especially around low/negative prices, it has a very negative impact on hydropower and it removes liquidity from forward markets. Furthermore, NordREG is negative towards public PPAs, especially when obligatory and/or physical. Lastly, NordREG is negative towards the inframarginal cap, as it hampers investments in capacity for those hours where electricity is most expensive.

• NordREG’s response to the consultation can be found here: NordREG response Public Consultation Revision of the EU’s electricity market design.

NordREG’s position paper points towards five fundamental principles to guide the further work towards the issues of the electricity market and changes to the current market design: Short Term Markets are Functioning Well, Market Distortion and Fragmentation should be avoided, NordREG supports improvements in the European forward markets, A reform of the electricity market design should be based on Impact Assessments and Competitive retail markets provide real benefits to end users.

• NordREG’s position paper can be found here: NordREG Position Paper on the European Commission´s Consultation and Prospective Changes to the Electricity Market Design

The Commission’s consultation and prospective changes to the electricity market design is aimed at addressing the current energy crisis, which threatens the economic and social welfare of the European countries and the EU. The crisis has led to high prices, which negatively affects consumers and the overall economy, as well as concerns for security of supply.

*NordREG understands the typical two-way CfDs in question here entail (i) the state as a single buyer, (ii) settlement with single strike price (typically against the DA price) and produced volume and (iii) direct settlement with all consumers through taxes and levies (bonus or malus)

NordREG is a cooperative initiative between Nordic energy regulators. NordREG actively promotes efficient and advanced energy markets, for the benefit of consumers towards a decarbonized society.

NordREG has published a revised Strategy, the Work Program for 2023 as well as the Annual Report for 2022.

NordREG Strategy

For more than two decades NordREG has provided a constructive platform for coopetation between the Nordic energy regulators. The energy crisis and ambitious climate goals have highlighted the need for continued cooperation and NordREG has revised the strategy to ensure that it reflects the recent developments and rapid changes in the energy market. Our vision is “Efficient and advanced energy markets, for the benefit of consumers – towards a decarbonized society”. The vision points out the direction in which we are going and the strategy envisions where we are going in the long run. Correct price signals, active consumers with access to information and a dynamic framework enabling advanced energy markets and green transition are strategic principles which will guide the NordREG cooperation in the years to come.

• Read more: NordREG Strategy Report

NordREG Work Program 2023

The NordREG Work Program describes the tasks and activities for the upcoming year where the continued implementation of the Clean Energy Package as well as the network codes and guidelines remains important. We will also continue the cooperation regarding the Nordic end-user market as well as increased focus in the area of flexibility.

• Read more about the upcoming work in 2023: NordREG Work Program 2023

NordREG Annual Report 2022

The year of 2022 was characterized by surging energy prices across Europe. NordREG has continued the cooperation that aims to promote and develop efficient electricity markets in the areas of retail, wholesale and transmission, network regulation and demand side flexibility.

• Read more about the work carried out during 2022: NordREG Annual Report 2022

Most challenging monitoring cases and how high energy prices affect consumers were in focus when participants from the Nordic Energy Regulators (NRAs) met to exchange experiences on how to monitor retail markets more effectively.

The Danish, Finnish, Norwegian and Swedish NRAs all recognise that the range of contracts on the electricity market is changing. Fixed price contracts seem to diminish, and contracts based on spot price are increasing. Sweden and Finland are experiencing the biggest changes due to the large percentage of fixed price contracts in these countries. Comparison tools may also need to be adjusted because of new products on the market.

At the 5th Annual Monitoring Workshop arranged by NordREG, participants from the Nordic NRAs shared experience from national monitoring cases, compared possible remedial actions and learned from each other´s experiences.

The participants also discussed challenges regarding how to monitor and compare contracts due to how the term “price” is used. All four NRAs experience that price components vary and differ between different suppliers and contracts which makes monitoring more complicated.

In addition, participants also talked about the various support schemes applied in the countries.

The most active customers are found in Finland where 40 percent signed a new contract during the last 12 months. The least active are found in Sweden where only 25 percent recently signed a new contract.

In May/June 2022, Nordic energy regulators conducted a customer survey. In the survey, 6,000 customers in Denmark, Finland, Norway and Sweden answered questions about when they last signed or compared electricity contracts, why they were active or not, how much they know about their own contract, and whether it was easy or difficult to sign an electricity contract. A similar survey was conducted in 2018 and the results from the two surveys are compared in the report that is published today

Customers also seem to be more digital than four years ago. In Norway 17 percent signed a new contract to get updated information about their own consumption, for example in an app or on the supplier’s website. More customers are using comparison tools and are searching online for a new contract. In addition, the share of customers with electronic bills has increased. In Denmark only 6 percent still receive a paper invoice by mail.

At the time of the survey, the electricity prices had risen sharply. The customers in the survey then stated that their household economy to some extent been affected by the high electricity prices, and to a high extent that the price increase will affect their future choice of electricity contract.

Moreover, one in ten electricity customers in Denmark, Norway and Sweden had experienced problems with their new electricity suppliers after signing a contract. The most common problem was that the terms of the contract turned out to be different than expected or that the price was higher than stated in the contract. Eight out of ten of those affected by problems stated that they had complained to the company and seven out of ten that the complaint had led to a solution. Younger people experienced problems more often than older people.

In Finland only one in twenty had experienced problems after signing a contract.

Download the full report: Nordic customer survey 2022

Download the Nordic Customer Survey 2022:  Table report Total