COMMISSION STAFF WORKING DOCUMENT Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Digitalising the energy system - EU action plan
Date: 2022-10-18
Institutions: Directorate-General for Energy, European Commission
Subjects: EU action, EU energy policy, digital transformation, electrical energy, energy consumption, energy grid, energy transition, information security, innovation, investment, smart technology

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 18.10.2022  SWD(2022) 341 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Digitalising the energy system - EU action plan {COM(2022) 552 final}  
 
 
1  Contents 

1.  Digital and green transformation of the energy system ..................................................... 2 

1.1  Digitalisation in the energy system ............................................................................. 2 

1.2  Towards a decentralised, decarbonised and flexible energy system ........................... 3 

1.3  The benefits for citizens and consumers ..................................................................... 6 

1.4  Enabling cooperation and collective action ................................................................ 8 

1.5  Cooperation to share knowledge ............................................................................... 11 

2  Developing an EU framework for sharing data to support innovative energy services .. 12 

2.1  Context ...................................................................................................................... 12 

2.2  Evidence, projects and best practice ......................................................................... 14 

2.3  Key actions ................................................................................................................ 20 

3  Details on actions to promote investments in a smart electricity grid ............................. 26 

3.1  Support the development of a Digital Twin of the EU Electricity Grid ....................... 28 

3.2  Support the definition of common smart grid indicators .......................................... 29 

4  Details on actions to empower consumers ....................................................................... 30 

4.1  Digital tools for energy communities and other collective action initiatives ............ 30 

4.2  Peer-to-peer trading ................................................................................................... 30 

4.3  Support upskilling and reskilling of the workforce for the digitalisation of the energy 
value chain .......................................................................................................................... 32 

4.4  Dedicated structures supporting upskilling and reskilling for digitalisation of energy 
value chain .......................................................................................................................... 33 

5  Cybersecurity and resilience ............................................................................................ 34 

5.1  Context ...................................................................................................................... 34 

5.2  Evidence, projects and best practices ........................................................................ 36 

6 

Energy consumption of the ICT sector ............................................................................ 38 

6.1  Context ...................................................................................................................... 38 

6.2  Key actions ................................................................................................................ 42 

7  Annex: Summary of the sample of projects co-funded by Horizon 2020 programme with 
cybersecurity components ........................................................................................................ 57 

1 

 
 
 
 
 
 
 
 
1.  Digital and green transformation of the energy system 

1.1  Digitalisation in the energy system  
Digitalisation is developing at an exponential rate, internet traffic has tripled in only the past 5 
years and around 90% of the data in the world today were only created in the last 2 years.1 The 
increase  ICT  sector’s  use  of  energy  also  follows  this  trend  –  it  currently  accounts  for 
approximately 7% of global electricity consumption and this is forecast to rise to 13% by 2030.2 
Digitalisation is not new to the energy sector, however: the energy sector was one of the early 
adopters of digitalised solutions, many of which have already been in service for decades. The 
early developments took place mainly in a few areas of the value chains (e.g. large power plants 
or  electricity  transmission  networks),  while  the  more  recent  ones  span  across  the  whole 
spectrum. Since the 1970s, digital pioneers have been using emerging technologies to facilitate 
grid  management  and  operations  and  or  to  improve  decision  making  for  exploration  and 
production assets. The planning and operation of wind and photovoltaic (PV) installations uses 
geo-information systems and advanced weather models. Sensors help to maintain power plants. 
Modelling tools optimise the planning of wind farms or predict the re-charging needs of the 
growing  number  of  electric  cars.  The  digital  transformation  is  accelerating,  widening  and 
deepening.  More  computing  power,  improved  connectivity,  as  well  as  better  sensors  and 
algorithms.  

Main characteristics of digitalisation 

Apart from the move away from analogue solutions, access to ever more information and 
the rapid rate of innovation in computer and communication tools, the main characteristics 
of digitalisation are as follows.  

Access: 

Falling costs for measuring and sharing information have made data 
a valuable private and public resource. 

Algorithms: 

Combining information faster and smartly enhances forecasting and 
leads to better decision-making 

Automation 

A growing number of tasks can be delegated and executed without 
humans – for example, virtual assistants and self-driving cars. 

Source:  Hafner,  Manfred  /  Luciani,  (2022),  The  Palgrave  Handbook  of  International  Energy  Economics  Cham, 
Switzerland 

The  decentralisation  of  energy  generation  and  millions  of  connected  smart  appliances,  heat 
pumps and electric cars transform the last meters in the distribution grids into the first, and 
operators have to invest in monitoring and control capabilities. Improving the performance of 
wind  turbines  depends  on  digital  technologies,  for  example  by  equipping  wind  blades  with 

1  

International 
Digitalization 
https://iea.blob.core.windows.net/assets/b1e6600c-4e40-4d9c-809d-
1d1724c763d5/DigitalizationandEnergy3.pdf  

Agency, 

Energy 

and 

Energy, 

2017, 

2   Bertoldi, P. ; Avgerinou, M.; Castellazzi, L. (2017)  “Trends in data centre energy consumption under the 
European Code of Conduct for Data Centre Energy Efficiency”, EUR 28874 EN, Publications Office of the 
European Union, Luxembourg, 2017, ISBN 978-92-79-76445-5, doi:10.2760/358256, JRC108354 

2 

 
 
 
 
                                                 
 
sensors to gather more precise data on their performance and improve (predictive) maintenance 
that  will  reduce  outage  times.  Building  detailed  digital  models  of  energy  assets  based  on 
detailed sensoring and large data-sets to model performance under various circumstances, also 
known as digital twins, can improve performance of these energy assets or reduce the costs of 
research  and  experiments  through  virtualisation.  High-Performance  Computing  is  already 
contributing to the energy transition, for example by improving wind plant performance, by 
improving the understanding of the physics of solid-state batteries, or by better hydrological 
modelling that is key in reservoir management for hydropower production.3  

Smart Computer for the Energy Transition 

In Northern Germany large quantities of wind power are fed in to the grid: at peak times, 
this  is  often  more  than  can  be  transported  via  power  lines  to  the  south  and  west  of  the 
country, where many large consumers are located. German TSO TenneT and experts from 
the  Jülich  Supercomputing  Centre  (JSC)  have  developed  a  special  computer  system  that 
enables to perform numerous calculations in parallel for the optimal adaptation of the grid 
and design of new lines: with this system computer simulations of the power flows were 
accelerated more than 30 times.  

Source:  Smart  Computer 

the  Energy  Transition 
https://www.fz-juelich.de/en/news/archive/press-release/2018/2018-07-31-tennet  

(fz-juelich.de),  press 

for 

release  31 

July  2018:  

In the upcoming years, the digitalisation process will evolve into service-oriented architectures 
and moving beyond today’s cloud computing ecosystems.  Artificial intelligence can help to 
optimise the management and operation of the energy grids or to optimise the room temperature 
in  smart  buildings.  With  the  rise  of  the  platform  economy  and  personal  data  becoming  a 
valuable  commodity,  new  opportunities  and  challenges  for  the  governance  appear. 
Uncertainties,  if  connected  appliances  that  offer  more  comfort  might  also  open  the  door  to 
espionage and cyber-crime, could hinder the digital transformation if left unchecked. Also, the 
increasing energy consumption of the IT sector – improvements in energy efficiency are outrun 
by the increase in use of IT – poses a challenge to policy makers. 

1.2  Towards a decentralised, decarbonised and flexible energy system  

To meet the Green Deal objectives in the most cost-efficient way requires an energy system 
that is much smarter and more interactive than it is today. Increased grids’ observability and 
controllability, improved forecasting of energy production from distributed energy resources, 
and seamless integration across different operators in actively managing their systems are all 
innovative  digital  solutions. 
examples  of  new  needs  and  challenges 
Decarbonisation, electrification and decentralisation of the energy system require digitalisation 
to make it work. The Green Deal and the Digital Agenda need to go hand-in-hand as a twin 
transition.  

that  require 

3     January  2022,  Exascale,  a  great  opportunity  for  Clean  Energy  Transition  in  Europe,  European  Energy 
and  Energy-oriented  Center  of  Excellence,  Brussels:  https://www.eera-

Research  Alliance 
set.eu/component/attachments/?task=download&id=771, page 10-12  

3 

 
 
 
 
 
 
 
 
                                                 
  
The value of flexibility in the energy system 

Most renewable energy sources generate fluctuating amounts of energy, because they rely 
on the availability of sun,  wind or water. This  fluctuation  creates a significant  mismatch 
between generation and demand. Balancing the system requires adding flexibility through 
an array of solutions on four different levels: 

flexible energy generation (including biomass and geothermal) 

 
  storing energy and releasing it later through batteries or other options 
  markets linking the supply and demand of flexibility 

Digitalisation  interconnect  all  the  relevant  parts  of  the  energy  system  and  enabling  end 
consumers to access markets directly. Most renewable energy sources are of a variable nature. 
The availability of sun, wind, or water varies from seconds to seasons. This variability creates 
a potential mismatch between generation and demand. Balancing the energy system depends 
on adding flexibility, on both supply and demand sides. This flexibility ideally connects locally 
and system-wide, through an array of solutions that can address the fluctuations inherent in 
renewable  energy  sources.  Such  flexibility  will  be  particularly  important  for  short-term 
fluctuations,  whereas  it  is  unlikely  to  be  an  efficient  or  sufficiently  scalable  solution  for 
seasonal fluctuations that require long-term energy storage. This ‘smartness’, in turn, will avoid 
additional capital expenditures for enhancing the existing grid infrastructure, and allow a faster 
deployment of electric cars, decentralised renewables, and other technologies - due to reuse of 
existing infrastructure.  

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 1: Flexibility in the Energy System 

 Source: Energy Transition Expertise Centre (2021) Digitalisation of Energy Flexibility, p. 12 

The  need  to  integrate  an  increasing  amount  of  renewable  energies  while  maintaining  the 
security of energy supply, the decentralisation of energy generation and advent of prosumers, 
and the flurry of Internet of Things (IoT) devices connected to the grid require novel solutions 
and  energy  services  to  facilitate/incentivise  flexible  energy  consumption  and  demand  side 
management. All these services and the new actors emerging on the energy markets, ranging 
from  aggregators  and  providers  of  flexibility  to  prosumers,  are  relying  on  readily  available 
energy data.  

More specifically, realising such a smart system requires access to data, the ability to operate 
smooth and transparent data exchanges, and an effective management of data use and reuse. 
Operating the modern energy systems  and accommodating the variety of new technologies, 
products, as well as new business models and market players to enhance the flexibility require 
bi-directional  communication  capabilities,  data  exchanges  and  data  sharing.  Not  only  the 
energy, but also data must flow freely in the system4.  

In its turn, the quantity of data that is generated and used has been increasing at an exponential 
scale over the past several years while opening opportunities for data-driven innovation and 
new investment models. Thus, ensuring a coherent and coordinated European framework for 
data  sharing  and  (re-)use,  based  on  common  approaches  that  ensure  interoperable  solutions 
becomes an overall objective sought by numerous stakeholders. 

Despite the digitalisation of energy is already happening there is still a significant gap to come 
to a smart and flexible energy system. One essential element where more is needed, is to create 
suitable electricity infrastructure as well as digital-ready regulatory frameworks. Smarter grids 

4 

JRC Science for policy report - Digital Transformation in Transport, Construction, Energy, Government and 
Public Administration, 2019 

5 

 
 
 
 
 
                                                 
are the backbone of the digitalisation of the energy system. It is therefore essential to  foster 
investments in smart grids development and related enabling digital solutions. 

Smart charging in Stromnetz Hamburg 

The decentralisation of energy generation and millions of connected smart appliances, heat 
pumps and electric cars transform the last meters in the distribution grids into the first, and 
operators have to invest in monitoring and control capabilities. An assessment for Hamburg 
(Germany)  indicated  the  cost  savings  potential:  EUR  2  million  investments  in  smart 
charging  to  decrease  simultaneous  demand  can  prevent  EUR  20  million  costs  for  the 
necessary reinforcement of the grid to cater for a share of 9% of electric vehicles in the city.  

Source:   Stromnetz  Hamburg  (2018),  Elektromobilität  –  Netzausbaustrategie  und  Restriktionen  im  Hamburger  
https://www.hamburg.de/contentblob/10993526/1f90214d9b07e4de6323c078ff779d9d/data/d-

Verteilnetz 
anlage-13-pra%CC%88sentation-snh-20180504-energienetzbeirat-snh.pdf 

Example: IElectrix  

IElectrix is an EU-funded project that aims at developing innovative technical solutions and 
economical business models to facilitate the implementation of Local Energy Communities. 
This is also a way to speed up the integration of Renewable Energy Sources in Smart Grids 
and to increase the grid resilience and thereby the security of supply.  

The  IElectrix  project  consists  in  implementing  different  smart  grids  demonstrators  to 
experiment  a  set  of  functionalities  required  to  keep  up  with  the  current  energy  sector 
transformation:  renewable  intermittent  energies,  digitalisation,  decentralisation,  and 
consumer’s implication.  

Source:   IElectrix - Integrated local energy systems (Energy islands) (ielectrix-h2020.eu) ; Website: Indian and European  
Local Energy Communities for Renewable Integration and the Energy Transition. | IELECTRIX Project | Fact 
Sheet | H2020 | CORDIS | European Commission (europa.eu) 

1.3  The benefits for citizens and consumers  

Through different pilots, the project aims at overcoming the challenges posed by diverse 
geographical, technical and economic situation. The decentralisation of energy generation 
and millions of connected smart appliances, heat pumps and electric cars transform the last 
It may seem contradictory to address the need for investments in grids at a time where the EU 
meters in the distribution grids into the first, and operators have to invest in monitoring and 
is experiencing particularly high energy prices and fears shortages of energy for the coming 
control  capabilities.  An  assessment  for  Hamburg  (Germany)  indicated  the  cost  savings 
winter,  due  to  Russia’s  war  of  aggression  against  Ukraine.  These  high  energy  prices  had  a 
potential: EUR 2 million investments in smart charging to decrease simultaneous demand 
particular impact on the energy poor and the more vulnerable households, for whom energy 
can prevent EUR 20 million costs for the necessary reinforcement of the grid to cater for a 
already  represented  a  higher  portion  of  their  average  expenditure.  Increased  renewables 
share of 9% of electric vehicles in the city.  
production and increased energy efficiency  could help mitigate the impact of such episodes 
and  reduce  the  EU  dependence  on  energy  imports  (as  stated  in  the  REPowerEU 
Source:   Stromnetz  Hamburg  (2018),  Elektromobilität  –  Netzausbaustrategie  und  Restriktionen  im  Hamburger  
Communication). But, in addition to other measures, this requires a smart energy system that 
https://www.hamburg.de/contentblob/10993526/1f90214d9b07e4de6323c078ff779d9d/data/d-
empowers citizens through better and more innovative energy services and digital tools. 

Verteilnetz 
anlage-13-pra%CC%88sentation-snh-20180504-energienetzbeirat-snh.pdf 

For example,  it is  essential  that consumers have  the option to  access  their energy data, and 
ensure that they have the appropriate knowledge of how to use it for them to be able to adopt 

6 

 
 
 
 
 
 
 
more  energy-efficient  consumption  patterns  and  reap  further  benefits  of  energy-efficient 
behaviour.  For  instance,  such  was  the  goal  of  the  EU-funded  ECO2  (Energy  Conscious 
Consumers) project5, which created thee-learning Act4eco.eu platform, which provides 22 e-
learning  modules  that  consumers  can  use  to  learn  how  to  plan  and  improve  their  energy 
efficiency. 

Many Member States now make it possible for households to equip their homes with smart 
meters  to  follow  their  energy  consumption  on  a  day-to-day,  or  even  real-time  basis.  This 
information  and  insight  into  their  energy  use  can  help  them  take  control  of  their  energy 
consumption,  make  informed  choices  on  when  and  how  to  consume  and  opt  for  the  most 
suitable pricing contract. Moreover having the appropriate information, consumers will be able 
to  improve  their  energy  habits  for  making  savings,  and  manage  their  energy  behaviour  to 
reduce their bills, which is especially important in the current high and volatile price context .6 
Smart meters can also support a wider-range of tariffs that encourage consumers to shift their 
energy usage to off-peak cheaper times. This helps consumer save money and it would reduce 
the pressure on the energy system to activate fossil fuel capacity, including gas, at peak times. 

Furthermore, digitalisation allows to automate the reaction to price-signals or other incentives: 
consumers  can  use  their  electric  vehicles  and  other  small  and  easy-to-mobilise  assets  (i.e. 
batteries  and  heat  pumps  which  can  provide  energy  storage  and  enable  bidirectional 
recharging) to increase grid efficiency and help the system operators to avoid costly network 
reinforcements  thus  lowering the use of system  charges. This  can also  be the best  response 
when too much renewable electricity is produced (digital tools can provide information in real 
time on the renewable electricity and of GHG emissions share in the grid, so that consumers 
can use clean electricity to charge their electric vehicles). 

Digital  tools  such  as  smart  meters  have  helped  to  empower  consumers  in  recent  years. 
Simplicity is crucial: tools and services must be easy to understand and use so that users do not 
revert back to their old consumption patterns, lose interest and even disengage. Users may find 
it difficult to understand and apply concepts such as energy flexibility. It is therefore of crucial 
importance  to  increase  their  trust  in  demand-side  management  and  associated  innovative 
energy services so that they can fully exploit the potential of digital tools. Overall, new business 
models and actors should be encouraged in the market, as they will facilitate the introduction 
of innovative products and make it easier for consumers to recognize the benefits and subscribe 
into new energy services.   

To  fully  unlock  the  potential  of  the  opportunities  of  digitalisation  and  facilitate  end-users' 
participation  in  the  system,  awareness  and  learning  must  support  the  twin  transitions. 
Consumers must be able to operate these new innovative tools so that new vulnerabilities are 
not created and no one is left behind. Successful green and digital transitions require significant 
changes in organisational culture, leadership profiles, mind-set and skillsets. 

Matching  technological  innovation  with  innovation  in  social  practices  and  relations  (both 
individually and collectively) is crucial for the success of the twin green and digital transitions. 
Digital  innovation  and  social  innovation  reinforce  each  other.  Disparities  between  different 
consumer  groups  (e.g.,  different  levels  of  digital  skills  or  different  levels  of  willingness  to 
participate in the energy markets) mean that the design of digital tools and solutions must adapt 

5   http://eco2project.eu/  
6   For instance, without smart metres consumers have no control over their bills when suppliers adjust prices. 

7 

 
 
                                                 
to  differing  needs.  Different  consumer  groups  (e.g.  on  the  basis  of  consumers’  principal 
motivations and/or their willingness to engage) have been proposed7 .Digitalisation provides 
an additional opportunity for consumers to engage in the energy market, because the inherent 
flexibility of digital tools makes it possible to adapt designs to each consumers’ specificities 
and preferences.  

1.4  Enabling cooperation and collective action  

Communities as well as individuals can participate in the energy market. Since the 1970s in 
Denmark and Germany, some communities and local groups have come together to invest in 
shared renewable production assets, share the resulting benefits and exchange information and 
best practices on supporting the energy system. More recently, social innovation and digital 
innovation have reinforced each other. Energy communities (as defined by the Clean Energy 
for  All  Europeans  Package,8)  are  important  drivers  of  innovation  due  to  the  disruptive  and 
decentralised  nature  of  their  activities  (community  networks,  energy  sharing,  self-
consumption), and they have more recently enjoyed increasing attention and popularity.9  

Energy communities are a testing ground for real-life experimentation with new technologies 
and the social arrangements needed for an inclusive and just transition, and they are some of 
the drivers of such forms of citizen’s empowerment.10 These innovative activities can often be 
facilitated or optimised using digital tools. For example, remote rural energy systems that suffer 
from  high  transport  costs  and  insecure  supply  due  to  weak  and  unstable  and/or  remote 
connection to the medium-voltage grid can use digital tools to reduce their dependence on the 
main electricity grid by pooling their own consumption of individually produced electricity.11 
Benefits of digitalisation are also evident for urban energy systems which are characterised by 

7   See for instance https://www.ceer.eu/documents/104400/-/-/44055630-31dc-d3da-386a-a6edfec24eb1  
8  

In order to provide a homogenous institutional framework for energy communities while still encompassing 
the diversity of such forms of organisation, Directive (EU) 2018/2001 on the promotion of the use of energy 
from renewable sources (RED II) and Directive (EU) 2019/944 on common rules for the internal market for 
electricity (the IEMD) introduce the notions of renewable energy communities (RECs) and citizens’ energy 
communities  (CECs).  The  two  notions  differ  in  several  respects  (type  of  production  assets,  geographical 
scope,  participation  requirements  etc.),  and  Member  States  have  substantial  flexibility  in  transposing  the 
relevant provisions of these directives, but the overall objective is to ensure that all Member States have an 
enabling framework for energy communities that features a standard set of conditions and associated rights 
(particularly in terms of licensing and permitting procedures, and applicable charges, levies and taxes). 
9   Communities  in  the  EU  are  a  buoyant  and  even  booming  sector,  with  thousands  of  associations  run  by 
members of the public to develop local energy solutions. The European Federation of Energy Cooperatives 
(REScoop.eu) alone claims that it has a growing network of 1 900 cooperatives operating across the EU and 
than  1.25  million  members  of  the  public.  For  further  examples  see 
that 
https://op.europa.eu/en/publication-detail/-/publication/e421aa35-fe0e-11ea-b44f-01aa75ed71a1/language-
en/format-PDF/source-search. 

it  represents  more 

10   This  means  empowerment  not  only  in  terms  of  access  to  services  and  goods  that  help  communities  to 
overcome their problems, but also in terms of capacity-building so that they can manage for themselves and 
own the means to secure their own well-being. 

11   For  an  example  of  using  digital  tools  to  optimise  collective  electricity  self-consumption  and  reduce 
dependence on the main electricity grid, see Pilot site Luče – Compile Project (compile-project.eu). This also 
concerns  not  only  the  development  of  smart  micro-grids  (currently  partly  enabled  by  EU  legislation  on 
community  networks  and  closed  distribution  networks  without  an  islanding  option),  but  also  energy 
management systems (decentralised or centralised control systems; action-based or automated systems etc.). 

8 

 
 
 
 
                                                 
a complex energy infrastructure that is designed to supply energy to multiple energy users and 
from  an increasing number of players (including members of the general public) acting not 
only as consumers but also as suppliers or otherwise adding flexibility to the system.12 A recent 
report published by CINEA emphasises that the digitalisation of energy systems has multiple 
specific benefits in urban contexts. These benefits also extend to mobility, infrastructure, and 
buildings.  The  same  report  examines  different  scenarios  for  2025,  2030  and  2040,  and 
formulates policy recommendations to foster these evolutions and lift remaining barriers.13  

Digital tools for energy communities 

Many digital tools make it possible for communities of consumers to scale up and diversify 
their positive impact on the electricity system. 

- 

 For instance, digitalisation makes it possible to develop business cases to provide 
flexibility1 services through aggregation. Digital tools make a seamless exchange of 
electricity between grid operators and the community possible. This can in turn make 
it possible to use digital tools and interfaces to set up dynamic pricing tools and share 
price  signals  with  the  community’s  members.  The  Belgian  energy  community 
Ecopower  is  focusing  on  developing  such  models.  The  Delta-EE  Whitepaper  on 
Residential  demand  response  shows  that  residential  sector  has  huge  untapped 
potential with over 200GW of installed assets of which HVAC and hot water heaters 
account for 97%. Lastly, an EU-funded project, FLEXCoop, is developing digital 
tools to enable energy cooperatives to act as an aggregator and build up the flexibility 
potential of their members. 

-  Communities’  digital  tools  can  be  used  to  manage  congestion  (e.g.  the  EnerGent 
project  partially  resolved  power-poverty  issues  by  controlling  inverters  of 
households’ photovoltaic panels to support the grid). 

One of the most interesting developments of the past decade has been the development and 
implementation  of  tools  that  enable  the  peer-to-peer  (‘P2P’)  trading  of  electricity.  A  recent 
study  from  the  German  Institute  for  Ecological  Economy  Research  (IÖW)14  evidenced  the 
enormous potential for energy sharing: more than 90% of all households in Germany could 
benefit  from  electricity  from  citizens-owned  power  plants,  thereby  mitigating  current  high 
European energy prices. 

Evidence also shows that P2P trading of electricity increases the added-value citizens15 (that is 
to say both self-producers and consumers) can gain from engaging in electricity trading, which 
in turn may drive increased levels of private investment in renewable energy generation assets. 

12   This was the case in the Partagélec energy sharing project in Brittany, which was directly initiated by the 
municipality  of  Pénestin  and  the  CAP  Atlantique  community  of  municipalities  along  with  an  energy 
syndicate. See Verde, S. F. and Rossetto, N.,  The Future of renewable energy communities in the EU: an 
investigation at the time of the clean energy package, available at https://op.europa.eu/en/publication-detail/-
/publication/e421aa35-fe0e-11ea-b44f-01aa75ed71a1/language-en/format-PDF/source-search.  

13   See https://cinea.ec.europa.eu/publications/digitalization-urban-energy-systems_en  
14   See https://www.ioew.de/en/news/article/energy-sharing-how-citizens-can-accelerate-the-energy-transition  
15   The H2020-funded project SocialRES’ ‘Report on new business models for cooperation among cooperatives, 
crowdfunding platforms and  aggregators in the  energy  market of  the future’ describe  how  autonomy  was 
identified as an ‘active’ social value in the context of a Portuguese P2P energy-sharing demonstration and 
was seen by users as a social value that was reinforced by the P2P energy-sharing activities (Adams et al., 
2021). 

9 

 
 
                                                 
Peer-2-peer trading 

o  Several companies and projects – both in the EU and elsewhere – use peer-2-
peer trading: The Brooklyn microgrid (BMG) project in the US has enabled 
40 prosumers and 200 consumers to sell the electricity they produce on their 
own premises at a price they are free to set for a period of 12 months. 

o  The RENeW Nexus Project in Australia has enabled 22 residential prosumers 
and  26  residential  consumers  living  in  the  same  area  to  trade  their  surplus 
energy production through a blockchain-based platform. 

o  The  Dutch  SchoonSchip  pilot  project  has  interconnected  a  floating 
neighbourhood  of  46  households  and  enabled  them  to  engage  in  P2P 
residential energy sharing while at the same time helping the operator of the 
distribution system to avoid congestion. The project was set up under a Dutch 
national  experimentation  scheme.  Through  the  application  of  demand 
response,  energy  storage,  conversion  and  electrification,  the  Schoonschip 
smart  grid  has  become  almost  fully  autonomous,  requiring  only  a  minimal 
backup  connexion  with  the  rest  of  the  national  grid:  the  46  homes  with  a 
combined capacity of approximately 900 kVA are connected to the public grid 
with a single connection of only 160 kVA. 

o  Ogarniamgrad.pl is a Polish energy trading platform that makes it possible to 
buy  and  sell  electricity  at  real-time  auctions.  It  has  saved  more  than 
USD 970 000 for its users. 

o  The EU project PARITY aims at delivering a transactive flexibility framework 
that  will  increase  durability  and  efficiency  of  the  electrical  grid,  while 
simultaneously  enabling  the  adoption  of  more  RES  through  enhanced  real-
time  control  of  DER  Flexibility  combined  with  novel  active  network 
management functionalities. PARITY goes beyond the traditional “top-down” 
grid management practices by enabling the functioning of a local flexibility 
market platform making use of IoT, as well as blockchain technologies for P2P 
energy  trading.  The  examples  elaborated  in  the  PARITY  project  tend  to 
evidence  that  the  major  share  of  the  cost  savings  enabled  by  consumer 
participation in the energy system result from local (P2P) energy trading, but 
hybrid market models (energy trading + flexibility provision) are also able to 
generate additional smaller revenues from flexibility provision.  

o  The EU-funded Energy Community Cooperatives (ECCO project) has created 
a  digital  platform  to  provide  users  with  all  the  necessary  resources  for 
community  energy  projects.  These  include:  (i)  a  community  space  which 
connects users and provides space for communication, (ii) a resources page 
with links to relevant resources to assist community energy groups’ progress, 
and (iii) custom-built tools designed to measure the progress of community 
energy projects, including: a) a greenhouse gas calculator that calculates the 
annual carbon dioxide savings that can be achieved by consuming  different 
forms  of  renewable  energy,  b)  a  self-assessment  tool  to  help  community 
energy groups see what stage of development their projects have reached, c) a 
technology decision plan that suggests the best renewable energy option for a 
given user based on the resources available in their local community and d) a 
timeline tool that gives an in-depth view of each step in the ECCO timeline. 

10 

 
 
  
 
1.5  Cooperation to share knowledge 

The  evidence  from  policy  trends,  stakeholders’  feedback  and  insights  into  research  and 
innovation projects that were analysed as input for this action plan underlined the importance 
to  understand  and  steer  the  digital  transformation  of  the  energy  system.16  The  potential  to 
accelerate the EU Green and Digital Transition and the implementation of the REPowerEU 

Knowledge and knowledge sharing 

  As  we  gradually  progress  to  a  green  energy  system,  new  knowledge  which  is 
currently  lacking  will  have  to  be  built  up,  at  both  EU  and  national  levels. 
Technology,  market  functioning  and  legal  frameworks  are  all  closely  connected  to 
each other. Knowledge needs to be shared across different policy areas and levels. 

  A lot of research and innovation is taking place in the EU on relevant topics, producing 
a lot of new knowledge, but  this knowledge is sometimes fragmented. Collective 
learning and knowledge sharing should be improved (BRIDGE is active in this area). 
Knowledge should be shared between all stakeholders (including policymakers and 
regulators  in  Member  States,  market  stakeholders  and  the  general  public). 
Sharing knowledge will make it possible to develop a common vision and strategy, 
making it easier to create the conditions for success. 

  As  the  transformation  towards  a  green  and  digital  energy  system  progresses,  new 
knowledge which is currently missing will have to be built up, both on an EU and on 
a national level. Technology, market functioning and legal frameworks are strongly 
intertwined, and its corresponding knowledge should be shared across the different 
structures and at all levels. 

  Knowledge coming out of research and innovation activities is sometimes fragmented. 
Many respondents  ask for extended collective knowledge sharing, organised at EU 
level, among policy makers and regulators in MS, stakeholders, and last but not least, 
European citizens. 

Upscaling from innovations 

  A significant number of EU research and innovation projects have not upscaled their 
results  into  new business operations. The main  reasons  given  were interoperability 
issues and inconsistencies between the Member States’ legal frameworks. 

Organisation and governance structures 

 

In the step towards new business operations, coordinate action at EU and MS level is 
asked  to  ensure  governance,  market  design,  business  models,  standardisation  and 
interoperability facilitate scale-up. 

16   65 projects have been analysed for these lessons learnt, identified through Horizon Europe and a stakeholder 

survey. 

11 

 
 
 
                                                 
 
 
 
 
 
 
 
Plan  requires  a  closer  cooperation  in  the  EU,  with  likeminded  countries  and  international 
organisation, and between energy and digital players across the entire energy value chain.  

2  Developing an EU framework for sharing data to support innovative 

energy services 

2.1  Context 

Strategic and regulatory EU frameworks are starting to lay down measures to ensure coherent 
approaches and interoperable solutions. Thus, the EU Strategy for Energy System Integration17 
stresses  the  importance  of  data  availability  and  interoperability  for  the  functioning, 
development and further integration of the energy system, and for realising the full potential of 
prosumers and grid flexibility. Additionally, several legal acts already in force or recent legal 
proposals for the energy sector include provisions regarding the  exchange of energy-related 
data.  

  The Electricity Market Directive18 and Regulation19 include provisions on the access 
to,  and  interoperability  of  data20  from  (smart)  meters,  as  well  as  requirements  for 
transmission  and  distribution  system  operators  with  regard  to  data  access  and  data 
management. 

  The Commission’s proposal  for a  revision  of the Renewables  Directive21  lays down 
requirements on access to data to enable smart and bidirectional charging of electric 
vehicles.  It  also  requires  making  available  information  on  the  share  of  renewable 
electricity and the greenhouse gas emissions content of the electricity supplied in the 
Member States. 

  The  Commission’s  proposal  for  a  revision  of  the  Energy  Performance  of  Buildings 
Directive22 defines rules for access to, and exchange and interoperability of data from 
(smart) buildings. This will enable the rollout of new smart building services and will 
support renovation actions. 

In addition, recent legal proposals and strategic documents cover general topics regarding the 
exchanges  of  data.  They  are  highly  relevant  for  numerous  economic  sectors,  including  the 
energy sector. 

17  COM(2020) 299 final.  
18  Directive (EU) 2019/944 of the European Parliament and of the Council of 5 June 2019 on common rules for 

the internal market for electricity and amending Directive 2012/27/EU, OJ L 158, 14.6.2019, p. 125. 

19  Regulation (EU) 2019/943 of the European Parliament and of the Council of 5 June 2019 on the internal 

market for electricity, OJ L 158, 14.6.2019, p. 54.  

20  The term ‘data’, according to article 23(1) of the Electricity Directive, refers to metering and consumption 

data, as well as data required for customer switching, demand response and other services. 

21  COM(2021) 557 final.  
22  COM(2021) 802 final.  

12 

 
 
 
 
 
 
                                                 
  The Commission’s proposal for a Data Governance Act23 aims to foster the availability 
of  data  for  use  by  increasing  trust  in  data  intermediaries  and  by  strengthening  data-
sharing mechanisms across the EU. It also establishes the European Data Innovation 
Board,  a new  expert group that would  support  the Commission  on enhancing  cross-
sectoral data sharing and (re-)use. 

  The Commission’s proposal for a Regulation on harmonised rules on fair access to and 
use  of  data  (Data  Act24)  defines  generic  data-sharing  requirements,  based  on 
consumers’ requests, for non-personal data generated by physical, connected objects. 
  The Commission’s proposal for a Regulation on alternative fuels infrastructure25 aims 
to support the availability and accessibility of data from publicly accessible recharging 
points, ensuring a suitable functioning and offering of services. 

  The  European  Data  Strategy26  published  in  2020  announced  the  establishment  of 
common European data spaces in nine sectors, including energy. The energy data space 
will reinforce the availability and cross-sector sharing of data, in a customer-centric, 
secure and trustworthy manner. This will facilitate innovative solutions and support the 
decarbonisation of the energy system. 

  The Statement of the Members of the European Council of 25 March 202127 calls for 
progress  in  establishing  the  sectoral  data  spaces  announced  in  the  European  Data 
Strategy. 

  Building  on  the  European  Data  Strategy,  the  Commission’s  2022  Staff  Working 
Document on Common European Data Spaces28 stresses the point that the energy data 
space  will  help  the  further  integration  of  renewables,  increase  the  energy  system 
efficiency, and ensure a smooth and competitive transition towards the electrification 
of sectors such as heating and transport. 

  The  European  Interoperability  Framework  lays  down  guiding  principles  and 
recommendations29 that could drive the seamless exchanges of data within and across 
various sectoral data spaces. 

Several key actions will therefore be implemented with the aim of making the best use of data 
in the energy sector, and helping to build, scale up and maintain interoperable solutions for a 
strong European energy system. 

The actions proposed have the electricity system at their core, as an accelerated integration of 
renewables and  electrification are now driving the pace of its transformation. However, the 
proposed framework is designed not only to closely interact with and gradually include other 
energy carriers (e.g., decarbonised  gases and hydrogen), but  also  to  interconnect  with other 
sectors such as transport and finance.  

Furthermore, it should be noted that the actions do not directly address matters related to the 
ownership of data or intellectual property rights that may apply. Nor do they directly address 
data confidentiality, privacy and personal data protection. These very important cross-policy 

23  COM(2020) 767 final.  
24  COM(2022) 68 final.  
25   COM(2021) 559 final. 
26  COM(2020) 66 final.  
27  https://www.consilium.europa.eu/media/48976/250321-vtc-euco-statement-en.pdf.  
28  SWD(2022) 45 final.  
29   https://joinup.ec.europa.eu/collection/nifo-national-interoperability-framework-observatory/3-

interoperability-layers.  

13 

 
 
                                                 
aspects  are  all  considered  to  have  a  general  applicability,  which  is  governed  by  separate 
frameworks30. The focus is kept on data sharing arrangements and processes that are needed to 
improve the functioning of existing energy services, and on developing new ones in order to 
increase the share of renewables in the energy system and to strengthen the system efficiency 
and the overall security of supply. In this approach, it is considered that the relevant actors (e.g. 
prosumers)  have  an  interest  in  sharing  their  energy-related  data.  The  relevant  stakeholders 
therefore express their consent for sharing their energy-related data when subscribing to new 
services that bring them direct benefits, e.g. through the monetisation of their flexibility, by 
lowering  the  energy  bills  through  charging  their  electric  vehicles  (EVs)  in  a  smart  way,  by 
improving the self-consumption of the energy produced by their PVs or by any other means. 
Additionally, data sharing is envisaged to be conducted among eligible and trusted parties.  

Finally, the data sharing arrangements that need to be built in a coordinated way aim primarily 
to further develop several areas of the energy value chains, and innovative energy services and 
products that are key to  deliver on the  Green Deal  and REPowerEU objectives. The  policy 
areas  that  require  easy  and  seamless  data  exchanges  include:  establishing  new  flexibility 
products  and  services  that  help  the  integration  of  increasing  shares  of  renewables  and 
strengthen the liquidity and resilience of the energy markets; facilitating the rollout of smart 
EV charging  and vehicle-to-grid services;  supporting  smart  energy  buildings  as  a source of 
renewable energy production and flexibility in the energy system, and making the data from 
buildings available to define business cases for renovation and improving the buildings’ overall 
efficiency.  The  data  exchanges  among  the  grid  operators  (i.e.  transmission  and  distribution 
system  operators),  which  are  required  for  the  functioning  and  stability  of  the  grids,  are  not 
directly addressed here, but the strong synergies will be closely observed and factored in31. In 
other  words,  the  main  aim  will  be  to  coordinate  action  at  the  edge  of  the  grids  and  at  the 
interface  with  the  electricity  markets,  by  bringing  together  the  views  of  a  large  variety  of 
stakeholders that would otherwise find very hard to coordinate among themselves. 

2.2  Evidence, projects and best practice32  

Numerous  stakeholders  have  pointed  out  the  need  to  strengthen  EU  cooperation  and 
coordination  on  the  exchange  of  data  for  energy.  Their  views  indicate  several  key  areas  of 
action and the main priorities to be addressed.  

The Commission conducted an online public consultation33 between October 2021 and January 
2022 to collect the views of citizens, businesses and national authorities on the main priorities 

30  For 

instance,  by 

the  General  Data  Protection  Regulation 

(https://eur-
lex.europa.eu/eli/reg/2016/679/oj),  Regulation  (EC)  No  223/2009  on  European  statistics  (https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32009R0223)  or  by  the  cybersecurity  measures 
described in the area of the Action plan dedicated to them. 

(EU)  2016/679 

31   Additionally, a specific action under this Action plan will support enhanced data exchanges between TSOs 
and DSOs. See ‘Support the development of a Digital Twin of the EU electricity grid’ for more details. 
32   Selective country and project examples are presented throughout the text. However, these are not intended to 
cover exhaustively the whole of the EU, nor are the result of a prioritization exercise. The examples are solely 
for providing insights into specific arrangements for exchanging data in the energy sector, without prejudice 
to the numerous other valuable actions that are undertaken throughout the EU.  

33  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13141-Digitalising-the-energy-

sector-EU-action-plan/public-consultation_en  

14 

 
 
 
 
 
                                                 
for digitalising energy. The answers received stressed the point that insufficient cooperation, 
at various levels, is a barrier to unlocking the full potential of the data. Legal uncertainties due 
to  different  national  rules  on  accessing  energy  data  across  Member  States,  and  the  lack  of 
appropriate infrastructures for such data access prove to be currently quite problematic.  The 
national organisations should therefore cooperate and harmonise their approaches whenever 
possible. Additionally, any legal uncertainties regarding their mandates should be resolved and 
the responsibilities of the actors involved should be clarified.  

Interoperability aspects were also a major area of concern for the stakeholders consulted. The 
lack  of  interoperability  for  accessing  data  and  exchanging  it  between  devices  and/or 
organisations was seen as the main barrier at operational level.  

Country example: Austria 

Nation-wide  standardized  data  exchanges  on  energy  started  in  2012,  with  the 
implementation  of  an  automated  digital  process  for  consumers  to  switch  their  energy 
supplier. The data exchange framework underwent multiple developments over time, driven 
by  the  needs  of  smart  grid  stakeholders  that  established  working  groups.  Today,  a 
decentralized,  scalable,  and  highly  standardized  framework  covers  many  additional  use 
cases, including customer billing and customer management processes, access to metering 
and consumption data, processes linked to energy communities etc. The principles observed 
ensure that data always stays as close to the source as possible and is only exchanged based 
on customer consent or in the context of well-defined business processes observing clear 
legal requirements. Consumers and energy market players get a unified and secure interface 
to  interact  with  the  smart  grid  services.  All  data  exchanges  are  conducted  with  securely 
signed  and  encrypted  market  messages.  Customers  can  give  and  revoke  their  consent  to 
sharing data and/or participating in an energy community.  

Each  new  market  process  is  developed  on  the  basis  of  public  consultations  and  it 
subsequently becomes mandatory for all market actors. The management of the technical 
infrastructure  for  the  energy-related  data  exchanges  (EDA)  was  initially  ensured  by  a 
working  group  without  a  legal  personality.  In  2020  this  was  transformed  into  a  limited 
liability company (EDA GmbH), which now acts as a solution provider.  

Additional information: https://eda.at; https://ebutilities.at. 

Concluding, the top three actions recommended by stakeholders to be taken at the EU level 
were:  (1)  to  define  roles  and  responsibilities  and  to  clarify  the  legal  framework  for  data 
exchanges in energy; (2) to address interoperability; and (3) to create a governance structure 
for access to and sharing of data.  

The  Commission  followed  up  its  online  public  consultation  by  organising  a  series  of  six 
workshops34 in February and March 2022 to collect additional inputs. Hundreds of participants 
attended and shared valuable views and ideas. One of the key conclusions drawn35 referred to 
the opportunity to establish an EU expert group on data for energy. This would bring together 
several  main  categories  of  stakeholders,  including  Member  State  authorities  and  regulators, 

34  https://ec.europa.eu/info/events/workshops-digitalisation-energy-system-2022-feb-16_en  
35    Workshop conclusions – ‘Priorities in the energy transition that require enhanced data exchanges at EU 

level’:https://ec.europa.eu/info/sites/default/files/energy_climate_change_environment/conclusions_2302_d
ata_exchange_priorities.pdf. 

15 

 
 
                                                 
grid  operators  and  energy  market  players,  research  and  innovation  experts,  technology 
providers  and  equipment  manufacturers,  standardisation  representatives,  and  organisations 
representing consumers/prosumers. Additionally, a governance for the upcoming energy data 
space should be built and interoperable building blocks should be established for developing 
the data space in a robust and scalable way36. 

Country example: The Netherlands 

All  Dutch  electricity  grid  operators  joined  forces  in  2007  and  embarked,  via  the  NEDU 
association, on exchanging energy data with market stakeholders. The scope covers data for 
supplying  energy,  consumers  switching  their  energy  suppliers,  and  exchanging  metering 
data.  In  2018  it  became apparent  that  the  energy  transition  would  require  data  exchange 
between  more  parties  within  the  energy  sector,  and  with  other  sectors  such  as  transport, 
buildings, and the financial sector. A national initiative was launched and resulted in a legal 
entity  (BAS,  the  data  exchange  framework  administrator)  and  an  association  (MFF,  the 
market facilitating forum, which replaced NEDU). Both became operational in April 2022. 
BAS is an independent legal entity that has the Dutch TSO and DSOs as its shareholders. 
BAS  is  expected  to  handle  all  energy  data  exchanges.  In  the  MFF  meetings  all  relevant 
energy and cross-sectoral stakeholders, which require access to energy-related data, meet 
and agree on standard data formats and data exchange processes that should be used. Once 
agreed, BAS will implement those solutions, and monitor and report on their correct usage.  

Additional use cases for data exchanges are being actively developed as needed. Thus, data 
that  is  instrumental  for  operating  the  electricity  system  is  currently  exchanged  between 
market  stakeholders  and  grid  operators.  This  is  done  via  the  GOPACS  platform,  which 
coordinates the procurement by grid operators of market-based flexibility services that are 
used  to  mitigate  grid  congestion.  Furthermore,  frameworks  start  to  be  developed  for 
accommodating  smart  EV  charging,  and  for  supporting  social  housing  associations  to 
renovate the homes of their tenants for improving their energy efficiency.  

Additional information: https://www.mffbas.nl/; https://en.gopacs.eu/.  

Challenges  regarding  interoperability  and  access  to  data  that  might  hamper  the  large-scale 
deployment of demand side solutions  for flexibility  were  also  identified in an expert report 
published  by  the  Smart  Grids  Task  Force  (SGTF)37.  The  report  recommended  several  key 
actions, which included: ensuring stakeholder coordination at EU level to promote data access 
and  interoperability,  jointly  developing  guidelines,  defining  standard  capabilities  and 
requirements for smart appliances, defining an EU framework and associated building blocks 
for  data  access,  and  working  with  the  Member  States  for  establishing  customised  national 
implementations of those building blocks. A separate SGTF report38 laid the ground for more 
detailed work on data access in the electricity and gas sectors. It recommended engaging all 
relevant stakeholders and agreeing on several key interoperability features. Building upon this 

36    Workshop conclusions – ‘Best practices for energy data sharing’, 

https://ec.europa.eu/info/sites/default/files/energy_climate_change_environment/conclusions_1602_best_pr
actices_for_data_exchange.pdf. 

37  European  Smart  Grids  Task  Force,  Expert  Group  3  –  Final  Report:  Demand  Side  Flexibility  -  Perceived 

barriers and proposed recommendations, April 2019.  

38  SGTF, Expert Group 1 - Towards Interoperability within the EU for Electricity and Gas Data Access and 

Exchange, March 2019. 

16 

 
 
 
                                                 
work, the SGTF experts further proposed39 a set of interoperability rules to be considered at 

Country example: Estonia 

Estfeed  is  the  first  Estonian  secure  platform  and  protocol  for  managing  distributed 
exchanges of metering and consumption data between data providers and data users. The 
transfer  of  metering  data  requires  the  owner’s  consent.  The  platform  is  designed  and 
operated  by  Elering  AS,  the  Estonian  TSO,  as  a  flexible  and  scalable  system  to  share 
consumer energy data with any energy services that can use it for deploying value-added 
services.  A  dedicated  API  (Application  Programming  Interface)  allows  access  to  the 
platform services through standard interfaces. 

The  initial  use  cases  that  drove  the  design  of  the  platform  referred  to  supporting  and 
coordinating  the  energy  supply  processes.  As  such,  the  main  users  have  been  energy 
suppliers,  balance  responsible  parties  and  grid  operators.  Recently,  aggregators,  as 
providers  of  flexibility  services  to  the  electricity  system,  were  also  granted  access. 
Furthermore, any consumer/prosumer can grant access to its data to any third party, while 
remaining the owner of that data and being able to fully supervise its use.  

Estfeed  is  built  on  the  X-Road  software-based  national  solution,  which  manages  data 
exchanges  and  is  the  backbone  of  e-Estonia.  X-Road  allows  various  public  and  private 
sector e-service information systems to link up and function in harmony.  

Additional information: https://elering.ee/en/developments-related-energy-companies; 
https://e-estonia.com/solutions/interoperability-services/x-road/. 

EU level for access to electricity metering and consumption data. 

Valuable work for improving data exchanges in energy and advancing interoperability is being 
carried  out  by  the  Bridge40  Initiative  of  the  European  Commission.  The  Data  Management 
working  group  regularly  publishes  reports  based  on  the  findings  and  lessons  learnt  from 
research and innovation projects. Their reports focus on analysing frameworks and technical 
matters  that  underpin  the  exchange  of  data  in  a  secure  and  interoperable  manner.  Ensuring 
interoperability  is  identified  as  a  key  prerequisite  for  a  successful  energy  transition  and 
solutions  are  being  sought.  Therefore,  a  common  European  reference  architecture  for  data 
exchanges41 and a repository of use cases42 are being developed and proposed to be used by 
the energy actors and research projects, and a methodology43 was developed for analysing the 
system implementation of flexibility-related use cases. These products are being further refined 
and developed. Further joint work by key stakeholders will be needed in order to ensure their 

39  SGTF, Expert Group 1 - EG1 advice on the implementing acts on data access and interoperability – metering 

and consumption data, March 2022. 

40  The BRIDGE initiative brings together Horizon 2020 and Horizon Europe projects that are active in the areas 
of  smart  grids,  energy  storage,  islands,  and  digitalisation.  It  aims  to  foster  the  exchange  of  information, 
experience, knowledge, and best practices among its members. It was launched in 2016, comprises 93 projects 
(out of which 58 are ongoing) that bring together almost 1000 partner organisations from 40 countries and 
have  a  total  value  of  over  1  billion  euros.  For  more  information  visit  https://bridge-smart-grid-storage-
systems-digital-projects.ec.europa.eu/.   

41  Bridge, Data Management Working Group  - European energy data exchange  reference architecture, April 

2021. 

42  Bridge, Data Management Working Group – Use case repository, April 2021. 
43  Bridge, Data Management Working Group – Interoperability of flexibility assets, April 2021. 

17 

 
 
                                                 
 
use on a wide scale. This technical perspective is naturally complemented by the regular reports 
published by the other Bridge working groups44, which focus on regulatory models, business 
models, and consumer and citizens’ engagement, respectively.  

With regard to  the main priorities that would warrant  enhanced data exchanges and require 
extensive stakeholder coordination, the feedback collected during the preparatory phase of this 
action  plan  converged  by  indicating  several  areas.  The  vast  majority  of  respondents  in  the 
online  public  consultation  indicated  that  balancing  electricity  supply  and  demand  by  using 
flexibility  solutions  should  be  the  top  priority.  The  stakeholder  workshops  went  into  more 
detail and stressed that priority should be given to the areas that are rapidly developing from 
strategic,  legal,  technical  and  organisational  perspectives.  These  areas  include  aggregation, 
demand response and flexibility services for the grids, smart and bidirectional EV charging, 
and reinforcing the role of smart buildings as key players for improved energy efficiency and 
innovative energy services.  

The OneNet project 

OneNet is co-financed by Horizon Europe with EUR 22 million and has a total value of EUR 
28 million. Over 70 partners from 22 European countries, including two major associations 
of electricity grid operators (ENTSO-E and E.DSO) are part of a unique consortium with an 
ambitious goal. They aim to provide a seamless near real time integration of all the actors in 
the  electricity  networks  across  Europe  for  the  optimization  of  the  overall  system  and  the 
promotion  of  an  open  and  fair  market  structure.  More  specifically,  during  its  three-year 
implementation  schedule  lasting  until  September  2023  the  project  undertakes  to:  define 
standardised products and key parameters for grid services that aim at the coordination of all 
actors, from grid operators to customers; define a common IT architecture and common IT 
interfaces that enable open interactions among the existing platforms for all energy products 
and services envisaged; and implement and showcase scalable solutions grouped in large-
scale demonstrators covering major regions in Europe.  

OneNet therefore works to develop an open and flexible architecture to transform the actual 
European electricity system, tackling country- or zonal fragmentation, and building a pan-
European smarter and more efficient coordination. The vision is to coordinate market and 
network technical operations among them and across different countries, while maximizing 
the consumer capabilities to participate in an open market structure. The general use case of 
the OneNet system describes, among others, the main steps to enable a cross-platform energy 
data  exchange  using  the  OneNet  middleware.  Such  a  data  exchange  will  allow  building 
multiple cross-platform services for market-based management of flexibility in the electricity 
system.  Open  mechanisms  will  allow  the  OneNet  participants  (including  platforms, 
applications or services that act as Data Providers or Data Consumers) to interact with each 
other by using the OneNet Middleware. 

Additional information: https://onenet-project.eu/; https://op.europa.eu/en/publication-
detail/-/publication/abf32809-143e-11ec-b4fe-01aa75ed71a1/language-en.  

44   https://bridge-smart-grid-storage-systems-digital-projects.ec.europa.eu/download  

18 

 
 
                                                 
 
Similar  priorities  were  identified  by  a  recent  study  completed  by  the  Energy  Transition 
Expertise Centre (EnTEC)45.  

The RENAISSANCE project 

RENAISSANCE  is  a  Horizon  Europe  project  that  ends  its  36-month  implementation 
schedule in the second half of 2022. The project has a total value of EUR 6.9 million, out of 
which EUR 5.9 million represent the EU co-financing. Fifteen organisations from 7 European 
countries are partnering for a successful delivery of the project objectives.  

RENAISSANCE  aimed  at  demonstrating  highly  replicable  design  and  management 
approaches  for  integrated  local  energy  systems,  that  achieve  high  participation  of  local 
consumers (15-20%), exceed at local level the EU targets for renewable energy sources (37-
80%)  while  decreasing  the  energy  price  for  community  members  (10-15%  below  current 
market prices). The methodology and each of the four pilots (in Belgium, Greece, Spain and 
the Netherlands) covered key energy vectors (like electricity and heat), and involved different 
actors  (e.g.  households,  SMEs,  institutions)  to  valorise  flexibility  services  within  and 
between communities, and with DSOs. Local data exchanges for each pilot site, as well as 
between  pilots,  were  instrumental  for  putting  the  design  into  practice,  lowering  the  local 
GHG  emissions  and  bringing  value  to  the  local  energy  communities  of  prosumers.  The 
secure, interoperable and scalable RENAISSANCE platform interconnects all energy vectors 
of the demonstration sites into a unique decentralized multi-vector energy services market 
where  consumers/prosumers  can  interact  and  perform  financial  actions  defined  by  smart 
contracts.  

Additional information: https://www.renaissance-h2020.eu/; 
https://op.europa.eu/en/publication-detail/-/publication/abf32809-143e-11ec-b4fe-
01aa75ed71a1/language-en.  

45  EnTEC  -  Digitalisation  of  Energy  Flexibility,  February  2022,  https://op.europa.eu/en/publication-detail/-

/publication/c230dd32-a5a2-11ec-83e1-01aa75ed71a1/language-en.  

19 

 
 
 
 
                                                 
The InterConnect project 

The  Interconnect  project  funded  by  the  Horizon  2020  programme  gathers  50  European 
organisations from 11 countries to bring efficient energy management solutions within the 
reach of end-users. The four-year project will operate until 2023 and has a value of EUR 35.8 
million, receiving an EU contribution of EUR 35.8 million.  

InterConnect  will  implement  interoperable  solutions  connecting  smart  homes,  smart 
buildings and smart grids. It will demonstrate, among others, the benefits of enabling smart 
homes  and  buildings  to  become  active  energy  players.  Seven  large-scale  pilots  in  the 
participating  countries  are  deploying  and  testing  innovative  digital  solutions  that  are 
interoperable  and  provide  flexibility  services  to  the  electricity  grids.  These  pilots  make  it 
possible  to  reduce  grids  investment  and  operational  costs,  and  will  benefit  consumers. 
Facilitating seamless  exchanges of interoperable  data will also  make it possible  to  extend 
these benefits beyond R&I pilots.  

Additional information: https://interconnectproject.eu/; https://op.europa.eu/en/publication-
detail/-/publication/abf32809-143e-11ec-b4fe-01aa75ed71a1/language-en.  

2.3  Key actions 

Against  this  backdrop,  the  Commission  will  take  concrete  steps  to  establish  a  common 
European energy data space for improving the access to, exchange of, and (re-)use of data. The 
goal is to broaden the availability of data, and to make smooth and transparent data exchanges 
possible for the benefit of different players and different use-cases throughout the entire value 
chain.  They  include:  system  operators,  suppliers,  aggregators,  providers  of  storage  and/or 
demand response services, energy service companies, building managers, financial institutions, 
consumers and prosumers, manufacturers of electric vehicles, smart equipment and appliances 
(including SMEs), operators of charging points for EVs. The best use of already available data 
must be ensured, including data from smart meters, to serve the interests of consumers and the 
energy system as a whole. The actions will also enhance the interoperability of energy assets 
and services, will facilitate the comparability of solutions, promote standardisation, enhance 
grids  flexibility  and  responsiveness,  and  will  ultimately  contribute  to  the  overall  energy 
security and reliability of the energy system.  

Along  the  road  towards  deploying  a  common  European  data  space  for  energy,  several 
underlying principles will be observed. 

  Access to non-personal and/or anonymised energy data needs to be made available to 
all  relevant  parties,  based  on  the  consent  of  the  data  owners  and  while  observing 
technical data protection needs and confidentiality requirements. Data monopolies need 
to be avoided. 

  Cybersecurity and personal data protection are an intrinsic part of the approach. 
  Consumer acceptance and empowerment are key, being the starting point for accessing 

and using data coming from individuals46 and businesses. 

46   Chapter 4 presents additional details. 

20 

 
 
 
 
                                                 
  EU data sovereignty principles are duly observed, with data being able to flow within 

the EU and across sectors.  

  The rules for access to, and use of data are fair, practical and clear, and there are clear 
and trustworthy data governance mechanisms in place; there is an open, but assertive 
approach to international data flows, based on European values47. 

  Open-source solutions, including software modules, open standards and data models 
will  be  considered  whenever  possible,  as  enablers  of  innovation  and  generating 
economies of scale. The use of open application programme interfaces (APIs) should 
nonetheless be the norm, facilitating the exchanges of real-time data. 

  Data that are to be shared (and widely exchanged) should be focused and should contain 
only  the  elements  that  are  really  needed  for  establishing  and  managing  innovative 
energy  services.  Additionally,  non-essential  data  should  be  stored  and  processed 
locally. 

  The  construction  of  the  energy  data  space  will  be  closely  coordinated  with  the 
development of other sectoral data spaces, so that interoperable cross-sectoral solutions 
and services could be rolled-out. 

The logic of the actions envisaged will cover several key dimensions. 

  The actions will ensure that energy data is actually made available and shared with the 
relevant partners and market players (subject to the consent expressed by the owners of 
that  data).  Access  to  relevant  energy  data  is  instrumental  for  bringing  innovative 
services to the market and creating value along the value chains.  

  They will coordinate the EU and Member States efforts and relevant initiatives, and 
will ensure that the European arrangements build on the national ones, and facilitate 
pan-European or cross-border transactions. National models and arrangements for data 
exchanges should be coordinated at EU level with a view to furthering the integration 
of the energy markets.  

  They will bring all relevant parties together to develop coherent business models and 
grid services that are deployed at scale and in an interoperable manner. Stakeholders 
should therefore coordinate their work when developing relevant energy services that 
fully  respond  to  the  key  enablers  laid  down  in  the  energy  regulatory  framework. 
Economies of scale and faster deployment could be reached this way. 

  They will capitalise on the solutions that are readily available and, where  necessary, 
accelerate  their  development  and  ensure  their  full  market  uptake.  These  key  inputs 
equally include relevant legal instruments and arrangements (such as interoperability 
requirements  for  metering  data),  market  and  stakeholders  coordination  results  (for 
instance a code of conduct for smart appliances), and key results achieved by research 
and  innovation  activities  (for  instance,  recommendations  on  data  exchanges  and 
interoperability put forward by the Bridge initiative). 
 They  will  mobilise  the  resources  and  interoperable  building  blocks  developed  as 
described  above  in  order  to  roll  out  a  common  European  energy  data  space. 
Coordination arrangements will contribute to the future governance of the data space, 
while  the  various  interoperability  building  blocks  will  facilitate  effective  data 
exchanges across the EU energy markets and value chains. 

 

The key actions that will be pursued are grouped into three main dimensions, bringing together 
in a complementary way top-down coordination initiatives, with bottom-up targeted actions, 

47   According to the vision established by the European Data Strategy. 

21 

 
 
                                                 
all benefitting of support from the latest developments in research, innovation and digitalisation 
actions and programmes. 

A ‘one size fits all’ solution would not be optimal for this area of action, which is very complex 
in  terms  of legal,  operational  and technical  requirements, entailing numerous processes and 
involving a variety of actors. Therefore, a development of customised approaches based on use 
cases will be pursued. 

A first category of actions will define the strategic approach, aiming to ensure convergent 
and  coherent  EU  action.  Thus,  a  key  action  is  to  strengthen  the  coordination  at  EU  level 
regarding  data  exchanges  in  the  energy  sector.  The  Commission  will  set  up  the  ‘Data  for 
Energy’  (D4E)  expert  working  group  to  coordinate  the  views  and  actions  of  the  relevant 
stakeholders with regard to sharing and (re-)using energy data. The working group will foster 
the  exchange  of  experiences  and  best  practices,  and  will  assist  the  Commission  in  the 
preparation of policy initiatives and regulatory frameworks. Notably, its advice will play a key 
role in the preparation and rollout of a common European data space for energy, and in setting 
up its governance. A set of priorities will guide from the outset the activity of this expert group, 
and those are based on areas of energy markets and services that are in rapid development and 
undergo profound transformations. 

The D4E group will be integrated, as a permanent working group, within the current ‘Smart 
Grids  Task  Force’  (SGTF).  The  SGTF  will  be  formally  re-established,  expanded  and 
reconfigured  to  achieve  its  revised  objectives,  which  will  include  specific  competences 
regarding data exchanges. This overhaul will include broadening its membership and further 
developing its internal organisation and working procedures. Member States’ representatives 
will  work  together  with  energy  system  operators,  technology  and  service  providers, 
manufacturers,  research  and  innovation  organisations,  academia,  financial  institutions, 
technical  standardisation  experts  and  NGO  representatives  to  strengthen  coordinated  data 
sharing across Europe, to improve interoperability and to reduce market fragmentation.  

The  participation  of  Member  States  in  D4E  is  key,  as  data  exchange  is  defined  by  energy 
market  and  data  rules  and  principles  agreed  at  EU  level,  but  it  also  requires  national  data 
exchange  frameworks  for  its  practical  implementation.  Additionally,  ensuring  EU-wide 
interoperability  among  the  various  national  frameworks  will  be  needed  for  successfully 
building a genuine common European energy data space. Some of the text boxes above give 
examples of data exchange governance in Member States, and of EU-wide projects that achieve 
consistency  and  interoperability  across  borders.  Facilitating  and  promoting  the  exchange  of 
best-practices and experiences between policy makers in Member States, while learning from 
EU-wide projects and making best  use of their results, will be an important  added value of 
D4E. 

D4E will undertake the development of a portfolio of European high-level use cases for data 
exchanges in energy. These use cases represent the main priorities that need to be analysed and 
developed. The coordination at EU level will aim to ensure that, on the one hand they evolve 
into the main elements of a future common European energy data space and, on the other hand 
they build on the work already carried out either in the Member States or through various EU 
initiatives.  

The high-level use cases that will be addressed from the outset by D4E are: 

1.  ‘Flexibility in energy systems’ – aims to further develop and roll out flexibility products 
for  the  energy  markets,  including  demand  response  services  for  the  integration  of 

22 

 
 
 
renewable  energy  sources  and  to  limit  grid  congestion,  including  facilitating  the 
aggregation of flexibility potential based on access to data from devices behind-the-
meter;  

2.  ‘Smart and bidirectional EV charging’ – refers to integrating smart EV charging into 

power grids and promoting bidirectional vehicle-to-grid (V2G) services; 

3.  ‘Smart and energy-efficient buildings’ – develops mechanisms for capitalising on data 
from  smart  buildings  for  promoting  and  financing  energy-efficient  building 
renovations. 

It should be noted that although the second priority mentioned above could also be analysed as 
part of the wider flexibility approach of the first high-level use case, it is nonetheless defined 
as  a  priority  in  its  own  right  because  of  the  distinctive  characteristics,  prominent  uses,  and 
cross-sectoral application. Other high-level use cases48 might be considered later on, depending 
on the development priorities of EU energy grids and markets. 

D4E will develop these priorities to detail the use case-specific needs and objectives for data 
exchanges.  This  will  prepare  the  ground  and  building  blocks  for  establishing  a  common 
European energy data space. In doing so, D4E will make the best use of the relevant inputs and 
building  blocks  developed  by  various  initiatives  or  new  legal  instruments,  and  will  closely 
interact with existing initiatives to explore synergies. These include: the upcoming Network 
code on demand side flexibility49 (in particular for the 1st high-level use case above), the work 
of the Sustainable Transport Forum (STF)50 (for the 2nd high-level use case), and that of the 
Expert group on European financial data space51, the Energy Efficiency Financial Institutions 
Group52, and the Smart Readiness Indicator and its platform53 (for the 3rd high-level use case). 
This work also  aims to establish EU-wide interoperability principles  both inside the energy 
data  space,  and  between  energy  and  other  European  data  spaces  (e.g.  for  transport  or  for 
financial  services).  Interoperability  will  be  analysed  and  worked  on  in  all  its  different 
dimensions, be it coherent business and functional approaches based on common use cases, or 
technical interoperability ensured by common data models and communication protocols. A 
close cooperation with the upcoming European Data Innovation Board is envisaged to that end. 

As an example of ensuring cross-sectoral interoperability and data sharing, D4E will jointly 
work with the Data group54 of STF for developing in detail the high-level use case on smart 
and  bi-directional  EV  charging,  and  with  the  Expert  group  on  the  financial  data  space  for 

48   Additional examples of priorities that could be addressed in the future include: data coming from the operation 
of  renewable  energy  generation  assets  (as  discussed  with  stakeholders  in  a  webinar  in  February  2022: 
https://ec.europa.eu/info/sites/default/files/energy_climate_change_environment/conclusions_2402_data_ex
change_res.pdf),  data  enabling  enhanced  forecasts  and  predictive  maintenance  for  optimised  energy 
production, or data needed for unlocking sustainable private financing of the energy transition.  

49 

https://www.acer.europa.eu/sites/default/files/documents/Media/News/Documents/2022%2006%2001%20F
G%20Request%20to%20ACER_final.pdf  

50   https://transport.ec.europa.eu/transport-themes/clean-transport-urban-transport/sustainable-transport-forum-

stf_en  

51   https://ec.europa.eu/transparency/expert-groups-register/screen/expert-

groups/consult?lang=en&groupID=3763  

52   https://eefig.ec.europa.eu/index_en  
53   https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficient-buildings/smart-readiness-

indicator_en  

54   Working group ‘A Common Data Approach for Electromobility and other Alternative Fuels’ (STF on Data), 
https://transport.ec.europa.eu/transport-themes/clean-transport-urban-transport/sustainable-transport-forum-
stf/active-sub-groups/sub-group-common-data-approach-electromobility-and-other-alternative-fuels_en.  

23 

 
 
                                                 
developing the details on green mortgages and funding green renovations under the use case 
on  energy  efficient  buildings.  Ensuring  stronger  linkages  between  the  energy  and  transport 
sectors  could  contribute  to  the  overall  optimisation  of  the  energy  system  as  a  whole.  The 
integration  of  electric  vehicles  into  the  energy  system  offers  a  clear  opportunity  to  provide 
flexibility  to  the  electricity  system,  facilitating  the  incorporation  of  renewable  energy  and 
supporting the development of an energy-efficient charging infrastructure. D4E and the Data 
group of STF will pursue an effective expert collaboration for outlining the requirements and 
key actions to develop effective and interoperable European data-sharing arrangements for the 
energy  system,  capitalising  on  and  complementing  the  provisions  for  governance  and  data 
sharing of electric vehicle charging infrastructure. To that end, the two working groups will 
define a joint work programme with the aim to issue recommendations on common principles 
and  best  practices  for  supporting  the  EU-wide  uptake  of  smart  and  bidirectional  charging 
solutions.  They  will  also  work  to  define  the  key  elements  for  a  data  exchange  framework 
between  grid  operators,  aggregators  and  relevant  charging  infrastructure  stakeholders  that 
supports  a  successful  integration  of  electric  vehicles  into  the  energy  system.  Limiting  grid 
congestion and enabling vehicle-to-grid (V2G) services will be key objectives. Furthermore, 
seamless data exchanges between the energy and the financial data spaces could help unlocking 
additional private financing to support the energy transition.  

As a general approach, the activity of D4E will cover two main phases of development. 

 

 

In the first phase, the precise scope of the EU action in all the three high-level use cases 
will  be  further  developed  by  building  on,  and  complementing  various  national 
initiatives. The roles and responsibilities of the main actors that exchange data will be 
clarified and the data flows and their various components will be defined. Horizontal 
requirements  will  be  established,  including  the  legal,  operational,  functional  and 
technical components that underpin those data exchanges. The identified processes and 
principles will constitute the main building blocks of the future energy data space.  
The work of the first phase, envisaged to take around 24 months, will use the immediate 
inputs  that  will  be  made  available  by  the  second  and  third  categories  of  actions 
described below. The continuous development of the energy data space and ensuring 
its subsequent improvements and expansions will remain a key task of D4E on long 
term; 
In the second phase, after the main building blocks will be defined and agreed upon, 
D4E will assist the European Commission in deploying the common European energy 
data space, and will play an active role in establishing its governance. This will be done 
in close coordination with the governance of the other European data spaces, to ensure 
consistent  approaches  and  to  embed  interoperable  processes.  Overall  support, 
coordination  and  guidance  to  ensure  a  coherent  development  of  the  various  sectoral 
data spaces, and interoperability among them, will be provided by the European Data 
Innovation Board and the Data Spaces Support Centre55. 

A  second  category  comprises  immediate  actions,  which  will  feed  into  the  strategic 
coordination  and  will  provide  the  first  deliverables  for  enhancing  data  exchanges  and 
underpinning the work of the upcoming D4E expert group. These actions represent targeted 
initiatives, for which preparatory work is being carried out, and will provide immediate results. 

55   The  Data  Spaces  Support  Centre  is  set  up  with  the  support  of  the  Digital  Europe  Programme 
(https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/opportunities/topic-details/digital-
2021-cloud-ai-01-suppcentre).  

24 

 
 
                                                 
Their outcomes will benefit the work that the D4E will undertake for developing the high-level 
use cases. 

An implementing act on interoperability requirements and procedures for access to metering 
and  consumption  data  is  being  developed  and  will  be  submitted  by  the  Commission  for 
adoption  through  the  comitology  procedure.  Subsequently,  the  Commission  will  start  the 
preparation of one or more implementing acts on interoperability requirements and procedures 
for access to data required for demand response and customer switching. The Commission was 
empowered to adopt these acts by the Electricity Market Directive56. These implementing acts 
will lay down the rules regarding the interoperability requirements and non-discriminatory and 
transparent procedures for access to, and management and exchange of data generated by the 
(smart) meters, aiming to support the interoperability of energy services throughout the EU.  

The Commission  will  also  promote a  code of  conduct  for energy smart  appliances to  boost 
participation in demand response schemes. This action will build on the work started under the 
Ecodesign  framework57.  Through  this  action  there  will  be  defined  sets  of  (functional  and 
interoperability)  requirements  for  energy  smart  appliances.  These  requirements  would 
demonstrate  a  specific  ‘energy-smart’  behaviour  of  products,  meaning  that  they  are  able  to 
participate in demand response schemes and they could do so in an interoperable way. The 
code of conduct will be offered for adherence to the manufacturers that place equipment on the 
EU internal market. A mass adoption of this Code of Conduct will mean that heat pumps, smart 
EV chargers, PV inverters, smart washing machines and other smart home appliances would 
be able to easily communicate with each other and aggregate efforts to provide flexibility to 
the grid. This level of interoperability is expected to greatly facilitate both the participation of 
consumers/prosumers in demand response schemes, and the efforts of aggregators to access 
significant numbers of assets and installed flexibility capacities. 

Thirdly,  research  and  innovation  actions  will,  together  with  pilot  deployments  of  data 
exchange frameworks and solutions, support the development and implementation of the 
actions detailed above and the deployment of the common European energy data space.  

Substantial funding will continue to be made available through Horizon Europe and Digital 
Europe  programmes  for  research  and  innovation,  and  to  bringing  digital  transformation 
towards market deployment. European projects will be invited to develop and upscale the high-
level use cases, and to bridge the identified market gaps. They will also start to prepare and 
demonstrate the building blocks of the upcoming energy data space. In particular, the Digital 
Europe Programme will include a specific call in 2024 for supporting the deployment of the 
common  European  data  space  for  energy.  This  will  capitalise  on  the  results  that  will  be 
achieved by five projects funded by Horizon Europe, which aim to establish the ground for a 
common European data space for energy58. 

As an important step forward for enhancing interoperability on a European scale, mechanisms 
for building interoperable solutions will be embedded from the outset in the future research 
and innovation projects. The Bridge59 initiative, which groups together all the Horizon 2020 

56  As per the provisions of Article 24. 
57  Additional  details  are  available  at  https://ses.jrc.ec.europa.eu/development-of-policy-proposals-for-energy-

smart-appliances.  

58   Horizon Europe 2021 Work Programme, Call for projects ‘Sustainable, secure and competitive energy supply 
(HORIZON-CL5-2021-D3-01)’  with  a  budget  of  EUR  32  million,  https://ec.europa.eu/info/funding-
tenders/opportunities/portal/screen/opportunities/topic-details/horizon-cl5-2021-d3-01-01.   

59  https://www.h2020-bridge.eu/   

25 

 
 
                                                 
and Horizon Europe projects  that  are  active in  the areas of smart  grids,  energy storage and 
digitalisation,  will  take  concrete  steps  in  that  direction.  Key  building  blocks  are  being 
developed  and  will  be  proposed  for  use  by  all  the  future  European  projects.  These 
interoperability  blocks  include  a  repository  of  common  use  cases,  agreement  on  reference 
architectures to be widely used, and the use of a set of harmonised role models for the energy 
actors.  Other  building  blocks  could  be  developed  in  the  future,  based  on the  needs  that  are 
identified by the projects. Complementing these technical products, coordination activities will 
ensure that the widespread use of these technical products will be embedded in the work plans 
of Bridge and its various working groups. This will boost the interoperability and scalability of 
the solutions developed by the research projects, and thus prepare them better for their large-
scale adoption in real-life operation. A subsequent step will be to feed these results into the 
work  of  D4E,  because  they  could  be  used  for  the  development  of  the  high-level  use  cases 
envisaged. 

3  Details on actions to promote investments in a smart electricity 

grid 

As highlighted in the introduction, to digitalise the energy system and be able to fully exploit 
the opportunities it brings, investments in smart grids development and related enabling digital 
solutions are instrumental. Currently the pace at which these investments are taking place is 
not  high  enough.  It  is  therefore  necessary  to  speed  up  investments  in  smart  and  digital 
electricity grids in order to make the network and the energy system as a whole more intelligent 
(ref.  Expert  Workshop  held  on  25  May  202260).  This  was  also  highlighted  during  the  open 
public consultation conducted as part of the consultative process on which this Action Plan is 
built upon. 

Many  of  these  investment  projects  are  innovative,  so  a  regulatory  framework  that  further 
supports innovation is crucial. 

60   https://ec.europa.eu/info/events/workshops-digitalisation-energy-system-2022-feb-16_en  

26 

 
 
 
 
 
 
                                                 
Net2DG Horizon 2020 Project  

The  Net2DG  Horizon  2020  Project  has  led  to  the  development  of  an  ICT-Gateway  that 
enables a digital twin of the low voltage distribution grid. On top of this digital twin, some 
applications for Grid Monitoring, Loss Calculation, Outage Detection and Diagnostic have 
been developed. Overall, this architecture leads to a fully digital process for operation and 
planning of the low voltage grid.  

The system has been deployed in two field environments in Germany and Denmark and 
field trials in the low-voltage grid have allowed to highlight the following benefits of using 
this system:  

1. 
2. 

3. 

Outage detection and diagnosis time could be reduced to few minutes 
Grid losses could be reduced by 11% via voltage management applied in 
combination with continuous voltage monitoring; when applying a variant of 
the reactive power coordination of inverters, a reduction by 20% was possible.  
The hosting capacity of the field trial example grid was increased by 30% 
through an enhanced planning process using the digital grid status, and an 
additional 50% increase was achievable through the coordinated reactive 
power management of the inverters. 

Source: Net2DG Horizon 2020 Project, http://www.net2dg.eu/wafx_res/Files/Net2DG_D5.3_25.06.2021.pdf  

In  many  Member  States,  the  regulatory  frameworks  appear  to  set  barriers  to  innovation  on 
electricity  infrastructure.  It  may  be  the  case  that  there  are  no  specific  provisions  related  to 
innovation or that these set out a bias towards capital expenditure (CAPEX) based solutions 
instead of operational expenditures (OPEX) solutions. In general, innovative solutions that are 
usually of lower (total) costs and more operational expenditure (OPEX) intensive are not as 
attractive to invest in as they should be61. 

 Investments in digitalisation of the grid by Fluvius 

In  its  2022-2032  investment  planning,  Fluvius,  the  Flemish  distribution  system  operator 
(DSO), has added EUR 4 billion in planned grid investments to the EUR 7 billion already 
planned to achieve the energy transition. Fluvius evaluates that an additional EUR 2 billion 
in  hardware  (e.g.,  cables,  etc.)  investments  would  be  needed  if  the  investments  are  not 
‘smart’ (i.e. if they do not include, for example, the roll-out of flexibility services, smart 
meters and capacity tariffs). 

Source: 
over.fluvius.be/publicatie/investeringsplan-2023-2032 

Investeringsplan  2023-2032,  versie  8 

juni  2022 

(versie  voor  publieke  consultatie): 

61   ACER  position  on  incentivising  smart  investment  to  improve  the  efficient  use  of  electricity  transmission 

assets, November 2021 

27 

 
 
 
 
                                                 
 
3.1 

Support the development of a Digital Twin of the EU Electricity Grid 

In  order  to  establish  a  long-term  strategy  for  innovation,  promote  investment  in  a  smarter, 
greener, safer and more resilient electricity network, and reduce the associated investment risk, 
an EU “digitalisation of energy” flagship initiative, in the form of a Digital Twin of the EU 
electricity  grid,  aims  to  ensure  structured  cooperation  on  investments  and  data  exchange 
between  network  operators.  Holistic  DSO  and  TSO  cooperation  in  network  planning  and 
operation is a prerequisite for a smart electricity grid. The EU DSO Entity and ENTSO-E play 
a key role in line with the tasks set for them under the Electricity Regulation, whilst considering 
the required flexibilities at national level, and cooperation to create a Digital Twin of the grid 
can further facilitate such cooperation.  

A Digital Twin of the EU electricity grid will not only help optimise operations management 
integration 
and  network  development  planning,  but  also  streamline 
analysis, synchronise data  from  various  sources across  the  value  chain, and  generally 
strengthen the  visibility  and controllability of  the  grid. It  will  also  make  it  possible 
to investigate  and  assess  how  the  electricity  grid  responds  to  stimuli  or  shocks  (e.g. 
renewable energy sources integration, demand response and cyberattacks) using forecasting 
and long-term modelling, and thus contributing to a more resilient electricity grid. It is also 
vital to test the application of science and innovation in the energy sector (e.g. testing the 
combination of high performance computing, big data, AI and cloud computing). 

renewable 

The aim of the Digital Twin will be to enhance the efficiency and smartness of the grid in order 
to make the networks and the entire energy system more intelligent. The creation of the Digital 
Twin  will  be  a  stepwise  process  take  place  step  by  step  and  will  be  achieved  through 
coordinated investment in five areas: 

i) 
ii) 
iii) 
iv) 

v) 

observability and controllability 
efficient infrastructure and network planning 
operations and simulations for a more resilient grid 
active system management and forecasting to support flexibility and demand 
response data exchange  
interaction between TSOs and DSOs. 

Subject  to  approval  by  the  Member  States,  the  Commission  will  support  the  creation  of  a 
Digital Twin with Horizon Europe.  

28 

 
 
 
 
 
 
 
 
 
Implementation of a digital twin by a TSO  

The  Finnish  transmission  system  operator,  Fingrid,  implemented  a  digital  twin  to  help 
manage its assets and operations, and plan its infrastructure investment.  

This digital solution allowed Fingrid to reduce data collection workload and focus on data 
analysis.  

The model provided by the digital twin allows Fingrid to plan investment up to 25 years in 
advance. The digital twin is used to develop several investment scenarios that take different 
policy frameworks into account. This enables Fingrid to save costs and use its time more 
efficiently.  Fingrid  is  currently  investing  more  than  EUR  1  billion  in  developing  clean 
power  sources  and  integrating  them  into  the  grids.  This  investment  is  based  on  projects 
developed by the digital twin.  

Fingrid had already decided to digitalise the grid at an early stage. This allowed it to 
exploit the opportunities provided by the digital twin, because a smart grid is a 
prerequisite for an accurate digital grid model.  

Source: Digital Twin Fingrid | 2018 | Siemens Global: Digital Twin Fingrid | 2018 | Siemens Global  

3.2  Support the definition of common smart grid indicators 

In  addition  to  the concrete  cooperation initiative of the Digital  Twin,  it is  essential that the 
regulatory framework fully supports innovative investments in the smartness of the grid. To 
that end, a structured interaction between national regulatory authorities (NRAs) and network 
operators in defining (common) network key performance indicators (in addition to tailored 
ones) to measure the smartness of the electricity network (and in the longer term the impact of 
such investments) is key to setting targets and monitoring developing trends, opportunities and 
challenges. 

The  Commission  will  support  and  cooperate  with  the  European  Union  Agency  for  the 
Cooperation  of  Energy  Regulators  (ACER)  and  the  NRAs  to  define  common  smart  grid 
indicators.  If  useful,  objectives  for  these  indicators  may  be  set.  These  common  smart  grid 
indicators will be defined in the five areas listed above and will allow NRAs to monitor smart 
and digital investment in the electricity grid annually as of 2023, as required by Article 59.1(l) 
of the Electricity Market Directive. Such common indicators will also provide guidance on the 
implementation of that article.  

These common indicators will help to speed up investment in smart and digital electricity grids 
because they will ensure cooperation and  the exchange of best practices between NRAs for 
defining efficient investment in digitalisation and innovation at a time when the need to invest 
in networks is high. The role of NRAs will at the same time ensure that investments are efficient 
and that the quality of service to  grid users improves. Key performance indicators will also 
help  network  operators  identify  the  most  effective  ways  to  invest  in  smartness  and 
digitalisation. 

The common smart grid indicators should include a limited set of output indicators, supported 
by input indicators. 

29 

 
 
 
 
  Output indicators reflect the benefits/impacts of the smart and digital electricity grid for 
grid users. They therefore measure whether system operators fulfil their activities in an 
efficient manner. 
Input indicators, by contrast, reflect the level of readiness and uptake of specific digital 
solutions by system operators (SO), and help guide the transition progress by assessing 
whether SOs have sufficient tools/instruments to deliver on the output indicators. 

 

Both actions are intrinsically linked and both require TSO-DSO cooperation in smartening 
the  electricity  grid.  The  Digital  Twin  of  the  grid  provides  a  concrete  collaboration 
framework for integrating the smart grid indicators, helping to monitor progress made in 
digitalising the grid. Smarter and more digitalised grids will generate more data as a basis for 
optimised and interactive grid management to  promote flexibility,  including  smart  charging 
and the integration of more renewables and greater energy efficiency. 

4  Details on actions to empower consumers  

4.1  Digital tools for energy communities and other collective action initiatives  

The  Energy  Communities  Repository62  will  help  policy  makers,  regulators  and  local 
communities to better understand how to set up and support business models that require ICT 
and  data-driven  solutions  (such  as  community  electricity  trading).  This  could  increase  the 
financial  viability  of  energy  community  projects  and  incentivise  convergent  and  consistent 
energy legislation across the EU. To the extent that these tools are activity-related, they could 
also help inform other types of collective action initiatives. 

Finally, the Energy Communities Repository could help identify and shortlist digital tools to 
provide  ready-to-use  building  blocks  for  emerging  energy  communities,  thus  boosting  the 
digital  literacy  of  their  members  and  their  ability  to  become  active  and  dynamic  energy 
consumers. The Commission will also provide funding to support communities at the set-up 
stage  and  to  support  system  integration  projects  through  the  LIFE  Energy  Communities 
Facility. 

4.2  Peer-to-peer trading 

As mentioned above, P2P electricity trading would allow both individuals and companies (both 
self-producers and consumers) to gain more from their engagement in the energy system. This 

62   https://energy-communities-repository.ec.europa.eu/index_en  

30 

 
 
 
 
 
 
 
 
 
                                                 
may in turn encourage private investment in renewable electricity-generation assets63. It is also 
in keeping with the aspiration of more and more members of the public to contribute to the 
green  transition  from  the  bottom-up,  by  reducing  their  consumption,  producing  and  using 
energy  locally,  and  reducing  their  overall  reliance  on  the  electricity  grid  (thus  helping  to 
mitigate grid congestion and reduce network losses). Finally, by allowing local individuals to 
trade electricity locally (thereby increasing consumer participation in local energy markets and 
promoting investment in decentralised generation assets), P2P electricity trading could become 
the first emerging component of local energy markets. The development of this tool will be 
funded under the Horizon Europe programme through a dedicated call with the aim of creating 
a  model  project  in  terms  of  customer-centric  design64,  community  ownership,  replicability, 
easy open-source access to deliverables and ease of maintenance of the resulting tools. 

This will be accompanied by a study to help: 

(i) 

(ii) 

identify  and  explore  multiple  business  models  that  could  be  relevant  for  Energy 
Sharing and P2P trading; 
define the requirements for ICT platforms that are relevant for the identified business 
models;  

(iii)  engage with ICT platform solution providers to identify the requirements and build 
an  overview  of  the  solutions  currently  available  on  the  market  for  these  business 
models;  

(iv)  describe how these solutions would fulfil the requirements in force;  
(v) 

identify  the  legal,  technical  and  operational  prerequisites  for  a  successful 
implementation. 

The Commission will also, together with the Joint Research Centre (JRC) Living Lab, develop 
an experimentation platform to test simulated energy communities. This will incentivise 
consumers and other stakeholders to create, develop and support, new energy communities, 
join existing energy communities and/or improve their practices. It will also provide a testbed 
for innovative activities  such as blockchain-based energy trading to  optimise processes  and 
operations, and will help identify potential legal, regulatory, fiscal and technical barriers. 

63   Local P2P electricity trading is listed among the 18 types of social innovation in energy described in D2.1 
Collective Action Initiatives. Some  theoretical perspectives and a working definition of the H2020-funded 
SONNET project. 

64   Digitalisation also makes it possible to develop more consumer-centric market designs by enabling the use 
of tools designed to adapt to the needs and preferences of different categories of market participants – thereby 
maximising consumer adoption and ensuring that different consumers have their needs met. For instance, the 
‘Exchange of Energy Blocks’ (‘EoEB’) concept presented by the Elia group in Belgium makes it possible for 
consumers  to  react  to  real-time  price  changes,  while  also  allowing  them  to  opt  into  additional  private  or 
https://www.eliagroup.eu/-
embedded 
/media/project/elia/shared/documents/elia-group/publications/studies-and-reports/20210618_ELIA_CCMD-
white-paper_EN.pdf 

reinforce 

metering 

trust. 

See 

to 

31 

 
 
 
 
 
                                                 
4.3  Support upskilling and reskilling of the workforce for the digitalisation of the 

energy value chain  

We will in the future need digitally empowered and capable members of the public, a digitally 
skilled workforce and digital experts. The twin green and digital transitions require new and 
emerging  green  and digital skills  to  be integrated into existing jobs  and  professionals  to  be 
enabled to acquire new and specialised skills so that they can adapt to the fast-changing data-
driven  service  market.  Innovative  technology  solutions  rely  on  there  being  enough  skilled 
workers  and  trained  professionals  to  apply  them  on  a  wide  scale  in  our  daily  lives.  The 
European  Green  Deal  made  this  very  clear,  acknowledging  the  urgent  need  for  proactive 
upskilling and reskilling schemes at all levels65. 

The  results  of  the  public  consultation66,  have  led  the  Commission  to  conclude  that 
shortcomings in skills development and the lack of a properly trained workforce are the most 
significant barriers to the uptake of digital technologies. In the context of REPowerEU, such 
barriers can hamper the application of clean energy technologies. Clear responses are therefore 
needed in order to successfully close existing skills gaps and mismatches that hinder the growth 
of the sector.  

Revising vocational and educational training strategies, and changing the curricula67 in energy 
education  are  key  ways  of  properly  responding  to  the  dynamic  context  of  high  renewable 
penetration and digitalisation of the energy sector, because these require specific knowledge 
and  skills  as  well  as  new  ways  of  using  new  technologies.  Well-informed  and  qualified 
professionals will have a key role to play in encouraging and stimulating the development and 
implementation of digital tools for the benefit of consumers. 

65   The Erasmus+ funded project EDDIE (Education for the Digitalisation of Energy) conducted a survey of the 
industry (60 respondents) on the importance of green skills and adding green components to existing skills. 
Most respondents replied that they have to adapt to climate-driven goals and policies, and engage in activities 
that require green skills. A significant number also indicated that new green skills are emerging, and that new 
components have to be added to existing skills. Analysis performed by EDDIE‘s partners has shown that 
there are similar skill gaps for different staff categories indicating that skills must be developed at various 
levels. The report “Current and future skill needs in the Energy sector” (https://www.eddie-erasmus.eu/wp-
content/uploads/2022/03/D2.2%20Current%20and%20future%20skill%20needs%20in%20the%20Energy
%20Sector_v3.0.pdf)  identifies  some  of  the  most  significant  skill  gaps  identified  in  the  process,  and  the 
degree at which each staff category is expected to be qualified. The results are drawn from a survey in which 
60  organisations  throughout  the  EU  participated.  The  results  were  confirmed  in  a  new  survey  of  49 
stakeholders. 

66   The  summary  report  of  the  stakeholder  consultation  process  is  available  on  the  Have  your  say  portal 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13141-Digitalising-the-energy-
sector-EU-action-plan/feedback_en?p_id=26009595.  Moreover,  in  the  survey  conducted  by  the  European 
Commission on February 2022 to 28 EU-funded and national projects, six reported that energy communities 
identify missing knowledge and skills, in facing complexity, as a barrier impacting their market readiness, 
and  access  to  the  market  and  capital  (RESCOOP,  PARITY,REDDREAM,  INTERFACE,PLATONE, 
ACCEPT) 

67   University-level upskilling programmes can boost the emergence of new and highly skilled occupations such 
as energy auditing and energy consulting, while also promoting the upgrading of professional skills required 
by existing occupations such as building facilities management, architecture and engineering (source: ILO, 
Skills for a Greener Future, 2019. https://www.ilo.org/skills/pubs/WCMS_732214/lang--en/index.htm Table 
ES 1. Changes in skills required, by skill level of occupation). 

32 

 
 
 
                                                 
Building on the 2020 Skills  Agenda, Council  recommendation on Ensuring a fair transition 
towards climate neutrality  68 and the Blueprint Strategy for the Digitalisation of  the Energy 
Value  Chain  (BSDE)69,  the  Commission  will  address  these  issues  by  supporting  the 
establishment of a large-scale partnership within the framework of the Pact for Skills70. Key 
national,  non-governmental  and  industrial  stakeholders,  system  operators,  academia  and 
research  institutions  will  cooperate  in  promoting  concrete  investment  in  reskilling  and 
upskilling  opportunities  so  that  the  EU’s  workforce  can  adapt  and  prepare  for  the  future 
digitalisation of energy-related jobs. Synergies and cooperation with other relevant  sectorial 
alliances71 and large-scale partnerships will be identified and exploited. 

This action will complement the target for basic digital skills established by the European Pillar 
of  Social  Rights  action  plan72  and  the  targets  of  the  Digital  Decade73.  The  Commission 
encourages Member States to boost skills by making full use of the European Social Fund+ 
and  the  Just  Transition  Fund.  The  European  Climate  Pact  and  the  upcoming  Erasmus+ 
Alliances  for  Innovation74  will  also  play  a  role  in  developing  forward-looking  skills  and 
university-level partnerships for cooperation on skills. The Recovery and Resilience Facility 
(RRF) can also help promote local and regional upskilling and reskilling schemes.  

4.4  Dedicated structures supporting upskilling and reskilling for digitalisation of 

energy value chain 

Plans and strategies with a specific focus on green jobs and skills tend to be improvised by 
organisations in sectors badly hit by the greening of employment. There tends to be a weak 
connection  between  organisations  involved  in  national  policymaking  on  environmental 
topics and those involved in labour markets and skills policy, including skills anticipation. 
Furthermore, the monitoring and anticipation of green jobs and skills tend to take place not 
through permanent mechanisms dedicated to the green economy, green jobs or green skills 
– but instead as part of an overall skills anticipation structure (with some notable exceptions 
such as France’s National Observatory for Jobs and Occupations in the Green Economy). 

Skills gaps vary depending on the industries, specialisations and demographics of each region. 
Local  actors  have  a  deep  understanding  of  the  challenges  and  needs  faced  by  the  local 

68    (2022/C 243/04), in particular Articles 4 (a) and 5 (c), which detail the need to promote digital skills investment 

69  

in the context of the energy transition.  
 The blueprint for sectoral cooperation on skills will develop a sectoral strategy for the development of skills 
relevant to the labour market – including the development of relevant EU vocational core curricula and roll-
out training. This could frame strategic cooperation between key stakeholders in a particular economic sector 
in order to address skills needs which could affect the overall growth of that sector. This will be a feature of 
the BSDE and will be demonstrated and validated in a pilot environment. 

70     https://ec.europa.eu/social/main.jsp?catId=1517&langId=en  
71   For  example:  cybersecurity,  onshore  renewables  (see  EU  Solar  Energy  Strategy,  COM/20222/221  final), 

blockchain. 

72 

https://ec.europa.eu/info/strategy/priorities-2019-2024/economy-works-people/jobs-growth-and-

investment/european-pillar-social-rights/european-pillar-social-rights-action-plan_en  

73   https://digital-strategy.ec.europa.eu/en/policies/europes-digital-decade  
74   The Erasmus+ Innovation Alliances foster the EU’s innovation capacity through cooperation and the flow of 
knowledge between higher education, vocational education and training (both initial and  ongoing) and the 
broader socioeconomic environment. 

33 

 
 
 
                                                 
population  and  can ensure  that local  skills  strategies  address  them  all.  In the context  of  the 
‘Creating an “EU Digital Energy” platform to support innovation ecosystems’ action,75 
the  Large-Scale  Partnership  on Skills  for  the  Digitalisation  of  the  Energy  Value  Chain  will 
support the creation of a common vision; promote the sharing of best practices, knowledge and 
skills throughous the value chain; and contribute to the regional roll-out of the sectorial alliance 
strategy within the European Digital Innovation Hubs (EDIHs) devoted to the energy sector.76 
EDIHs will be structures dedicated to boosting digital energy skills, deploying strategies for 
creating demand for such skills and sharing best practices.  

5  Cybersecurity and resilience  

5.1  Context 

Cybersecurity is essential for the security and reliability of the increasingly digitalised energy 
system. All other sectors depend on energy-critical infrastructures. A cyber-attack that create 
an outage in a part of the energy system might trigger an immediate and far-reaching cascade 
consequences.  For  example, cloud  infrastructures  for hosting  and processing  data, transport 
(through the Vehicle to Grid and smart charging technologies) and building automation, are 
highly dependent on reliable energy systems.  

In 2019, the Commission provided guidance77 to network operators and technology suppliers 
on the energy sector’s main cybersecurity challenges, notably: 

1)  real-time requirements 
2)  the cascade effect,  
3)  the combination of legacy and state-of-the-art technologies. 

There are a number of other key requirements and challenges in this area: 

1.  Clear and robust cybersecurity governance structures between public and private actors. 
This includes, for example, the TSOs, the DSOs, vendors, national regulatory bodies 
from  different  sectors  and  EU  structures  such  as  the  Computer  Security  Incident 
Response Team (CSIRT)78 and the Cyber Crisis  Liaison Organisation (CyCLONe)79 
networks 

2.  Harmonised rules for assessing cybersecurity risks and security measures 
3.  Agreed procedures for collective responses to cybersecurity incidents 
4.  Low levels of capacity-capacity building and knowledge sharing in the Member States 

75   See https://ec.europa.eu/info/sites/default/files/conclusions_2502_edihs.pdf 
76   See https://digital-strategy.ec.europa.eu/en/activities/edihs 
77   C(2019) 2400 final Commission Recommendation of 3 April2019 on cybersecurity in the energy sector and 
Staff Working Document Accompanying the document Commission Recommendation on cybersecurity in 
the energy sector {C(2019) 2400 final} 

78    CISRIT network 
79     The CyCLONe network was established in 2020 for rapid cyber crisis management coordination in case of a 
large-scale, cross-border cyber incident or crisis in the EU. The European Network Information and Security 
Agency provides its secretariat, infrastructure and tools. 

34 

 
 
 
 
 
 
                                                 
5.  Increasing digitalisation and connectivity of energy infrastructure. These make the new 
decentralised models of production and consumption possible. These models require 
additional  exchanges  of  data  for  operations,  maintenance  and  trading,  creating  data 
security risks. 

Different instruments are being developed to achieve these objectives. For example: 

1)  forthcoming Network Code on Cybersecurity of Cross-Border Electricity Flows stems 
from  the  Electricity  Regulation  and,  will  lay  down  sector-specific  rules  for 
cybersecurity of cross-border electricity flows, including rules on common minimum 
requirements,  planning,  monitoring,  reporting  and  crisis  management.  Other  energy 
sectors, such as gas or hydrogen, might require similar rules. 

2)  The  EU  funding  programmes  that  will  be  managed  through  the  European 
Competence Centre and the Network of Coordination Centres80 will contribute to 
cybersecurity  capacity  building.  Some  of  those  programmes  aim  to  increase  and 
enhance knowledge sharing between Member States. 

3)  While  cybersecurity  is  essential,  it  should  not  hamper  fair  competition  and  market 
access  to  for  new  or  competing  products  and  services.  To  that  end,  the  legislative 
proposal on the Cyber Resilience Act in 202281 will lay down harmonised rules for the 
placing on the market of products with digital elements in the Union and duty of care 
for  the  whole  lifecycle  of  these  products,  as  well  as  corresponding  rules  on  market 
monitoring  and  surveillance.  This  should  help  to  establish  common  rules  while 
improving the security of products with digital elements. 

To  address  the  challenges  and  implement  the  instruments  mentioned  above,  the  EU  is 
developing an approach to strengthening the cybersecurity of energy systems. This will build 
on the EU cross-sectoral cybersecurity framework.  

At strategic policy level, the cybersecurity in the action plan is aligned with the Commission 
priority ‘A Europe fit for the Digital Age’ and the ‘EU Cybersecurity Strategy for the Digital 
Decade’ 82. 

At  operational  level,  the  Commission  (particularly  DG  ENER)  pays  utmost  attention  to 
cooperation with the Member States and their cybersecurity bodies. Policy work in the area of 
cybersecurity for  energy is  carried out  in  close  collaboration with  other entities such as the 
European Network Information Security Agency (ENISA)83 and the Computer Emergency 
Response Team for the EU bodies and agencies (CERT-EU)84. Further collaboration will be 
sought with other bodies and organisations, such as the CSIRT Network85, the Cyber Crisis 

80   The European Cybersecurity Competence Centre and Network is now ready to take off | Shaping Europe’s 

digital future (europa.eu) 

81   General information on the Cyber Resilience Act initiative at Cyber resilience act – new cybersecurity rules 

for digital products and ancillary services (europa.eu) 

82   Joint Communication to the European Parliament and the Council: The EU's Cybersecurity Strategy for the 

Digital Decade (JOIN(2020)18) 

83   ENISA (europa.eu) 
84   CERT-EU News Monitor (europa.eu) 
85   CSIRTs Network 

35 

 
 
 
 
                                                 
Liaison Organisation Network (CyCLONE)86, the Joint Cybersecurity Unit87, European 
Cybersecurity Competence Centre and the Network88 of National Coordination Centres. 

In terms of policy instruments, the main legislative text for cybersecurity is the Directive on 
Security  of  Network  and  Information  Systems  concerning  measures  for  a  high  common 
level of security of network and information systems across the Union (the NIS 1 Directive 89). 
The  Commission  proposed  to  revise  this  Directive  through,  so  called,  the  NIS2  Directive90 
version and it responds to the increasing degree of digitalisation and connectivity in society. 
The Directive defines the energy sector (including electricity, district heating and cooling, oil, 
gas and hydrogen) as a sector of high criticality. 

Specific cybersecurity legislation in the energy sector will bring the sector into line with, and 
complement the revised Directive on Security of Network and Information Systems and the 
Risk Preparedness Regulation91. 

Cybersecurity has become a more important requirement for resilient energy systems because 
of  digitalisation.  The  cybersecurity  attacks  on  the  operational  technologies  (OTs)  can  have 
consequences that go beyond IT systems, such damages to the wider energy infrastructure. 

5.2  Evidence, projects and best practices 

Digitalisation  makes  new  energy  systems  possible  and  cybersecurity  is  a  prerequisite  for 
digitalisation. The Commission’s public consultation on the digitalisation of the energy system 
action plan revealed that a majority of stakeholders see high and medium risks related to digital 
components and services, on both at the demand and supply sides. There is, however, no clear 
consensus as to who is best placed to manage these risks.  

86   CyCLONe:  “Cyber  Crisis  Liaison  Organisation  Network »,  established  in  2020  for  rapid  cyber  crisis 
management coordination in case of a large-scale, cross-border cyber incident or crisis in the EU. ENISA 
provides the Secretariat, infrastructures and tools. 

87    Joint Cyber Unit | Shaping Europe’s digital future (europa.eu)  
88   https://digital-strategy.ec.europa.eu/en/policies/cybersecurity-competence-centre 
89   Directive (EU) 2016/1148 of the European Parliament and of the Council of 6 July 2016 concerning measures 

for a high common level of security of network and information systems across the Union.  

90   Proposal COM 2020/823 for a Directive of the European Parliament and of the Council on measures for a 

high common level of cybersecurity across the Union, repealing Directive (EU) 2016/1148.  

91   Regulation (EU) 2019/941 on risk preparedness in the electricity sector and repealing Directive 2005/85/EC 

36 

 
 
 
 
                                                 
Examples of real cases of cyberattacks that show the consequences and impacts: 

  Recent  attacks  to  the  satellite  communication  networks  used  for  monitoring  of 
windfarms in Northern Europe. More than 5000 wind turbines lost connection for 
remote management. 

  The  Colonial  pipeline  ransomware  attack  in  May  2021.  It  halted  operations  for 
several days due to unavailability of their IT support systems. Several Federal States 
had  shortage  of  gasoline  and  other  oil  and  gas  products  impacting  hundreds  of 
thousands of citizens and companies. 

  The  Solar  Winds  compromise  of  its  software  supply  chain  embedding  malicious 
code in its Orion software and replicating it in the end customer’s installations. 
  The  power  grid  attack  in  Ukraine  in  2015  that  resulted  in  power  outages  lasting 

several hours. 

In addition to the public consultation, the Commission has also reviewed a number of projects 
co-funded by the Horizon 2020 Framework Programme in the field of cybersecurity (see the 
Annex  for  an  overview).  In  the  reviewed  sample  of  projects,  the  consortia  and  project 
coordinators  perceive  a  strong  role  for  cybersecurity  and  physical  security  for  their 
infrastructure.  

A number of the main lessons have been learned from projects: 

1)  Lack  of  interoperability  of  ICT  protocols  and  solutions:  different  communication 

protocols impeding a common cybersecurity framework in the energy sector.  

2)  There  are  number  of  organisational  barriers  (e.g.  perceived  insufficient  cooperation 
between  the  stakeholders  involved  in  regulation,  operations,  research,  production, 
testing and implementation of cybersecurity solutions). 

3)  The roles and responsibilities of the parties involved in the prevention, detection and 
resolution of cybersecurity incidents should be better defined and implemented so that 
they can effectively support crisis operations.  

4)  Research  and  innovation  of  digital  products  should  include  the  concept  of 

Cybersecurity by design.  

5)  Certification schemes for products and services are still lacking.  
6)  Sector  specific  information  sharing  networks  are  proving  very  useful  for  to  timely 
reaction  to  security  threats..  This  should  also  be  the  case  for  energy  equipment 
manufacturers and technology vendors.  

7)  The so-called smart technology makes new services and products possible but brings 
new  cybersecurity  risks.  For  example,  secure  gateways  for  smart  meters,  provide 
services in addition to measuring electricity consumption. They enable data exchanges 
that will most probably allow for the creation of new services. Similarly, to other sectors 
such as telecommunications, these new services and applications will need to be very 
reliable.  

The  upcoming  policy  work  should  address  these  and  other  challenges.  Close  cooperation 
between regulatory authorities, public administrations, the private sector and the general public 
will be necessary in order to ensure that on one side the energy system remains reliable in the 
new digital age and that it contributes to the wellbeing of the population. 

37 

 
 
 
 
  
6 

 Energy consumption of the ICT sector 

6.1  Context  

This action plan illustrates the potentially very significant economic, environmental and social 
benefits of digitalisation in the energy sector. Many other sectors and use cases, ranging from 
teleworking  and  e-learning  platforms  to  digital  tools  for  the  monitoring  of  climate  change, 
show that digitalisation is very useful from many different perspectives.  

These benefits are mainly thought of in socio-economic terms, but are also of an environmental 
nature:  in  2022,  the  European  Commission  launched  the  European  Green  Digital  Coalition 
(EGDC)92 which currently includes 34 signatories committed to working together with experts 
and academia on science-based methods to measure the net environmental impact of digital 
solutions across priority sectors, including the energy and power sectors. The Commission has 
also financed a European Parliament Pilot Project to assist with this. By the end of 2022, 18 
real-life case studies93 will be examined to help validate and refine the iterative development 
of  the  net  environmental  impact  methodology  across  sectors.  The  first  calculations  of 
environmental effects of green digital solutions for energy systems, as well as draft guidelines 
for deployment of digitalisation with enabling effects, will be available within 2023. 

The many beneficial use cases unlocked by digitalisation should not, however, obscure the fact 
that  the  ICT  sector  also  requires  energy  to  operate  and  is  not  climate-neutral.  Indeed,  the 
amount of energy consumed by the ICT sector is constantly increasing as the need for and use 
of digital tools, internet  traffic and the number of connected devices  rise. This immediately 
raises the question of the energy consumption of the ICT sector, its energy efficiency and its 
climate impact. This section aims to provide a framework and show concrete ways to address 
increasing energy consumption of the ICT sector. 

Firstly, it should be stressed that digitalisation affects all areas of society (households, private 
companies, public administrations, infrastructures, etc.) as well as almost all sectors (the most 
frequently mentioned for comparison during the Commission’s open public consultation were 
financial services, mobility, building, healthcare and advertising).  

This  transformation  has  proceeded  very  quickly  in  recent  decades,  requiring  significant 
corporate investment in communication networks and computation power, as well as household 
investment  in  telecommunication  equipment,  computers  and  other  electronic  devices.  This 
investment  has  gone  hand-in-hand  with  a  very  steep  increase  in  global  internet  traffic.  It  is 
estimated that internet traffic increased 12-fold between 2010 and 2020 (with an average annual 
growth rate of 30%)94. It is further expected that the internet traffic will continue to increase at 

92   https://www.greendigitalcoalition.eu/  
93   https://www.greendigitalcoalition.eu/case-studies/  
94   Data  Centres 

and  Data  Transmission  Networks, 
https://www.iea.org/reports/data-centres-and-data-transmission-networks#resources  

Paris 

IEA, 

–  November 

2021. 

38 

 
 
 
 
 
 
                                                 
a very fast rate of over 40% per year in coming years. This naturally has consequences in terms 
of energy consumption and the use of natural resources.  

Some  remarkable  energy-efficiency  gains  notwithstanding,  the  ICT  sector‘s  energy 
consumption has grown very large. It is estimated that the sector accounts for approximately 
7% of global electricity consumption and that this share is forecast to rise to 13% by 203095. 
This  is  between  3  and  5%  of  global  carbon  emissions,  which  is  on  a  par  with  the  aviation 
industry’s  emissions  from  fuel96.  More  recent  analysis  based  on  lifecycle  analysis 
methodologies  suggests  that  at  the  global  level,  ICT  systems  represented  4.2%  of  primary 
energy consumption, 5.5% of electricity consumption and 3.8% of greenhouse gas emissions. 
These three metrics are rising very fast and are expected to have roughly tripled between 2010 
and  2025.97  Finally,  a  recent  meta-study98  concluded  that  ‘published  estimates  all 
systematically  underestimate  the  carbon  footprint  of  ICT,  possibly  by  as  much  as  25%,  by 
failing to account for all of ICT’s supply chains and full lifecycle (i.e. emissions scopes 1, 2 
and  fully  inclusive  3).’  The  metastudy  also  deplores  the  lack  of  publicly  available  data 
underpinning many of these estimates. The fact that published estimates (particularly reports 
by companies on their ICT-related energy consumption) tend to underestimate the actual level 
of  energy  consumption  attributable  to  the  ICT  sector  is  widely  documented99.  Several 
converging indications therefore suggest that (i) current estimates of the ICT sector’s energy 
consumption are significant, (ii) this energy consumption is growing (albeit at a much slower 
pace than, for example, worldwide internet traffic), and (iii) current estimates of this energy 
consumption are likely to underestimate its actual magnitude. 

Secondly, energy consumption is certainly not the only relevant issue within the broader topic 
of the environmental footprint of ICT technologies. For instance, the use of natural resources 
such as water and rare earths, and the environmental impact of their extraction (which largely 
takes place outside the EU) is another impact of ICT technologies that some of the measures 
described below will  affect. Nonetheless, this section focuses mainly100 on the ICT sector’s 
energy consumption. In particular, it does not for several reasons contain a detailed analysis of 
the carbon emissions generated by this energy consumption. The main reasons for this are the 
following: 

  At the macro level, in order to match total energy demand with renewables/low carbon 
sources of energy, we need to increase the production of renewables/energy with a low 
carbon footprint while keeping overall energy demand at a reasonable level (and ideally 
decreasing  it).  The  relevant  metric  to  be  considered  from  the  demand  side  therefore 
appears to be energy consumption. This is also the approach taken by the Commission 
in the energy labelling framework (under which appliances are labelled according to 

95   Bertoldi,  P.,  Avgerinou,  M.  and  Castellazzi,  L.  ‘Trends  in  data  centre  energy  consumption  under  the 
European Code of Conduct for Data Centre Energy Efficiency’, 2017, EUR 28874 EN, Publications Office 
of the European Union, Luxembourg, 2017, ISBN 978-92-79-76445-5, doi:10.2760/358256, JRC108354 

96   Nicolas  Jones,  “How 

to  stop  data  centres  from  gobbling  up 

the  world’s  electricity”.  See 

https://www.nature.com/articles/d41586-018-06610-y  

97   See https://www.greenit.fr/wp-content/uploads/2019/11/GREENIT_EENM_etude_EN_accessible.pdf  
98   See 

trends  and 

impact  of 

review  of 

estimates, 

ICT:  A 

climate 

“The 

regulations”: 

https://arxiv.org/ftp/arxiv/papers/2102/2102.02622.pdf  

99   Klaaßen,  L.,  Stoll,  C.  “Harmonizing  corporate  carbon  footprints.”  Nat  Commun  12,  6149  (2021).  See 

https://www.nature.com/articles/s41467-021-26349-x  

100   Though not only – for instance non-energy-related environmental impacts linked to the manufacture of ICT 
devices  and  the  extraction  and  production  of  the  necessary  materials  (in  particular  rare  earths)  will  be 
discussed in the sub-section on the production of ICT equipment. 

39 

 
 
                                                 
their  energy  consumption,  rather  than  their  carbon-intensity),  as  well  as  in  the 
Commission's energy efficiency first principle101. 

  The carbon footprint of a given technology depends largely on the carbon intensity of 
electricity in a given country. However, significant variations in the carbon intensity of 
different electricity mixes in different EU Member States confuse the issue. 

  This section is a sub-area of the overall action plan. As such, the digitalisation of the 
energy sector is likely to entail increased use of data centres and network equipment 
(through  an  increase  in  data  exchange).  By  comparison,  the  use  of  small  portable 
devices (e.g. mobile phones) is likely to be relatively unaffected by this  action plan. 
Since  the  embodied  carbon  footprint  and  environmental  impact  of  devices  is 
proportionately greater for small devices (due to their lower energy consumption and 
shorter life span) than for larger devices and network equipment, energy consumption 
is one of the environmental aspects of ICT most likely to be negatively impacted by the 
digitalisation of the energy sector. It therefore seemed natural to address this aspect as 
a priority. 

Thirdly, this section considers the ICT sector’s energy consumption and environmental impact 
throughout  the  entire  value  chain.  This  value  chain  is  traditionally  broken  down,  for  the 
purposes  of  analysing  the  ICT  system’s  energy  consumption  into:  (i)  energy  consumption 
during the manufacture of ICT devices, (ii) the energy consumption of consumers’ devices, 
(iii)  the  energy  consumption  of  networks,  and  (iv)  the  energy  consumption  of  data  centres. 
Most recent analysis suggests that the energy consumption of consumers’ devices accounted 
for roughly 50% of the overall energy consumption of ICT technologies in 2020. The next two 
most  significant  contributors  were  the  production  of  ICT  devices  (~20%)  and  data  centres 
(~15%).  This  is  expected  to  change  drastically  by  2030,  however,  as  the  overall  energy 
consumption of ICT technologies is expected to increase by 50% during the 2020s. The top 
three  contributors  in  2030  would  then  be  consumers’  devices  (33%  of  the  overall  energy 
consumption of ICT technologies), data centres (30%) and networks (27%). In particular, while 
the  energy  consumption  of  consumer  devices  will  decrease  (due  to  a  progressive  switch  to 
smaller terminals), the electricity demand of data centres (currently close to 0.8% of global 
final electricity demand102) is expected to grow between three and five times by 2030, to as 
much  as  974  TWh  worldwide  (3.9%  of  global  final  electricity  demand)  with  a  best-case 
scenario of 366 TWh (1.5%). Similarly, the energy consumption of fixed and mobile networks 
is expected to grow three fold by 2030103. An overview of these developments is provided in 
Figure 2 below. 

Figure 2: overview of the different components of the energy consumption of the ICT sector 
in 2020 and 2030 (projected) according to Andrae, A.S.G. (worldwide, in TWh) 

101   See 

https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-

rules/energy-efficiency-first-principle_en  

102   The  International  Energy  Agency  estimated  to  be  200  TWh  in  2019.  Andrae  and  others  estimated  it  to 

be~300TWh in 2020. 

103   See Andrae, A.S.G. (2020a) ‘New perspectives on internet electricity use in 2030’. Engineering and Applied 

Science Letters DOI: 10.30538/psrp-easl2020.0038 

40 

 
 
 
                                                 
Source: Andrae, A.S.G. (2020a) “New perspectives on internet electricity use in 2030”. Engineering and Applied Science 
Letters DOI: 10.30538/psrp-easl2020.0038  

The International Telecommunication Union (ITU) has also published estimates for the current 
energy consumption of the different segments of the ICT value chain in 2020, as well as so-
called  “trajectories”  for  2030.104  While  these  figures  are  more  or  less  in  line  with  the  ones 
presented  above  for  2020,105  the  recommended  trajectories  for  2030  appear  substantially 
lower.106 An overview of these figures  (corrected  for the difference in scopes mentioned in 
Footnote 105) is presented in Figure 3 below. 

Figure 3: overview of the different components of the energy consumption of the ICT sector 
in 2020 and 2030 (recommended) according to the ITU (worldwide, in TWh) 

104   See  “Greenhouse  gas  emissions  trajectories  for  the  information  and  communication  technology  sector 
compatible  with  the  UNFCCC  Paris  Agreement”,  available  at  https://www.itu.int/rec/T-REC-L.1470-
202001-I/en. It should be noted that ITU provides in this document a set of “normative trajectories” in line 
with different climate objectives. As such the exercise is somewhat different from a forecasting exercise, as 
performed by Andrae, A.S.G.  

105   The difference observed for the energy consumption of devices in operation is due to the fact that TVs are 
not accounted for in the ITU figures. When correcting for the different scopes, the figure of ~1 000 TWh for 
the  energy  consumption  of  devices  (including  TVs)  in  operation  in  2020  appears  consistent  across  both 
publications. 

106   To  the  extent  that  it  is  relevant  to  compare  projections  with  recommended  trajectories. See  Footnote  104 

above. 

41 

 
 
 
                                                 
ICT consumption in 2020 and 2030

2500

2000

1500

1000

500

0

Consumer devices

Fixed access networks Wireless networks

Data centres

Production of devices

Source: ITU: “Greenhouse gas emissions trajectories for the information and communication technology sector compatible 
with the UNFCCC Paris Agreement”, available at https://www.itu.int/rec/T-REC-L.1470-202001-I/en. 

Any projections (or trajectories) are indeed accompanied by several major uncertainties. On 
the demand side,  it is difficult to  predict the actual  form  and main drivers of  ICT services’ 
demand  in  the  2020s.  This  demand  could  be  influenced  by  the  uptake  of  new  solutions, 
technologies and business models (e.g. AI, autonomous vehicles, advanced/virtual reality, edge 
computing,  cryptocurrency  mining  and  IoT  technologies).  The  uncertainties  are  equally 
significant on the supply-side, where the main driver of ICT energy-efficiency over the past 
few  decades  has  been  the  miniaturisation  of  electronic  circuits,  which  is  currently  slowing 
down. Future performance gains might be based more on the parallelisation of computational 
power, which may nonetheless lead to increasing energy consumption. Major breakthroughs in 
computing technologies and the subsequent rate of technology adoption are evidently hard to 
predict. The opportunities provided by quantum computing could lead to a radical decrease in 
energy consumption by some very energy-intensive applications. 

6.2  Key actions 

Production of ICT devices 

ICT devices are mostly manufactured outside the EU. Ways to reduce energy consumption in 
this area include (i) imposing tougher sustainability standards for these products (e.g. in terms 
of the use of recycled or recyclable materials, reparability or recyclability), (ii) making them 

42 

 
 
 
 
 
last  longer107  and  (iii)  promoting  their  reuse108  (e.g.  by  developing  a  secondary  market  for 
smartphones). 

The recently proposed Ecodesign for Sustainable Products Regulation (ESPR)109 will be the 
cornerstone of the EU’s circular economy action plan. It will in particular amend the Ecodesign 
Directive and introduce new measures to increase the sustainability of products placed on the 
EU  market.  It  will  establish  sustainability  principles  and  specific  requirements  linked  to 
environmental and, where appropriate, social aspects. It will also contain the changes to the 
EU  legal  framework  that  are  needed  to  achieve  the  objectives  set  out  in  the  2020  circular 
economy action plan110. 

The ESPR will in particular address a selection of product groups, including electronic and ICT 
products. 

It will: 

  establish overarching product sustainability principles; 
 

require  producers  to  provide  more  circular  products  and  intervene  before  products 
become  waste  (e.g.  providing  products  as  a  service,  providing  repair  services,  and 
ensuring that spare parts are available); 

  set  requirements  for  mandatory  sustainability  labelling  and/or  the  disclosure  of 
information  to  market  actors  along  value  chains  in  the  form  of  a  digital  product 
passport; 

  set minimum sustainability requirements for the public procurement of products; 
 

impose  measures  on  production  processes  (e.g.  to  facilitate  recycling  and/or 
remanufacturing); 

  ban the destruction of unsold durable goods. 

Energy consumption of ICT devices in operation 

Energy  consumption  by  consumers’  devices  is  the  only  component  of  overall  ICT  energy 
consumption that is expected to decrease by the end of the current decade according to Andrae, 
A.S.G., because of a progressive switch to smaller terminals111. However, the fact remains that 
electricity  consumption  by  our  terminals  currently  represents  over  50%  of  the  ICT  sector’s 
energy consumption and is expected to still represent 33% of its energy consumption by 2030 
(still over 50% in 2030 according to the ITU trajectories).  

107    Provided that this is not counter-productive (e.g. when more energy-efficient products come onto the market). 
This  would  depend  in  particular  on  the  balance  between  the  in-built  carbon  footprint  (resulting  from  the 
product’s manufacture) and the carbon footprint related to the use of the product. As mentioned above, the 
in-built carbon footprint and environmental impact of devices is in general disproportionately larger for small 
devices. See in particular Malmodin, J. and Lundén, D., ‘The Energy and Carbon Footprint of the Global ICT 
and E&M Sectors 2010-2015’, Sustainability, 2018, 10, 3027. 

108   Subject to the same caveats as above. 
109   https://environment.ec.europa.eu/publications/proposal-ecodesign-sustainable-products-regulation_en   
110   https://environment.ec.europa.eu/strategy/circular-economy-action-plan_en  
111   The size of the screen has a crucial impact on the overall energy consumption of many types of electronic 

devices. 

43 

 
 
 
                                                 
The Commission’s ecodesign framework 

The  Commission  has  in  recent  years  enacted  product-specific  ecodesign  regulations  that 
apply  to  a  range  of  products,  including  several  types  of  electronic  products112.  These 
ecodesign  regulations  have  led  to  a  remarkable  improvement  in  the  energy  efficiency  of 
electronic  products  sold  in  the  EU,  generating  considerable  energy  savings113.  The 
Commission has also introduced an energy labelling obligation for a more restricted range 
of  products  (electronic  displays  are  the  only  electronic  products  currently  subject  to  this 
energy labelling obligation). 

Computers account for a significant portion of the energy consumption attributed to consumer 
electronic devices, because both companies and private households have many such devices 
and because a laptop computer consumes over 10 times more energy than a smartphone during 
its  operational  life  (and  5-6  times  more  energy  than  a  tablet)  –  while  a  desktop  computer 
consumes 5-6 times more energy than a laptop computer (i.e. 25-35 times more than a tablet 
and more than 50-60 times more than a smartphone) during its operational life114. It is therefore 
crucial to address computers’ energy consumption115. 

While  some  existing  labels  provide  information  on  the  idle-state  energy  consumption  of 
computers (e.g. the US-EPA voluntary Energy Star logo), no label provides information on the 
energy efficiency of an actively working computer. Idle-state labels are also now considered 
outdated  –  despite  the  recent  tightening  of  some  of  their  requirements  –  because  of  the 
significant  progress  made  in  limiting  the  idle-state  energy  consumption  of  computers.  As  a 
result, consumers  and businesses  currently  have no indicators that they  can use to  make  an 
informed choice and to compare the energy efficiency of different computers when they are in 
operational mode. 

Computers are very versatile and are used for very different purposes. This makes it very hard 
to  formulate  a  proposal  on  energy  labelling  for  computers.  Depending  on  its  hardware  and 
design characteristics, a computer could be very energy-efficient when performing ordinary 
office activities (e.g. editing text, videoconferencing and e-mail management), but very energy-
inefficient when used for intense gaming with very high speed and graphics resolution. This 
energy  labelling  proposal  will  therefore  use  a  set  of  worklets  to  assess  computers’  energy 

112  These product-specific ecodesign regulations apply to electronic displays, set-top boxes, computers, video 
game consoles, external power supplies, imaging equipment, servers and data storage products. They also 
apply to the standby-mode energy consumption of an even wider range of electronic products (e.g. imaging 
equipment, small appliances, complex set-top boxes, wireless audio speakers and radios) and products not 
falling within the traditional definition of electronic products (e.g. electric ovens). 

113  See  ‘Ecodesign  impact  accounting  annual  report  2020’:  https://op.europa.eu/en/publication-detail/-

/publication/568cac02-5191-11ec-91ac-01aa75ed71a1/language-en.  

114   See Malmodin, J.; Lundén, D. (2018), ‘The Energy and Carbon Footprint of the Global ICT and E&M Sectors 
2010-2015’,  Sustainability  2018, 10,  3027.  Part  of  the  reason  for  the  differences  is  the  reference  lifespan 
chosen for these devices. This is taken to be 5 years for a desktop computer, 4 years for a laptop computer or 
a tablet and 3 years for a smartphone. However, this is clearly not the main reason for the very significant 
differences outlined here. 

115   As mentioned above, an existing EU energy labelling scheme already targets electronic displays – the other 
category of electronic devices identified in the above-mentioned report as being significant energy consumers 
(and  the  only  ones  with  an  energy  consumption  higher  than  desktop  and  laptop  computers).  An  energy 
labelling  scheme  for  computers  therefore  appears  to  be  the  logical  next  step  for  addressing  the  energy 
consumption of electronic devices within the energy labelling context. 

44 

 
 
 
                                                 
consumption in different situations (i.e. (i) office work, (ii) gaming and (iii) graphic design and 
video  editing),  with  a  view  to  setting  three  different  ratings  that  are  best  suited  to  the 
purchaser’s precise needs. 

Finally, such energy labelling may pave the way for new and ambitious ecodesign regulations 
for other complex electronic devices (e.g. smartphones and tablets). 

Network’s energy consumption 

As mentioned above, both fixed and mobile networks’ energy consumption is expected to more 
than  triple  between  2020  and  2030  according  to  Andrae,  A.S.G.  This  is  hardly  surprising 
because, with a current compound annual growth rate (CAGR) of over 40%, global internet 
traffic is set to increase by almost 30 times over that period. The difference between these two 
figures highlights the remarkable progress made (and still expected to be made in the coming 
years)  in  terms  of  network  components’  energy  efficiency.  The  roll-out  of  fibre  networks 
(requiring much less energy to operate by unit of data transported) and 5G technology (also 
more energy-efficient) are the main reasons for these rather optimistic predictions. The energy 
consumption of networks is nevertheless set to become a major component of the ICT sector’s 
overall energy consumption by 2030. The main components of global internet traffic nowadays 
are  –  by  far  –  video  streaming  (over  60%  of  total  traffic),  online  gaming  and  social 
networking116. There are indications that online gaming and downloading video games could 
become an even more significant contributor to the mix – due in part to the increase in the size 
of downloads and the importance of latency117.  

The  Commission  has  addressed  this  topic  in  its  energy-efficiency  approaches  by  funding 
research  projects  aimed  at  improving  the  energy  consumption  and  efficiency  of  network 
components,  protocols  and  architectures.  The  One5G  research  project118  brought  together 
telecommunications operators, component and infrastructure vendors, universities and research 
centres from  across the EU with the aim of boosting mobile networks’ capacity, improving 
their energy efficiency and making possible a variety of new vertical use cases in both dense 
urban areas and rural environments. Other research projects have targeted the emerging and 
fast-growing transmission of IoT data. For example, the SerIoT project119 developed energy-
aware  data-flow  routing  in  IoT  networks  –  thus  minimising  energy  consumption  while 
guaranteeing optimal quality of service and security through software defined network (SDN) 
routing. 

In addition, the revision of the Broadband Cost Reduction Directive, will have both direct and 
indirect  benefits  for  the  energy  efficiency  of  electronic  communication  networks.  These 
benefits  stem  from  promoting  the  deployment  of  more  energy-efficient  fibre  and  5G 
technologies.  The  new instrument will  also  strive to  promote synergies  with  the renovation 
wave for energy efficiency purposes to  equip  buildings at  the same time  with  advanced in-
building connectivity physical infrastructure and wiring. 

Conversely,  some  regulators  have  (basing  themselves  on  the  idea  that  reversing  or  merely 
halting the current upward trend in internet traffic could help reduce the energy consumption 

116https://www.sandvine.com/covid-internet-spotlight-report 

and 

https://www.sandvine.com/hubfs/Sandvine_Redesign_2019/Downloads/Internet%20Phenomena/Internet%
20Phenomena%20Report%20Q32019%2020190910.pdf.  

117   https://www.de-cix.net/en/about-de-cix/news/cloud-gaming-as-driver-for-the-internet-traffic-of-the-future.  
118   https://one5g.eu/  
119   https://seriot-project.eu/  

45 

 
 
                                                 
of networks – including by postponing the need for new investment in response to increased 
traffic) introduced legal measures to give individuals a better idea of how much energy they 
are actually consuming through their online activities. It is believed that raising individuals’ 
awareness of this would prompt them to reduce their consumption as and when possible, and 
would ultimately make it possible to reduce (or limit an increase in) the amount of data passing 
through the networks. Raising individuals’ awareness of their energy consumption during their 
day-to-day digital activity (e.g. video streaming, sending an e-mail with a large attachment, 
playing online videogames and listening to music online) is a prerequisite for more data-frugal 
and responsible  behaviour  and  could  produce positive results without the need  for  coercive 
measures. 

France  is  a  particular  case  in  point.  It  adopted  a  law  on  15 November 2021  to  reduce  the 
environmental  footprint  of  digital  technologies120.  The  law  contains  several  provisions  to 
provide  consumers  with  better  information  on  the  real  energy  consumption  (and  equivalent 
CO2 emissions) of their online streaming activities. 

Encouraging data frugality – the example of France 

France  has  passed  one  of  the  most  ambitious  laws  on  the  energy  consumption  of  ICT 
technologies, notably from the digital frugality perspective. Article 23 of the law introduces, 
as  of  1 January 2023,  an  obligation  for  the  French  audiovisual  regulator  to  publish  a 
recommendation for television and on-demand video services and video-sharing platforms 
to inform consumers of their energy consumption and equivalent CO2 emissions. Article 26 
states that this information should take account of how content is accessed as well as the 
display resolution.  

The  Commission  has  adopted  a  similar  approach.  In  2019,  the  communication  Shaping 
Europe’s  digital  future  mentioned  the  opportunity  to  introduce  ‘transparency  measures  for 
telecoms  operators  on  their  environmental  footprint’  at  EU  level121.  More  recently,  the 
Declaration  on  European  Digital  Rights  and  Principles  published  on  26 January 2022 
emphasised in Chapter VI that ‘everyone should have access to accurate, easy-to-understand 
information  on  the  environmental  impact  and  energy  consumption  of  digital  products  and 
services, allowing them to make responsible choices.’122  

To  make  individuals  more  aware  of  the  impact  of  their  digital  services  consumption,  the 
Commission will also fund a study to quantify in detail the energy consumption of a number 

120   LOI  n°  2021-1485  du  15  novembre  2021  visant  à  réduire  l'empreinte  environnementale  du  numérique  en 
France  (Law  No  2021-1485  of  15  November  2021  aimed  at  reducing  France’s  digital  carbon  footprint): 
introduced  a 
https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000044327272.  France  had  already 
transparency 
consumers  
 in  their  bills  of  the  energy  consumption  and  equivalent  CO2  emissions  associated  with  their  data 
consumption. The French energy agency ADEME published the methodology for establishing these figures 
on 
https://www.ademe.fr/expertises/consommer-autrement/passer-a-laction/reconnaitre- 

telecommunications 

14 December 2021: 

obligation 

operators 

inform 

for 

to 

produit-plus-respectueux-lenvironnement/dossier/laffichage-environnemental/affichage-environnemental- 
secteur-numerique.  

121 

https://ec.europa.eu/info/strategy/priorities-2019-2024/europe-fit-digital-age/shaping-europe-digital-

future_en  

122   https://digital-strategy.ec.europa.eu/en/library/declaration-european-digital-rights-and-

principles#Declaration  

46 

 
 
 
                                                 
  
 
of representative day-to-day digital behaviours. This will provide reliable and simple estimates 
for use in a communication and awareness-raising campaign. 

Energy consumption of data centres 

Data centres are a core infrastructure element of ICT systems. As mentioned above, the energy 
consumption of data centres is expected to more than triple between 2020 and 2030123 due to 
increased  demand  for  decentralised  services  and  the  huge  increase  expected  in  internet 
traffic124. Data centres could thus become a major contributor to ICT energy consumption by 
2030. In absolute terms, the energy consumption of data centres in the EU was 76.8 TWh in 
2018. This is expected to rise to 98.5 TWh by 2030 – a 28% increase. In relative terms, data 
centres accounted for 2.7% of the EU’s electricity demand in 2018; this will reach 3.2% by 
2030  if  current  trends  continue125.  Moreover,  unlike  consumer  devices  and  networks,  the 
energy consumption of data centres is very unevenly distributed from a geographical point of 
view.  This  can  cause  concern  in  local  communities  and  even  introduce  constraints  in  the 
electricity  grids  at  local  level.  In  the  most  extreme  case  in  the  EU  –  Ireland –  data  centres 
consume 14.5% of electricity nationally, but this is much higher in some areas126. It is expected 
that data centres will account for 24% of national electricity consumption in Ireland by 2030.127 
In  other  Member  States  such  as  Sweden,  the  relocation  of  cryptocurrency  mining  activities 
following  their  prohibition  by  China  in  May 2021  placed  a  significant  extra  burden  on  the 
electricity network and fuelled the public’s concerns about the sustainability of such activities. 

The Commission long ago identified data centres’ energy consumption as a key topic and put 
in place its first policy tools. 

The Code of Conduct for data centres and its application in different policy tools 

The Code of Conduct for data centres was adopted in 2008. It is a voluntary tool to inform and 
encourage  data  centre  operators  and  owners  to  reduce  their  energy  consumption  in  a  cost-
effective  manner  (without  hampering  the  key  function  of  data  centres)  by  improving 
understanding  of  energy  demand  within  the  data  centre,  raising  awareness  of  their  energy 
consumption  and  possible  ways  to  decrease  it,  and  recommending  energy-efficient  best 
practices and targets. The Commission published green public procurement criteria in 2020. 
These  provide  Member  States  with  guidelines  for  building/purchasing  data  centres,  server 
rooms and cloud services. They frequently refer to participation in the Code of Conduct as a 
key criterion for the selection of data processing, cloud services or hosting services in public 
tenders128.  The  Code  of  Conduct  underwent  a  major  revision  in  2022.  This  included  (i)  an 
expansion  of  its  scope  to  include  non-energy-related  environmental  indicators  (e.g.  water 

123   According to Andrae, A.S.G. ITU trajectories foresee a more modest 20% increase over the same period. 
124   The share of cloud data centres accounted for 10% of data centres’ energy consumption in 2010. It increased 
2025. 
expected 

to 
and 
https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=71330. 

increase 

2018 

35% 

60% 

to 

to 

in 

in 

is 

125  https://digital-strategy.ec.europa.eu/en/library/energy-efficient-cloud-computing-technologies-and-policies-
eco-friendly-cloud-market  
126   Data centres’ energy consumption is also a cause of public concern and social tension in the Netherlands, 
where  a  large data  centre planned by  Meta/Facebook in Zeewolde is expected to use  the same  amount of 
energy annually as the city of Amsterdam. 

127   Source: BloombergNEF study on the grid integration of data centres. 
128  https://ec.europa.eu/environment/gpp/pdf/20032020_EU_GPP_criteria_for_data_centres_server_rooms_and 

cloud_services_SWD_(2020)_55_final.pdf  

47 

 
 
                                                 
consumption), (ii) the inclusion of new indicators on the share of renewable energy use and 
(iii) the inclusion of new indicators on the share of energy reuse. 

Studies 

The Commission has commissioned several studies to inform its policymaking. These include 
the 2020 study on ‘Energy-efficient Cloud Computing Technologies and Policies for an Eco-
friendly  Cloud  Market’129  and  the  2022  study  ‘Greening  Cloud  Computing  and  Electronic 
Communications Services and Networks: towards climate neutrality by 2050’130. 

The topic of the interaction between data centres and the electricity grid was the focus of several 
European research projects which didn’t reach commercial stage in the Commission’s Seventh 
Framework Programme131. This topic however appears relatively unexplored in literature to 
date, with the exception of a few studies, notably by CERRE 132. In 2022, the Commission will 
initiate a study on the integration of data centres within the energy network. This study will 
serve the aim of answering multiple questions related to the interaction between data centres 
and the grid, such as: 

  To what extent and how can data centres contribute to the stability of the electricity 

grid?  

  Can backup energy supply/uninterruptible power supply (UPS) be used and, if so, how? 
  How would the introduction of a more granular system for guarantees of origin affect 
the green electricity supply claims of data centre operators and how to address this? 
  Can data centres engage in demand-response133; if so, can one quantify the potential for 
demand response from data centres in the EU? How could this work for colocation data 
centres, which represent a significant share of all the installed data centres in the EU? 
  Would better-informed choices about the geographical location of data centres enable 
better  integration  of  them  into  the  energy  system  (for  instance,  by  contributing  to 
heating networks/district heating)?134 

  How  can  data  centres  offset  the  potential  destabilising  effects  they  have  on  local 

electricity networks?135 

  Do  data  centres  consume  all  available  renewable  electricity  in  order  to  satisfy  the 
additional electricity demand that they generate (to the detriment of the overall carbon 
footprint of the EU’s electricity systems) – or do they have a positive overall ‘stirring’ 
effect on the development of new renewables projects by creating security of income 
and reducing risk for project holders (with a beneficial long-term effect)?  

129   Energy-efficient Cloud Computing Technologies and Policies for an Eco-friendly Cloud Market | Shaping 

Europe’s digital future (europa.eu)  

130   https://www.ideaconsult.be/en/projects/study-on-greening-cloud-computing-and-electronic-

communications-services-and-networks-towards-climate-neutrality-by-2050  

131   https://www.smartcitiescluster.eu/projects  
132   To the  exception of the study  “Data  centres  & the grid  – Greening ICT in Europe” by Catherine Banet, 
Michael  Pollitt,  Andrei  Covatariu  and  Daniel  Duma,  produced  by  CERRE  –  see  https://cerre.eu/wp-
content/uploads/2021/10/211013_CERRE_Report_Data-Centres-Greening-ICT_FINAL.pdf  

133   See for instance https://blog.google/inside-google/infrastructure/data-centers-work-harder-sun-shines-wind-

blows/.  

134   It is debatable whether data centres have much choice in choosing their location in the first place, given all 
the constraints regarding the availability of connectivity, energy supply and free constructible space, growing 
public concerns, and local authorities’ reluctance to have data centres locate in certain areas. See, for instance, 
https://www.datacenterdynamics.com/en/news/dutch-government-halts-hyperscale-data-centers-pending-
new-rules/. 

135   https://www.iea.org/commentaries/data-centres-and-energy-from-global-headlines-to-local-headaches  

48 

 
 
                                                 
Research projects and pilots 

The Commission  has also funded  a number of research projects  and pilots on data centres’ 
energy  consumption  and  energy  efficiency.  In  doing  so,  it  followed  a  very  focused  and 
methodical approach in order to launch several successive waves of thematic projects to build 
on  previous  projects.  An  overview  of  these  successive  waves  and  the  name  of  the  relevant 
projects is provided in Figure 4 below. 

Figure 4: overview of EC research projects aimed at improving the energy efficiency of data 
centres 

Boden-type data centres  

One of the most recently completed projects was the Boden-type data centre project, which 
sought to design the most efficient data centre in the world and achieved an astonishingly 
low power use effectiveness (PUE) of 1,015 in northern Sweden by exploring: 

• 

the possibility of synchronising server cooling with building cooling; 

the possibility of cooling components with colder air (while at the same time allowing 

• 
the central processing unit (CPU) temperature to remain higher than is usually allowed) 

Catalyst and Eco-Qube: two examples of ongoing EU-funded projects  

  The  Catalyst  project  seeks  to  convert  data  centres  into  energy-flexible  assets  by 
turning  existing/new  data  centres  into  flexible  multi-energy  hubs  that  can  support 
investment in renewable energy sources and energy efficiency by offering mutualised 
flexibility services to smart energy grids (both electricity and heat grids). 

49 

 
 
 
 
 
 
 
  The Eco-Qube project seeks to improve the energy efficiency of small data centres’ 
instant cooling systems by developing an AI-enhanced holistic management system 
for data centres that connects cooling systems, IT loads and electrical infrastructure. 

Data centres usually produce waste heat in summer and/or when it is hot outside. This means 
that a significant share of data centres’ waste heat is produced when nobody needs it (at least 
for domestic heating purposes). The Commission intends to propose in the context of the 2023-
2024 Horizon Europe work programme to fund a project to  explore the possibility of using 
seasonal heat storage for the waste heat produced by data centres. 

Regulation (EU) 2019/424 on the ecodesign of servers and data storage products 

Servers  and  data  storage  products  are  a  critical  component  of  data  centres.  The  individual 
energy efficiency of the servers and data storage products they contain can therefore have a 
drastic impact on a data centre’s energy consumption. 

Regulation  (EU)  2019/424  on  the  ecodesign  of  servers  and  data  storage  products136  sets 
requirements  for  the  energy  efficiency  (e.g.  the  minimum  efficiency  of  the  internal  power 
supply unit or minimum active-state efficiency for servers) and material efficiency (e.g. the 
extent to which certain components can be disassembled) of servers and data storage products. 
It also sets information requirements on the operating conditions class/temperature. The review 
of  this  Regulation  will  help  assess  various  potential  improvements  in  order  to  tighten  its 
requirements, in particular: 

  operating  conditions  for  servers  and  data  storage  products  (particularly  in  terms  of 
maximum temperatures, which could have a positive impact on the energy consumption 
of cooling systems); 

  product-specific requirements for the standby-readiness of servers; 
  product-specific requirements for servers’ DC (direct current) power supply; 
  product-specific requirements for liquid cooling systems and solutions; 
  product-specific requirements for waste heat recovery systems and solutions; 
  product-specific  requirements  for  information  on  core  chip  temperature  and  the 
possibility  of  externally  overriding  internal  fan  speed  control  (the  Boden-type  data 
centre project demonstrated the relevance of this). 

The review is also assessing the technical and economic feasibility and relevance of introducing 
an energy label requirement for servers and data storage products (perhaps in the form of a 
label  comprising  targeted  indicators  for  the  different  possible  uses  of  the  product  –  e.g.  as 
webserver, disk server, database server or file/disk server). 

Such  labelling  may  be  an  excellent  opportunity  to  promote  the  best  performing  products, 
especially  in  the  context  of  public  tendering  and  procurement,  or  the  Green  Taxonomy. 
Moreover, the fact that the performance data declared and used in the context of an energy 
labelling scheme is formally declared and potentially verifiable by authorities avoids the need 

136  

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R0424  

50 

 
 
 
 
 
 
                                                 
for very burdensome verification of performance claims by the tendering body – reducing the 
cost of processing offers and the time needed to select the supplier and award the contract. 

Corporate sustainability reporting directive 

On  21  June  2022,  the  Council  and  European  Parliament  reached  a  provisional  political 
agreement on the corporate sustainability reporting directive (CSRD), initially proposed by the 
Commission on 21 April 2021. The CSRD amends the existing reporting requirements of the 
Non-Financial Reporting Directive that currently apply to large public-interest companies with 
more than 500 employees, and extends the scope to all large and all listed companies in the 
EU, as well  as non-EU companies with  activities in the EU above a certain threshold. This 
CSRD mandates the adoption of EU sustainability reporting standards. The Commission has 
instructed  the  European  Financial  Reporting  Advisory  Group  (EFRAG)  to  propose  a  set  of 
draft standards to this effect. 

The Commission will consider, depending on the technical advice it receives from EFRAG, 
including  an  obligation  for  companies  to  separately  report  on  significant  indirect  GHG 
emissions  from  the  procurement  of  cloud  computing  and  data  centre  services  under  the 
’upstream purchasing’ category of their “Scope 3” emissions.137 Such an obligation would raise 
the awareness, reflection and information gathering of data centre operators and their clients 
with respect to the issue of GHG emissions. 

The EU Taxonomy 

The  EU  Taxonomy  for  Sustainable  Finance  also  includes  criteria  for  data  centres.  It  lists 
compliance with the EC Code of Conduct for Energy Efficiency in Data Centres as a necessary 
prerequisite under the criteria on how to substantially contribute to climate mitigation through 
“data processing, hosting and related activities”. 

The European Chips Act 

Chips are the building block of servers and data storage products. They are therefore a crucial 
component of data centres and have a decisive impact on their energy consumption. One of the 
main  purposes  of  the  European  Chips  Act138,  adopted  on  8 February 2022,  is  to  build  and 
strengthen  the  EU’s  capacity  to  innovate  in  the  design,  manufacturing  and  packaging  of 
advanced, energy-efficient and secure chips. It also sets out certification procedures for energy-
efficient and trusted chips to guarantee quality and security for critical applications. More than 
EUR 43 billion of policy-driven investment will support this initiative until 2030. This will be 
broadly matched by long-term private investment. 

Revision of the Energy Efficiency Directive  

137 The widely used framework designed by the GHG Protocol to report on a given company’s GHG emissions 
distinguishes three types of emissions: Scope 1 refers to direct emissions from owned or controlled sources, Scope 
2 refers to emissions from the generation of purchased electricity, and Scope 3 refers to all other indirect emissions 
from up- and downstream activities along the value chain.  
138 
act#:~:text=The%20European%20Chips%20Act%20will%20reinforce%20the%20semiconductor,its%20global
%20market%20share%20in%20semiconductors%20to%2020%25.  

https://digital-strategy.ec.europa.eu/en/policies/european-chips-

51 

 
 
                                                 
The Energy Efficiency Directive (EED) is being revised with the aim of further promoting and 
strengthening the EU’s energy efficiency policies. The EED revision will address the question 
of data centres’ energy consumption by proposing a range of new requirements: 

  an obligation to assess the economic feasibility of increasing the energy efficiency of 
heat  supply  for  data  centres  exceeding  a  certain  threshold  (Article 23(4)  of  the 
Commission’s proposal); 

  green procurement criteria for the purchasing by public bodies of data centres, server 

rooms and cloud services (Annex IV); 

  a  monitoring  and  reporting  requirement  for  data  centres’  energy  consumption 

(Article 11(10)). 

The monitoring and reporting requirement will help build knowledge of the sector, which is 
currently lacking, by identifying the data centres in the EU and providing a better understanding 
of their distribution and main characteristics. In the longer term, it will also be used for the 
purpose of establishing an energy and environmental labelling scheme for data centres. This 
will  create  more  transparency  in  the  sector  and  serve  as  a  selling  point  for  top-performing 
companies (colocation data centres will be able to advertise their performance to their corporate 
customers  and  business  data  centres  will  be  able  to  advertise  their  performance  to  their 
customers and shareholders)139. This labelling scheme will probably transform the entire EU 
data centre industry, because it will make the energy and environmental performance of data 
centres more visible and make it a key factor in consumer choice and industry planning. 

Energy consumption of cryptocurrencies 

In addition to the elements examined above (i.e. the manufacture of ICT devices, the energy 
consumption  of  devices  in  operation,  the  energy  consumption  of  networks  and  the  energy 
consumption of data centres), some first generation cryptocurrencies have raised, in the course 
of the past decade, issues related to their environmental sustainability. They are widely seen as 
ICT-related  consumers  of  energy  and  related  physical  resources  such  as  semiconductors. 
Bitcoin  is  by  far  the  most  energy-consuming,140  because  it  relies  on  the  relatively  outdated 
“Proof-of-Work”  consensus  mechanism.  Various  sources141  agree  that  bitcoin’s  monthly 
energy consumption has increased tenfold over the past 5 years and has more or less doubled 
in the last 2 years, reaching a peak of 10.67 TWh in May 2022 (roughly 140 TWh annualised), 
before dropping to 9.68 TWh in June 2022 (84.87 TWh annualised), as a direct consequence 
of a decrease in bitcoin’s value, which has reduced incentives to “mine” bitcoin.142 The energy 
consumption of bitcoin mining143 has therefore attracted considerable public attention in recent 

139  As is already the  case  when a company invests in a very and efficient data  centre infrastructure  – see for 

instance https://www.euronext.com/en/technology/euronext-data-centre. 

140   It is estimated that bitcoin alone represents over two third of the energy consumption of all cryptocurrencies, 
the second largest cryptocurrency in terms of energy consumption being Ethereum, accounting for merely 
~10%  of  the  total.  See  Ulrich  Gallersdörfer  Lena  Klaaßen  and  Christian  Stoll,  “Energy  Consumption  of 
Cryptocurrencies Beyond Bitcoin” available at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7402366/  
141   See for instance https://www.bloomberg.com/professional/blog/why-bitcoins-energy-problem-is-so-hard-to-

fix-quicktake/#:~:text=1.,which%20keeps%20a%20running%20estimate.   

142   See Cambridge Bitcoin Electricity Consumption Index: https://ccaf.io/cbeci/index  
143   Throughout this section, mining will have the meaning of competing for the solution of a computationally 
demanding  and  –  as  a  result  –  energy-intensive,  cryptographic  puzzle,  for  the  purposes  of  transaction 
verification and creation of new units of cryptocurrency. 

52 

 
 
 
                                                 
years, and become a subject of public policy thinking and action. A few elements should be 
noted in order to describe this issue from an EU policy making perspective. 

First, the Cambridge Bitcoin Electricity Consumption Index (CBCEI),144 states that the vast 
majority of electricity consumption for bitcoin takes place outside the EU, especially in the 
USA and Kazakhstan (following the Chinese ban on crypto mining in spring 2021). The CBCEI 
also suggests that ~10% of global bitcoin mining takes place in the EU (mainly in Ireland and 
Germany145). These elements evidence that there is a clear case for international cooperation 
to tackle the issue, in addition to policy measures at EU level.  

Second, China was the leading country in terms of bitcoin-mining-related energy consumption 
before  spring  2021.  However,  its  ban  on  cryptocurrency  mining  in  spring  2021  had  only  a 
temporary impact on the global energy consumption of bitcoin mining, which returned to pre-
ban levels within only a few months. Chinese miners relocated their activities to other countries 
(to  Kazakhstan  in  particular  –  with  a  significant  negative  impact  on  Kazakhstan’s  national 
electricity system146) by physically moving servers and other IT equipment across borders. This 
suggests that the crypto-mining industry can relocate extremely fast and further confirms that, 
in  the same way that  greenhouse emissions are  a global issue, policy makers  would ideally 
need to  take a  global  perspective in  this  domain in  addition  to  potential  policy measures  at 
national/regional level.   

Third, the energy efficiency of the chips and hardware used for Proof of Work mining purposes 
has greatly  improved  in  recent  years. Energy consumption  has  gone from  around 0.1 MH/J 
(million hashes per joule) to around 10 000 MH/J as bitcoin mining shifted from CPU-based 
technologies to Graphic Processing Units (GPU) and finally to Application Specific Integrated 
Circuit (ASIC) technologies. However, these efficiency gains have been more than offset by 
an  increase  in  the  calculation  intensity  needed  to  mine  the  same  amount  of  bitcoin.  This 
suggests that measures focused on energy efficiency are bound to fail due to very significant 
rebound  effects  (particularly  in  the  case  of  very  energy-intensive  Proof  of  Work  consensus 
mechanisms such as the one used for bitcoin147). As demonstrated by the report ‘Blockchain 
Energy Consumption  – an Exploratory Study’148, the ratio between the price of bitcoin  and 
electricity prices is the only limit on the energy consumption of bitcoin mining at economic 
equilibrium and the energy efficiency of the technology in use is irrelevant. This conclusion 
also  seems  to  be  supported  by  the  visible  (but  not  proportional)  decrease  in  electricity 
consumption of the bitcoin network following the recent crypto crash, which led to a nearly 
fourfold drop in the price of bitcoin from a high of 68,789 USD in November 2021 to a low of 
17,593 USD in mid-June. 

144   CBECI - https://ccaf.io/cbeci/mining_map  
145   With a strong caveat  however for both countries  mentioning  that  “there is  little evidence of large mining 
operations in Germany/Ireland that would justify this figure. Germany’s/Ireland’s share is likely significantly 
inflated due to redirected IP addresses via the use of VPN or proxy services” 

146   Analysis of the relocation of bitcoin miners from China to Kazakhstan after the Chinese mining ban suggests 
that  this  move  actually  increased  the  overall  carbon  footprint  of  bitcoin  mining  (because  Kazakhstan  has 
fewer renewable energy sources than China and is therefore more reliant on coal) and had a negative impact 
on  Kazakhstan’s  electricity  system:  https://www.euronews.com/next/2022/02/26/bitcoin-mining-was-
actually-worse-for-the-environment-since-china-banned-it-a-new-study-sa. 

147   Any improvement in the energy consumption per unit of calculation is bound to be offset by a similar increase 
in the absolute number of calculations performed – with the result that overall energy consumption will not 
change (or will continue to increase) in absolute terms. 

148   https://www.aramis.admin.ch/Default?DocumentID=68053&Load=true  

53 

 
 
                                                 
Fourth,  there  has  been  a  growing  uptake  on  the  market  for  various  other,  more  modern 
blockchain technologies (e.g. those using consensus mechanisms such as “Proof-of-Authority”, 
“Proof-of-Stake”,  “Delegated  Proof-of-Stake”  or  “Byzantine  Fault  Tolerance”  instead  of 
“Proof-of-Work”)  that  require  much  less  energy  to  operate  than  Proof-of-Work  .  Such 
technologies are already being used and could be used even more widely in the future as the 
building  blocks  for  more  energy-efficient  cryptocurrencies,  and  for  other  blockchain 
applications  in  energy,  mobility,  supply  chains,  manufacturing  and  capital  markets.  In  the 
energy sector, blockchain technologies could be used to ensure trust and reliability in local P2P 
electricity trading. Blockchain technologies could also support Energy Attribute Certificates 
(EACs) which attest that a given unit of energy is generated from clean energy sources and act 
as a market-based instrument to incentivise clean energy roll-out. Other use cases that could 
contribute  to  sustainability  include  monitoring  assets  through  their  life  cycle  in  a  verifiable 
way, and tracking sustainability efforts along supply chains. For example, the second largest 
blockchain ecosystem, Ethereum, has pledged to switch its consensus mechanism to Proof-of-
Stake, which would allow energy savings in the order of a factor of 1000 (at the time of writing, 
this  switch  had  not  occurred).  The  governance  of  bitcoin  is  much  different  from  and  less 
structured than Ethereum, however, and replicating such a voluntary switch in bitcoin would 
depend on first convincing a majority of worldwide bitcoin miners to ‘hard fork’ the bitcoin 
protocol and switch from Proof-of-Work to Proof-of-Stake (similar to what Ethereum pledged 
to do), which appears extremely unlikely at this stage. 

All things considered, high energy consumption is not a characteristic feature of all blockchain 
technologies. Rather, it is related to the use of the Proof-of-Work consensus mechanism. The 
European Blockchain Observatory and Forum (EUBOF), an academic think tank for sharing 
knowledge  on  blockchain,  has  recently  explored  the  energy  efficiency  of  blockchain 
technologies.  It  concluded149  that  mining  is  not  a  prerequisite  for  blockchain  and  that  it  is 
possible  to  base  blockchain  technologies  on  consensus  mechanisms  that  consume  far  less 
energy than Proof-of-Work because they do not involve a mining process. The EUBOF also 
made a set of recommendations in line with its findings on the energy efficiency, scalability 
and  performance  of  blockchain-based  solutions,  the  use  of  renewable  energy  and  the 
deployment of specific energy efficiency evaluation criteria150. The Commission is reviewing 
EUBOF’s recommendations for additional actionable points. 

The Commission has recently gathered information, set up reflection processes and launched 
initiatives on how to better address this growing policy challenge. The EU’s blockchain pre-
commercial  procurement  has  in  particular  procured  research  and  development  aimed  at 
bringing more energy-friendly blockchain solutions to the market for the European Blockchain 
Services  Infrastructure (EBSI) and for the public sector151.  The EBSI is  an  initiative by the 
European Blockchain Partnership (EBP) to use blockchain to create cross-border services for 
public  administrations  and  their  ecosystems  to  verify  information  and  make  services 
trustworthy152. 

149 

See 

https://www.eublockchainforum.eu/sites/default/files/reports/Energy%20Efficiency%20of%20Blockchain
%20Technologies_1_0.pdf.  

150   See Ibidem, section 6: Policy Recommendations.  
151   https://digital-strategy.ec.europa.eu/en/news/european-blockchain-pre-commercial-procurement  
152  For  more  background  information  on  the  European  Commission’s  policy  with  regard  to  blockchain 

technologies, see: https://digital-strategy.ec.europa.eu/en/policies/blockchain-strategy.   

54 

 
 
                                                 
The next steps to address this topic can be put into three categories. 

  First, since many cryptocurrencies are being mined and/or delivered over the cloud, all 
existing steps to evaluate and address energy consumption from the expansion of cloud 
computing services in the EU (see the previous section on the energy consumption of 
data  centres)  are  relevant  for  curbing  the  energy  consumption  of  crypto  mining.  A 
recent study153 highlighted the relevance of using existing instruments (in particular the 
EU  Code  of  Conduct  on  Energy  Efficiency  in  Data  Centres,  the  revision  of  the 
Ecodesign Regulation on servers and data storage products, and the Energy Efficiency 
Directive) to address this issue. In addition, CO2 emissions from the power production 
system (including electricity production for data centres and IT services in general) are 
regulated  by  the  EU  Emissions  Trading  System  that  is  progressively  reducing  the 
emissions cap. This will have an impact on EU-based cryptocurrency mining. 

  Second, the Council presidency and the European Parliament reached in June 2022 a 
provisional  agreement  on  a  Regulation  of  Markets  in  crypto  assets  (MiCA).  This 
proposal would establish a regulatory framework to help regulate cryptoassets that fall 
outside the scope of current regulation and their service providers in the EU, and would 
provide a single licensing system throughout the EU by 2024. The Commission did not 
propose that the MiCA Regulation address energy consumption concerns about Proof 
of Work, but the European Parliament decided to include several points in this regard 
in  its  mandate  for  negotiations  with  the  Council.  The  MiCA  regulation  will  require 
actors in  the crypto-asset  market  to  disclose information  on their environmental  and 
climate  footprint.  ESMA  will  develop  draft  regulatory  technical  standards  on  the 
content,  methodologies  and  presentation  of  information  regarding  principal  adverse 
environmental  and  climate-related  impacts154.  In  addition,  the  Commission  will 
develop a report including a description on the environmental and climate impact of 
new technologies in the crypto-asset market. The report will also include an assessment 
of potential policy options that could be warranted to mitigate adverse impacts on the 
climate  of  technologies  used  in  the  crypto-asset  market,  in  particular  in  relation  to 
consensus  mechanisms.  This  would  be  a  first  attempt  worldwide  to  decrease  the 
attractiveness of bitcoin investments and curb the price of bitcoin (which, as mentioned 
above, has been evidenced as being the only relevant factor, along with the price of 
electricity,  acting  as  a  limit  to  bitcoin  mining’s  worldwide  energy  consumption  at 
economic equilibrium). 

  Third, as already mentioned, Chapter VI of the Declaration on European Digital Rights 
and  Principles  emphasises  that  ‘Everyone  should  have  access  to  accurate,  easy-to-
understand information on the environmental impact and energy consumption of digital 
to  make  responsible  choices.’155  As 
products  and  services,  allowing 
cryptocurrencies are typically used by their owners as a speculative investment asset or 
as a payment system, this principle should also apply to cryptocurrencies, and could 
subsequently act as a deterrent for members of the public considering investing in less 
environmentally  friendly  cryptocurrencies  and  crypto  assets.  This  transparency 
principle  is  also  reflected  in  the  environmental  disclosure  requirements  in  the  final 
MiCA text. 

them 

153  Study  on  efficient  cloud  computing 

technologies  and  policies:  https://ec.europa.eu/digital-single-

market/en/news/energy-efficient-cloud-computing-technologies-and-policies-eco-friendly-cloud-market.  

154   The final MiCA text was agreed by co-legislators on 30.06.2022. 
155   https://digital-strategy.ec.europa.eu/en/library/declaration-european-digital-rights-and-

principles#Declaration  

55 

 
 
                                                 
  Fourth,  it  appears  necessary  to  develop  technical  tools  to  assess  the  electricity 
consumption and carbon footprint of crypto mining at international level. International 
cooperation with standardisation bodies could provide the technical expertise needed 
to develop energy-efficient labelling for blockchains. International collaboration with 
standardisation bodies would put the EU at the forefront of any future global initiative 
to encourage sustainable blockchain technologies. This incentive should encourage the 
use of the more environmentally friendly consensus mechanisms and applications of 
blockchain  technology,  taking  due  account  of  other  relevant  aspects  such  as 
cybersecurity and financial and social impacts. This would need to be accompanied by 
awareness-raising  measures  in  relevant  settings  (e.g.  the  Social  Impact  and 
Sustainability Working Group of the International Association of Trusted Blockchain 
Applications (INATBA)156). 

156   https://inatba.org/social-impact-working-group/   

56 

 
 
 
 
  
 
 
 
 
 
 
                                                 
7  Annex: Summary of the sample of projects co-funded by Horizon 

2020 programme with cybersecurity components 

 Project reference 

Participation 

of 

Main fields of work 

Main technological solutions 

(CORDIS 

database, 

the  EU  Member 

States 

and 

Horizon 

2020 

affiliated 

projects) 

countries 

PHOENIX 

DE  EL  ES  FR 

IT NL RO SI FI 

+ Norway 

SDNmSENSE  BG EL ES SE + 

Norway 

and 

protocols/type 

of 

cybersecurity measures 

PHOENIX platform and 
EPES threat notification, and 
distribution mechanisms and 
countermeasures 

Security information and 
event management (SIEM) 
system, MISP system 

Focusing on Modbus, DNP3, 
IEC 60870-5-104, IEC 61850, 
GOOS and MQTT protocols 

Monitoring, detection, 
mitigation and recovery from 
threats and attacks related to 
vulnerabilities in existing 
supervisory control and data 
acquisition (SCADA) and 
information and communication 
systems 

ility assessment of industrial 
and IoT protocols on software 
defined networking, AI-based 
detection, mitigation and 
correlation mechanisms, 
community sharing of incidents 

ENERGY 

BG  DE  EL  IE 

SHIELDS 

IT LU RO SE 

Vulnerability assessment at 
systems/process and component 
levels 

1.SIEM system using standard 
formats  (IDMS)  for  incident 
reporting 

+  Iceland  and 

the 

United 

Kingdom   

for 

Tools 

anomaly 
2. 
distributed 
detection, 
mitigation 
security 
and 
behaviour  analysis.  Seamless 
reporting  to  EU  CERT  and 
EPES operators 

ELECTRON 

EL ES RO SE 

Development of frameworks: 

Cooperation with the 

+  Norway  and 

Ukraine 

CYBERSEAS 

IT SI HR FI EE 

European Network 

Information and Security 

Agency (ENISA) 

MIDAS application 

1. risk assessment and cyber 
security certification 
2. intrusion detection and 
correlating mechanisms 
3. prevention and mitigation 
measures 
4. training of staff 
1.  Protecting data and 

detecting breaches in the 
cloud. 

2.  Assigning digital assets to 
an immutable digital twin. 

57 

 
 
 
 
 
58