REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Report on the implementation of Article 5 of the Renewable Energy Directive (EU) 2018/2001
Date: 2023-12-11
Institutions: Directorate-General for Energy, European Commission
Subjects: EU Member State, EU energy policy, application of EU law, electrical energy, energy cooperation, energy production, greenhouse gas, reduction of gas emissions, renewable energy, support policy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 11.12.2023  COM(2023) 778 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Report on the implementation of Article 5 of the Renewable Energy Directive (EU) 2018/2001  
 
 
Report on the implementation of Article 5 of the Renewable Energy Directive 

1.  Introduction 

The revised Renewable Energy Directive1 sets a 2030 EU-level target of 42.5% for the share 
of  energy  from  renewable  sources  in  gross  final  energy  consumption,  with  an  aspiration  to 
reach 45%. Unlike the 2020 target, this EU-level target has not been translated into  binding 
national contributions. The target is to be achieved jointly by all Member States, building on 
their  coordinated  and  combined  action,  as  reflected  in  the  Directive  and  the  Governance 
Regulation2.  

According  to  the  Governance  Regulation,  Member  States  are  to  cooperate  with  each  other, 
taking into account all existing and potential forms of regional cooperation to effectively meet 
the  objectives,  targets  and  contributions  set  out  in  their  National  Energy  and  Climate  Plans 
(NECPs).  However,  the  European  Commission’s  EU-wide  assessment  of  the  2020  NECPs3 
concluded that Member States should make better practical use of regional cooperation.  

The  increased  renewable  energy  ambition  would  require  exploiting  cost-effectively  the 
potential for renewables deployment. This means that cooperation between the Member States 
will  play  a  role  in  achieving  the  target.  At  the  same  time,  cooperation  is  a  tool  to  achieve 
greater  regulatory  alignment  between  the  Member  States.  The  revised  Renewable  Energy 
Directive  aims  to  foster  cooperation  through  the  provisions  on  joint  projects,  statistical 
transfers and joint support schemes. 

Most  of  the  investments  in  renewable  electricity  generation  so  far  have  benefited  from 
national support schemes whose role in achieving the EU target is recognised in Article 4 of 
the  Directive  as  well  as  by  the  EU  State  aid  rules4.  This  support  should  be  granted  in  a 
competitive manner, for example through tenders.  

Article 5 of the Directive allows Member States to open participation in support schemes for 
electricity from renewable sources to producers located in other Member States. This may, in 
each year, amount to at least 5% of the scheme’s budget or the supported capacity from 2023 
to 2026 and at least 10% from 2027 to 2030, or, where lower, to the level of interconnectivity 
of  the  Member  State  concerned  in  any  given  year.  Furthermore,  the  opening  of  support 
schemes may or may not involve physical import of electricity. If a Member State that opens 
its support scheme requires proof of physical import, it may limit participation in the scheme 
to projects in countries with which it has direct interconnection. According to the Directive, if 
a Member State decides to open participation in support schemes, the Member States involved 
must agree on the principles of such participation, covering at least the principles of allocation 
of renewable electricity that is the subject of cross-border support. In order to acquire further 

1 Directive (EU) 2018/2001, as amended by Directive (EU) 2023/2413. 
2 Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the 
Governance of the Energy Union and Climate Action. 
3 Driving forward the green transition and promoting economic recovery through integrated energy and climate 
planning (COM(2020) 564 final). 
4 Guidelines on State aid for climate, environmental protection and energy 2022 (2022/C 80/01). 

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implementation  experience,  Member  States  may  organise  one  or  more  pilot  schemes  where 
support is open to producers located in other Member States.  

Article 5(5) requires the Commission to carry out an evaluation of the implementation of this 
Article.  The  implementation  report  should  assess  the  need  to  introduce  an  obligation  on 
Member  States  to  partially  open  participation  in  their  support  schemes  for  electricity  from 
renewable sources to producers located in other Member States, with a view to a 5% opening 
by 2025 and a 10% opening by 2030.  

For  this  purpose,  this  report  assesses  to  what  extent  the  Member  States  have  implemented 
Article 5 by opening participation in support schemes or by organising pilot schemes since the 
entry  into  force  of  Directive  (EU)  2018/2001.  This  report  presents  examples  such  as  case 
studies, as well as the results of stakeholder consultations on this topic.  

2.  Existing examples of the opening of support schemes and pilot projects  

a.  German-Danish cross-border solar photovoltaic (PV) tender 

In 2016, on the basis of a bilateral cooperation agreement, Germany and Denmark conducted 
two pilot cross-border auctions for solar PV, one carried out by Germany and the other one by 
Denmark. In the German auction of 50 MW, installations located in Denmark were allowed to 
bid  for  support  payments,  while  in  the  Danish  auction  of  20 MW,  2.4 MW  were  open  to 
installations  located  in  Germany.  The  auctions  differed  in  several  design  features.  For 
example,  the  German  auction  awarded  sliding  market  premiums  while  the  one  in  Denmark 
used fixed premiums. The permitted bid size in Germany ranged from 0.1 to 10 MW while it 
was capped at 2.4 MW in Denmark. Germany imposed a maximum bid price, in contrast to 
Denmark, which did not impose a ceiling price.  

The German auction received 43 bids totalling 297 MW, of which 143 MW were for projects 
located in Germany (26 bids), while 154 MW were for projects located in Denmark (17 bids). 
The  5  winning  bids  were  all  for  projects  located  in  Denmark,  with  the  maximum  eligible 
capacity of 10 MW. The Danish  auction received 36 bids  totalling  79.45 MW, with  no bids 
submitted for installations located in Germany. The 9 winning bids were all for projects with 
the  maximum  eligible  capacity  of  2.4 MW.  As  a  result,  the  full  capacity  of  the  joint  tender 
was allocated to projects located in Denmark.  

b.  Planned agreement on wind farms between Ireland and the UK 

In  2014,  Ireland  and  the  UK  worked  on  an  intergovernmental  agreement  aiming  to  set  up 
wind  farms  totalling  around  5  GW  in  the  Irish  Midlands  with  the  help  of  UK  government 
subsidies and export the electricity produced to the UK. This would offer Ireland an electricity 
export  market  and  other  economic  benefits  and  help  the  UK  to  meet  its  renewable  energy 
targets at  a lower cost  than  by  deploying  other  renewables. According to one of the project 
developers,  UK  consumers  were  expected  to  save  around  £7bn  over  15  years  from  this 
arrangement5.  The  agreement  was  ultimately  abandoned,  due  to  concerns  of  local 

5 https://www.bbc.com/news/science-environment-21147279 

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communities about the size of the proposed wind farms, the height of the individual turbines 
and the impact on the environment and property values.  Furthermore, the expected benefits 
for Ireland, were perceived as too small to outweigh the environmental impacts of having the 
wind farms installed in their country6. 

3.  Input from stakeholders  

Member States were consulted in the framework of the Concerted Action on the Renewable 
Energy  Directive  (CA-RES)7  and  through  bilateral  requests.  A  total  of  10  Member  States 
replied  to  the  questionnaire  sent  out  in  the  framework  of  CA-RES.  Of  these,  6  (Cyprus, 
Finland, Slovenia, Slovakia, Denmark and Poland) replied that they were not planning to open 
participation in support schemes. Sweden referred to its existing electricity certificate system 
with  Norway.  Greece  replied  that,  according  to  a  recent  Ministerial  Decision,  3  common 
auctions for wind and solar PV are planned in 2023, which will be open to producers located 
in  other  Member  States.  For  these  auctions,  the  capacity  share  for  producers  from  other 
Member States has not been specified. Another auction planned in 2023 is dedicated only to 
producers located in other Member States.  

So  far,  the  Member  States  that  replied  have  not  signed  any  cooperation  agreements  with  a 
view  to  opening  participation  in  support  schemes.  With  the  exception  of  Denmark,  none  of 
the  Member  States  that  replied  have  organised  pilot  schemes  where  support  is  open  to 
producers located in other Member States8.  

The  Member  States  were  asked  what  they  consider  to  be  the  main  obstacle  for  opening 
participation in support schemes. A number of factors were mentioned in response: differing 
national  support  schemes  and  the  risk  that  the  difference  brings  unfair  competition; 
differences  in  administrative  processes;  concerns  linked  to  security  of  supply;  challenges 
linked  to  communication  and  joint  understanding  with  other  Member  States;  and  a  lack  of 
electricity interconnectivity with other Member States.  

On  measures  the  Commission  could  take  to  incentivise  or  help  Member  States  in  opening 
support  schemes  to  producers  located  in  another  Member  State,  the  replies  mentioned  the 
standardisation of procedures, including a ready-made framework for agreements.  

In  addition  to  the  consultation  in  the  framework  of  CA-RES,  the  Commission  launched  an 
online  call  for  evidence  on  the  option  for  Member  States  to  partially  open  participation  in 
their  support  schemes  for  electricity  from  renewable  sources  to  producers  located  in  other 
Member States, including the possibility for the Commission to propose  mandatory opening 
of support schemes. 

6 Cross-border cooperation on renewable energy, p. 5, https://www.eea.europa.eu/publications/cross-border-
cooperation-on-renewable-energy.  
7 CA-RES is a project of the Horizon 2020 programme. It supports the transposition and implementation of the 
Directive. Through CA-RES, participating countries exchange experiences and best practice. 
8 In its reply, Denmark referred to the 2016 pilot cross-border solar PV tender with Germany, which is described 
in Section 2.a of this report. 

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The Commission received 18 contributions to the call for evidence. It also received 2 replies 
by email after the deadline. Most respondents expressed opposition to mandatory opening of 
support schemes. All replies from individuals to the call for evidence expressed opposition to 
mandatory opening, mainly stressing concerns about Member States’ sovereignty.  

The Commission received 3 replies to the call for evidence from Member States. Another one 
came  following  a  complementary  bilateral  request  from  the  Commission  to  the  Member 
States.  Of  the  replies  to  the  call  for  evidence,  2  came  from  the  Member  States  that  have 
already  carried  out  a  pilot  for  cross-border  auctions  –  Denmark  and  Germany9.  In  its  reply, 
Denmark  highlights  the  need  for  Member  States  to  be  flexible  when  deciding  on  the 
appropriate  tools  to  support  renewable  energy,  including  by  means  of  national  support 
schemes  and  opening  these  schemes  to  producers  in  other  Member  States.  Denmark  also 
recalls that in the future, onshore renewable energy is largely expected to be installed without 
using support schemes. 

The reply from Germany describes the design features of the pilot cross-border auctions with 
Denmark,  the  lessons  learned  from  them  in  terms  of  efficiency  gains  that  can  result  from 
cooperation  and  the  importance  of  regulatory  conditions  in  cross-border  auctions,  and  the 
applicable  regulation  in  Germany  on  renewable  energy  support  schemes.  According  to  the 
national rules, from 2017 onwards, when support for renewable energy has to be determined 
by auctions, a share of the total capacity to be added annually  is to be opened to renewable 
energy  projects  in  other  Member  States  under  certain  conditions10.  The  rules  were 
subsequently amended in 2017, 2021 and 2023, increasing the share of capacity that has to be 
open  to  projects  in  other  Member  States,  making  additional  technologies  eligible  for 
participation  in  cross-border  auctions,  introducing  changes  to  the  calculation  of  market 
premiums,  and  suspending  the  requirement  for  reciprocity.  Under  current  rules,  20%  of  the 
total  capacity  to  be  added  annually  needs  to  be  open  to  renewable  energy  projects  in  other 
Member States, while offshore wind capacity does not count towards the set limit of 20% and 
the full capacity can be open to projects in other Member States. In its contribution, Germany 
recognises that a mandatory obligation to open support schemes would boost cooperation on 
renewables  among  Member  States.  However,  it  also  recalls  the  strengthened  provisions  on 
joint  projects  of  Article  9  of  the  recently  revised  Renewable  Energy  Directive.  Germany 
considers the Commission’s support for cooperation to be helpful to increase support scheme 
efficiency in the EU.  

Most  industry  replies  argue  that  a  mandatory  opening  of  schemes  does  not  address  the 
underlying  needs  of  the  governments  involved,  that  this  could  reduce  the  legitimacy  of  and 
public  support  for  the  schemes  and  the  energy  transition  as  a  whole,  and  that  introducing  a 
binding  obligation  may  not  be  the  most  appropriate  way  to  help  achieve  the  2030  EU 
renewable  energy  target  since  it  may  involve  changing  the  requirements  that  the  supported 
facilities  must  comply  with  in  order  to  receive  support,  or  changing  the  financing  scheme 
itself, thus creating an administrative burden. For example, respondents point out that under 

9 The third reply from a Member State (Lithuania) refers to the applicable regulatory framework for joint support 
schemes and participation in auctions in another Member State, without taking a position in favour or against 
mandatory opening of support schemes. 
10 1) An international treaty on a cooperation mechanism under the Renewable Energy Directive is  
in place between Germany and the partner country;  2)  the cooperation is reciprocal, which means both parties 
open  their  auctions  in  their  respective  markets  for  the  partner  country  in  comparable  volumes;  and  3)  the 
electricity generated must be physically imported or have a comparable effect on the German electricity market. 

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the  Spanish  support  scheme  REER  (Régimen  Económico  de  Energías  Renovables),  power 
generation facilities must be located on the Spanish mainland and meet certain administrative 
milestones.  The  location  requirement  would  need  to  be  changed  to  enable  the  opening  of 
support  schemes,  as  well  as  the  requirement  to  meet  certain  administrative  milestones  for 
installations  located  in  other  Member  States,  since  these  installations  would  be  subject  to 
different permitting and administrative processes than those applicable in Spain. Furthermore, 
if the tender takes the form of a contract for difference, different rules on how to spread the 
financial  burden  of  the  support  payments  between  market  participants  in  the  countries 
involved may result in unequal treatment between Member States.   

By contrast, one industry association favourable to a mandatory opening argued for a unitary 
EU  scheme  or  harmonised  support  measures,  to  support  cost-effective  deployment  of 
renewable  energy  and  electricity  market  integration  and  functioning.  Another  industry 
association  respondent  cautioned  that,  if  the  opening  of  support  schemes  were  to  be  made 
mandatory, national funding would be provided directly or indirectly by the population of the 
respective  Member  State,  and  therefore  such  funding  should  contribute  in  particular  to 
reaching  that  Member  State’s  energy  and  climate  targets.  Another  industry  association 
expressed  support  for  mandatory  opening,  in  order  to  export  the  energy  produced  to  the 
Member  State  organising  the  auction.  Additionally,  the  respondent  called  for  the  option  to 
transport  the  cross-border  supported  renewable  electricity  as  gaseous  molecules,  namely 
hydrogen. The respondent argues that this could help overcome the issue of there not always 
being  sufficient  electricity  grid  capacity  and  create  the  possibility  of  seasonal  storage  of 
renewable energy.  

Even  though  most  respondents  had  a  preference  for  not  making  the  opening  of  support 
schemes binding, there was wide recognition of the benefits of cooperation in the deployment 
of  renewable  energy.  The  offshore  wind  sector  in  particular  was  singled  out  as  one  where 
systematic  coordination  and  cooperation  of  countries  around  a  sea  basin  is  of  critical 
importance.  

Several industry respondents were in favour of incentivising the opening of support schemes, 
since it would create competition among a larger pool of bidders, encourage Member States to 
harmonise their administrative procedures, and provide for more European approaches where, 
for  example,  one  Member  State  has  limited  space  to  deploy  additional  renewable  energy  in 
contrast  to  significant  national  demand,  while  another  Member  State’s  resource  potential  is 
larger  than  domestic  demand.  However,  the  solar  industry  stressed  that  for  cross-border 
tenders to be successful, the administrative burden must remain limited, and the visibility of 
support mechanisms and national policies on both sides must be guaranteed.  

Respondents  from  both  the  solar  and  the  wind  industry  stressed  the  importance  of  several 
points  related  to  grid  infrastructure.  They  highlighted  the  need  to  increase  the  level  of 
electricity interconnection,  referring to  physical  grid connections as one  of  the prerequisites 
for  opening  support  schemes.  A  respondent  from  the  wind  industry  stressed  that  grid 
connection  costs  also  need  to  be  part  of  the  cost-benefit  allocation.  A  respondent  from  the 
solar  industry  argued  that  a  level  playing  field  between  the  countries  concerned  should  be 
ensured  by  harmonising  the  regulatory  frameworks  or  applying  cost-sharing  measures.  For 
example,  if  grid  connection  costs  differ,  in  the  bid  selection  process,  a  premium  could  be 
added to bids in the market with more favourable conditions. 

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Replies  from  several  respondents  also  converged  in  terms  of  their  views  on  the  broader 
sharing of costs and benefits. The wind industry stressed that the cross-border scheme should 
help Member States to overcome differences in their assessment of costs and benefits, that the 
electricity produced should improve the security of supply of the country opening its support 
scheme, and that this country should also benefit from the decline in electricity prices due to 
the  additional  installed  renewable  energy  capacity.  The  solar  industry  highlighted  ways  in 
which the support mechanism could  be designed  so that the host country  could  also  benefit 
from  the  installation,  such  as  by  involving  the  local  population,  local  developers  and 
potentially  local  ownership  of  the  installation.  The  solar  industry  further  stressed  the 
importance of clear and  transparent  accounting for the electricity produced and exported,  in 
order to avoid double-counting. 

One respondent from the renewable energy industry in Denmark stated that renewable energy 
projects, both onshore and offshore, have been built without using support schemes, and that 
using subsidies would undermine the success and benefits of the renewable energy industry. 
On the other hand, the industry representative pointed to the need for subsidies for wind and 
solar manufacturing as a means to strengthen European value chains.  

4.  Assessment  

On the basis of the evidence gathered in the preparation of this report, it is clear that there are 
very  few  specific  developments  in  the  Member  States  concerning  the  opening  of  support 
schemes, both in terms of legislative requirements and in terms of implementation experience 
through pilot schemes.  

Germany is one of few Member States that has made the opening of support schemes part of 
its energy legislation. However, it points to the lack of interest in cross-border auctions from 
other Member States, which makes this cooperation mechanism difficult to implement. Most 
other  Member  States  do  not  intend  to  open  participation  in  support  schemes,  with  the 
exception of Greece,  which is  planning to  organise several  wind and solar auctions in  2023 
open  to  producers  located  in  other  Member  States,  with  one  of  them  dedicated  only  to 
producers located in neighbouring countries. In some Member States, the opening of support 
schemes would not be feasible without changes to the current regulatory framework, such as 
in Spain, where installations financed by support schemes must be located in Spanish territory 
and meet certain administrative milestones. In such cases, potential regulatory changes would 
need to create more flexibility regarding the location of the installation, and to the extent that 
specific elements remain in the national administrative procedures for renewables that are not 
harmonised  by  EU  rules,  to  allow  for  the  identification  of  comparable  administrative 
milestones  in  another  country’s  regulatory  framework,  while  taking  into  account  national 
specificities. 

In  terms  of  implementation  experience  through  pilot  projects,  the  German-Danish  pilot 
example  has  demonstrated  that  cross-border  auctions  enable  projects  with  more  favourable 
conditions, such as those related to resource potential, to compete at a lower cost to the public 
budget of the country financing the support scheme. In this pilot, the five winning bids in the 
German  auction  for  projects  to  be  built  in  Denmark  required  a  sliding  premium  of 
EUR 5.38 cent/kWh,  which  was  below  the  average  price  in  previous  German  national 
auctions at that time (EUR 7.25 cent/kWh), meaning a decrease of almost 26%. Nevertheless, 
as  the  input  from  several  stakeholders  to  this  report  indicates,  in  addition  to  the  benefit  of 

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deploying  renewable  energy  cost-effectively,  cross-border  support  schemes  should  also 
ensure  a  balanced  distribution  of  the  wider  costs  between  participating  countries  in  such  a 
way that this enables the renewable energy projects to be built. 

The experience of the German-Danish pilot scheme also highlights the importance of taking 
into  account  the  differences  in  regulatory  conditions  between  participating  countries.  The 
result  of  the  German  auction  where  all  winning  bids  were  located  on  farmland  in  Denmark 
could  be attributed  not  only  to  the better resource potential in  Denmark, but  also  to  the site 
restrictions in Germany, which forbid the installation of solar PV projects on agricultural land, 
as well as slightly lower taxes and lower land lease costs in Denmark11.  

Denmark  also  imposed  the  same  site  restrictions  in  the  Danish  tender,  but  only  for 
installations  in  German  territory,  which  some  stakeholders  perceived  as  a  disadvantage  for 
German  installations  in  the  cross-border  tender12.  Furthermore,  the  anticipation  of  future 
auctions in Germany may have discouraged German bidders from participating in the cross-
border auction. The discontinuation of the support mechanism for large-scale solar PV plants 
in Denmark before the cross-border auction and the lack of upcoming auctions may also have 
encouraged  active  participation  from  Danish  bidders.  The  interaction  between  national  and 
cross-border  measures  highlights  the  importance  of:  (i)  the  timing  of  national  and  cross-
border  measures;  and  (ii)  interaction  between  participating  countries  as  regards  the 
institutional, legal and financial set-up. 

Most  respondents  to  the  Commission’s  stakeholder  consultation  to  prepare  this  report 
expressed opposition to the mandatory opening of support schemes. The reasons range from 
national  sovereignty to  increased administrative burden and the difficulty  of distributing the 
costs and benefits in a way that would be perceived as fair by the parties involved. Bilateral 
exchanges  with  Member  States  also  revealed  issues  related  to  public  acceptance  of  the 
national  budget  being  used  to  finance  renewable  energy  development  in  another  Member 
State. An additional argument mentioned was that support for capital expenditure investment 
requires  immediate  disbursement  by  the  contributing  Member  State,  with  budgetary 
implications,  while  potential  gains  from  cooperation  would  only  materialise  in  the  future. 
However, since most current  renewable  energy support  schemes do not  involve any upfront 
capital  expenditure  payments  but  rather  ongoing  payments  for  electricity  output  spread  out 
over time, in most cases this concern would not arise. 

Furthermore,  consideration  of  imposing  mandatory  opening  of  support  schemes  should  also 
take  into  account  the  provisions  recently  introduced  into  the  Renewable  Energy  Directive. 
These provisions require each Member State to agree to establish a framework for cooperation 
on  joint  projects  with  one  or  more  other  Member  States  for  the  production  of  renewable 
energy,  by  the  end  of  2025.  This  was  introduced  as  a  binding  provision  in  response  to 
insufficient cooperation between Member States on renewable energy, so gaining experience 
in implementing this provision could help better understand whether further binding measures 
are  needed  to  strengthen  cooperation  and  thus  achieve  a  more  efficient  deployment  of 
renewable energy. 

11 https://static.agora-energiewende.de/fileadmin/Projekte/2017/RES-Policy/144_cross-
border_RES_cooperation_WEB.pdf  
12 https://www.eea.europa.eu/publications/cross-border-cooperation-on-renewable-energy  

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Nevertheless, there is widespread recognition of the benefits of cooperation and of the need to 
further incentivise it. With the growth in renewable energy deployment, suitable sites for new 
installations may become scarce in some Member States but not in others, in particular when 
looking at the differences between Member States in terms of electricity demand, renewable 
energy resource potential and sites available for new installations.  

There seems to be further potential in the implementation of cross-border support schemes for 
offshore renewable energy projects, which often offer large generation volumes exceeding the 
needs  of  one  country  while  requiring  significant  investment.  Such  projects  could  be  a 
particularly  attractive  option for landlocked countries with  limited local  availability for new 
renewable projects to access the renewable energy potential of offshore wind technologies. As 
explained  above,  such  an  approach  may  be  supplemented  by  a  requirement  for  a  physical 
electricity  exchange,  although  this  may  not  be  necessary  and  is  subject  to  the  needs  of  the 
Member  States  involved.  Further,  cross-border  support  schemes  may  also  be  particularly 
relevant in the context of some of the hybrid13 interconnector projects that are being designed 
and  agreed,  where  a  physical  interconnection  is  guaranteed  by  the  offshore  hybrid  projects 
and cross-border support schemes may facilitate cross-border offshore wind projects. 

5.  Conclusion  

This report describes the experience gained so far in implementing Article 5 of the Renewable 
Energy Directive, together with the feedback from Member States and various stakeholders as 
regards the lessons learned and the future outlook. 

The evidence clearly shows that, if organised well, cooperation between Member States in the 
area of renewable energy has significant potential in terms of cost-effectiveness, convergence 
of regulatory frameworks, and making better use of the available renewable resources. In the 
case of cross-border support schemes the potential can only be achieved  if the set-up of the 
scheme takes into account the impact of various design features on the outcome and the costs 
and  benefits  for  the  participating  countries  both  locally  and  from  a  market  integration 
perspective. Furthermore, the impact of regulatory differences on the outcome of cross-border 
support  schemes  seems  to  suggest  further  scope  for  the  Member  States  to  improve  their 
national frameworks for renewable energy deployment.  

There seems to be no single solution to the opening of support schemes that can be applied 
across  all  countries,  given  the  need  to  tailor  schemes  to  the  specific  circumstances  of  the 
partnering countries. However, the Commission can, upon the request of the relevant Member 
States,  facilitate  this  process  by  providing  guidance,  templates  for  cooperation  agreements, 
technical expertise, and assistance on the direct and indirect costs and benefits of cooperation. 
In  the  offshore  context,  which  has  particular  potential  for  setting  up  future  cross-border 
support schemes, the Commission is already regularly discussing with Member States in fora 
such as the North Seas Energy Cooperation, covering areas such as offshore infrastructure and 
renewable energy cost sharing, among other things. In this regard, the Commission will adopt 
guidance  on  offshore  cost  sharing  by  mid-2024.  The  Commission  will  also  share  data  with 
and offer advice to  the  Member States to  help  identify opportunities for offshore renewable 

13 Hybrid meaning combining offshore wind production and electricity interconnection. 

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energy,  including  by  technology  type,  following  the  Commission’s  assessment  of  the  final 
updated NECPs. 

The revised Renewable Energy Directive includes a mandatory requirement on establishing a 
framework for cooperation on joint projects, so the Directive already  addresses the need for 
stronger  cooperation  between  Member  States  in  the  area  of  renewables.  There  is  no 
conclusive  evidence  about  the  benefits  of  introducing  an  obligation  on  Member  States  to 
partially open participation in their support schemes for electricity from renewable sources to 
producers located in other Member States. Therefore, the most appropriate way forward could 
be to monitor the implementation of the newly agreed provisions with regard to cooperation 
and  their  impact  on  target  achievement,  while  retaining  the  possibility  of  proposing  further 
obligations later on, as a measure to strengthen progress towards achieving the 2030 target for 
renewables if progress is deemed insufficient. 

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