REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT reviewing the application of Regulation (EU) 2019/941
Date: 2025-09-29
Institutions: Directorate-General for Energy, European Commission
Subjects: EU Member State, electrical energy, electricity supply, energy cooperation, energy crisis, energy grid, energy supply, intra-EU trade, risk management, security of supply

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.9.2025  COM(2025) 539 final  REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT reviewing the application of Regulation (EU) 2019/941   
 
 
1.  Introduction 

The Risk Preparedness Regulation (EU) 2019/941 (hereafter, ‘the Regulation’), was adopted 
in 2019 as part of the Clean Energy Package with the aim of ensuring that all Member States 
are  equipped  with  appropriate  tools  to  prevent,  prepare  for,  and  manage  electricity  crisis 
situations  in  a  spirit  of  solidarity  and  transparency,  while  respecting  the  requirements  of  a 
competitive internal market for electricity. The Regulation was adopted in the context of the 
ongoing  profound  transformation  of  the  EU  electricity  markets,  characterized  by  more 
decentralized markets with more players, a higher proportion of renewable energy and better 
interconnected  electricity  markets,  which  calls  for  more  coordinated  security  of  supply 
measures. 

The Regulation aimed at addressing these challenges through a variety of measures, namely: 
(1) identification of regional and national electricity crisis scenarios, (2) assessment of risks 
related to the ownership of infrastructure relevant to electricity security of supply (SoS), (3) 
seasonal and short-term adequacy assessments, (4) risk preparedness plans, (5) regional and 
bilateral measures to cooperate in the prevention or management of a crisis, (6) exercises. The 
present report assesses the application of such measures based on the experience gained in its 
implementation1 and pursuant to Article 18(4) of the Regulation, which requires the preparation 
of this report by 1 September 2025.  

In parallel, the Commission is preparing a fitness check assessing the consistency and synergies 
between  the  Regulation  and  the  Gas  Security  of  Supply  Regulation  (EU)  2017/1938.  This 
report, the fitness  check  report,  as well as an upcoming impact  assessment will prepare the 
ground  for  a  revision  of  the  EU  energy  security  framework  that  was  announced  in  the 
Affordable Action Plan2 and in the European Preparedness Union Strategy3.  The revision will 
also enhance security of electricity supply at Union level, with a particular attention to system 
integration and to emerging risks (e.g., climate change impacts, hybrid threats, etc.). 

2.  Analysis of the application of the provisions contained in the Regulation  

2.1 Identification of regional and national electricity crisis scenarios 

The European Network of Transmission System Operators for Electricity (ENTSO-E) has to 
identify every four years the most relevant regional4 electricity crisis scenarios in relation to 
system  adequacy,  system  security  and  fuel  security,  in  close  cooperation  with  several 
stakeholders5 (Article 6). The identification follows a methodology that ENTSO-E develops 
and the Agency for the Cooperation of Energy Regulators (ACER) approves6 (Article 5). The 
regional scenarios are the basis for Member States to subsequently identify national electricity 

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This  report  has  been  prepared  before  the  conclusions  of  the  Expert  Panel  set  up  by  ENTSO-E  to 
investigate  the  blackout  in  the  power  systems  of  Spain  and  Portugal  on  28 April  2025 are  available. 
Consequently, such conclusions are not reflected in this report. 
COM(2025) 79 final.  
JOIN(2025) 130 final 
Under the Risk Preparedness Regulation, a region’ means a group of Member States whose transmission 
system operators share the same regional coordination centre. 
The Electricity Coordination Group (an Expert Group composed of Member States, ACER and ENTSO-
E), regional coordination centres (RCCs) and public authorities in Member States. 
ACER Decision of 6 March 2020 

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crisis  scenarios  (Article  7).  Both  types  of  scenarios  are  the  basis  for  the  design  of  sound 
preventive and mitigating measures. 

The first regional crisis scenario assessment was performed in September 2020 by ENTSO-E. 
In  their  Risk  Preparedness  Plans  (hereafter,  ‘the  Plans’)  which  they  submitted  to  the 
Commission in 2022, Member States kept only the regional scenarios significant for them and 
added specific ones where relevant (e.g., Dunkelflaute scenario for the Netherlands) . Based on 
the experience of the first identification of scenarios, the first set of plans and the Electricity 
Coordination Group’s recommendation7, ENTSO-E in close cooperation with ACER and the 
Commission, revised the methodology. This revised methodology8 was approved by ACER in 
2024 and used for the second identification of regional electricity crisis scenarios which was 
concluded  in  September  2024.  The  improvements  to  the  methodology  include  enhanced 
regional scenarios  description,  mandatory simulations of an increasing  number of scenarios 
with  an  increased  level  of  severity,  a  new  top-down  approach  to  ensure  a  broad  regional 
dimension from the early stages  of the identification process, and  a continuous engagement 
with stakeholders. 

This  has been the first time that a set of  concrete  regional  scenarios  has  been identified  on 
which  to  build  the  work  on  measures  and  thus  provide  a  degree  of  consistency  across 
Member States. This is a significant milestone that has brought together Transmission System 
Operators (TSOs) and national authorities to consider risk scenarios beyond national borders 
given the regional dimension of some risks (e.g. severe summers, which include heatwaves, 
forest fires, droughts) and the increased level of interconnection of the electricity system. 

However, despite the already achieved improvements, there are some persisting weaknesses. 
First  of  all,  the  description  of  the  risk  scenarios  in  most  national  plans  was  rather 
superficial and insufficient to understand what their concrete impacts were. This was the case 
for  scenarios  concerning  malicious  attacks  as  well  as  extreme  weather  events  and  climate 
adaptation. For example, and in particular for cybersecurity related scenarios, the Commission 
requested more details on cybersecurity requirements, incident procedures and relevant actors. 
Second, there was no concrete information to quantify the potential spill-over effects of a 
gas  crisis  on  the  electricity  sector  so  as  to  determine  the  need  for  potential  (regional) 
preventive measures, even in  the light  of the dramatic changes resulting from the full-scale 
invasion of Ukraine by Russia. In fact, some Member States had to run ad hoc scenarios or 
carry out stress tests to understand the extent of the impacts of such an event. To remedy this 
situation,  the  Commission  asked  Member  States  to  deepen  the  analysis  of  the  scenarios  to 
include geopolitical risks, dependence on imported fuels and on other supply chains from third 
countries  and  spillover  effects  from  other  sectors  into  electricity9,  10.    Third,  ENTSO-E 
estimated ahead of winter 2022-2023 the critical gas volumes necessary for the operation of 
the  electricity  sector  during  winter  to  support  decision-making  by  governments.  In  spite  of 
these ad hoc solutions, this has evidenced a fundamental shortcoming in a core element of the 

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Recommendation issued by the Electricity Coordination Group pursuant to Article 6(2) of the Regulation 
ACER Decision no 02/2024 of 8 March 2024 
For example, the increase in electricity demand for heating purposes in the absence of other fuels. 
The Commission requests were part of non-binding Commission opinions delivered pursuant to Article 
13(2) of the Regulation. 

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electricity risk preparedness logic that calls for more concrete and operational provisions, and 
further reflections on the impact of the dependence on imported fossil fuels.  

 Other issues concern the limited consideration of preventive and mitigation actions within 
the scenario simulations, which can lead to outcomes more severe than what can reasonably be 
expected in practice. Consequently, regional scenarios may result in more dramatic results than 
national  ones.  Also,  the  link  to  the  the  ENTSOG’s  natural  gas  supply  and  infrastructure 
disruption  scenarios  is  weak,  which  leads  to  the  overall  conclusion  that  the  cross-sector 
consistency and coordination is limited, in spite of the provisions in the Regulation.  

On climate change adaptation, a common issue was the lack of climate vulnerability and risk 
considerations in the scenarios that could help design preventive measures to reduce exposure 
to  climate-related  risks.  With  few  exceptions,  a  clear  indication  of  how  future  grid 
developments  will  help  to  cope  with  the  consequences  of  these  risks  was  missing  from  the 
plans  (see  also  section  2.4).    Lastly,  a  balance  needs  to  be  found  on  how  the  national 
dimension is incorporated into the simulations to complement the regional analysis. Where 
the national dimension is limited, the impacts of some types of risks can be underestimated 
(e.g. wild fires), but where it is too prominent, there is a risk of too fragmented and nationally-
focused assessments, which the involvement of Regional Coordination Centres (RCCs) has not 
solved. 

2.2 Risks related to the ownership of infrastructure relevant to electricity SoS  

Within four months of the identification of regional crisis scenarios, Member States have to 
identify and notify11 the Commission and the Electricity Coordination Group (ECG) any risks 
related to the ownership of infrastructure relevant to security of electricity supply (Article 7(4) 
and recital (17)). If relevant, Member States also have to indicate any relevant preventive or 
mitigating measure.  

Member States notified their first assessments of such risks in January 2021. These assessments 
largely focused on transmission infrastructure, which in many cases is either state-owned or 
owned by entities where the state holds a majority stake. Few Member States have identified 
potential ownership risks and these were deemed unlikely. Furthermore, most Member States 
have preventive and preparedness measures in place, such as screening mechanisms for foreign 
direct investments or specific procedures regulating ownership transfers. The assessment was 
carried out again in January 2025 with similar results. 

This  provision  has  resulted  in  a  dedicated  assessment  of  ownership  risks  for  the  first  time. 
Nevertheless, the focus has almost exclusively been on transmission and distribution grids. 
Other relevant assets, such as generation assets, were usually not considered (with a few 
exceptions) even when state-owned enterprises from third countries have shares in generation 
assets. This also means that cross-sectoral risks, e.g. those related to the ownership of relevant 
infrastructure in  the gas  sector,  were not  considered. This  is  an  area where improvement  is 
needed. 

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Most Member States (24) and Northern Ireland notified between Q4 2020 and Q1 2021. Malta and Latvia 
made their notification to the ECG in June 2021, following an EU Pilot. Greece made its notification to 
the ECG in June 2022, following a letter of formal notice. 

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2.3 Seasonal and short-term adequacy assessments:  

ENTSO-E has to carry out seasonal adequacy assessments at Union level ahead of every winter 
and summer and to publish them by 1 December and 1 June respectively. While this obligation 
is not new12, these assessments have to be carried out according to a new common methodology 
(Article 8). Such methodology has to be used for all short-term adequacy assessments, whether 
they are carried out at national, regional or Union level.  

The methodology for short-term and seasonal adequacy assessments was approved by ACER 
in March 2020, upon a proposal by ENTSO-E, and has been used since by ENTSO-E for the 
preparation of the ‘Winter Outlook’ and ‘Summer Outlook’. These assessments have become 
a very relevant tool in the preparation of every season and especially in situations where risks 
affected  several  Member  States  simultaneously,  e.g.  unavailability  of  generation  in 
traditionally exporting countries. Moreover, since the full-scale invasion of Ukraine by Russia, 
the adoption of the Winter outlooks has been advanced to November with prior discussions on 
observed trends and preliminary insights at the ECG also in October, to allow more time to 
adopt preventive measures ahead of winter.  

However, there is still room for improvement, for example on the consideration of spillover 
effects from other sectors. The calculation of critical gas volumes (see section 2.1.) was useful, 
and has remained in subsequent Winter Outlooks, but it reveals a need for further integration 
between  gas  and  electricity,  in  a  context  of  increasing  share  of  renewable  electricity 
generation and gradual phase-out of fossil gas, and possibly other sectors in the future (e.g., 
hydrogen). Some Member States have further asked for the consideration of ENTSOG’s winter 
assessment  results  in  the  winter  outlook  for  electricity,  as  well  as  more  integration  and 
cooperation between the two ENTSOs. 

Regarding the short-term adequacy assessment, all RCCs have already implemented it and have 
a Short-term Pan-European adequacy tool. The short-term adequacy assessment is important 
for  situational  awareness  and  to  solve  potential  constraints  in  the  week-ahead  period  (next 
seven days), thus  being  significant  indicator of  whether the electricity crisis  is  imminent  in 
Member States when considering adequacy (i.e. whether the country can satisfy their country’s 
demand with their generation and exchanges). However, this approach does not include power 
flows  and  security  analysis  of  the  system,  such  as  identifying  weak  links  which  can  get 
overloaded and cause out of control cascading events (N-k). The security analysis can provide 
additional dimension in the security of electricity supply. Therefore,  some Member States have 
pointed  to  the  need  to  include  therein  transmission  infrastructure,  currently  missing  in  the 
assessments,  as  in  the  case  of  a  looming  crisis  it  could  provide  an  overview  of  potential 
congested zones that impede energy to flow to where it is needed. 

2.4 Risk preparedness plans  

Based on the regional and national electricity crisis scenarios, Member States have to adopt 
and  update  every  four  years  national  Risk-Preparedness  Plans  (the  ‘plans’),  after  having 

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Article 106(1 and 2) of Regulation (EU) 2017/1485, tasks TSOs to contribute to the pan European winter 
and  summer  outlooks  analysis  by  control  area  adequacy  analysis,  whereas  the  Article  8(3)(f)  of 
Regulation (EC) No 714/2009 (repealed) includes among ENTSO-E tasks ‘annual summer and winter 
generation adequacy outlooks ‘. 

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consulted relevant stakeholders and national bodies. Before their adoption, Member States have 
to consult relevant Member States in their region, other relevant directly connected Member 
States and the ECG on draft versions of their plans to ensure consistency (Article 10). Articles 
11 and 12 describe the mandatory content of the Plans and a template is also provided in the 
Annex13.  

National competent authorities adopted their Plans and notified them to the Commission during 
202214,  after  the  mandatory  consultations  took  place.  The  Commission  assessed  the  plans. 
While many were quite comprehensive in the description of the national framework, it issued 
opinions15 pointing to the lack of compliance with the provisions from the Regulation and 
requested  amendments.  In  its  request  for  amendments,  given  the  circumstances  following 
Russia’s full-scale invasion of Ukraine, the Commission asked Member States, as a matter of 
priority, to: i) update the plans with a pragmatic focus on the impact of a shortage of imported 
fossil fuels (from Russia), e.g. fuel-switching, increase in electricity demand in case of shortage 
of other fuels for heating, ii) run a test of the plan ahead of the winter; iii) develop the solidarity 
provisions (see section 2.7) and iv) deepen the assessment of the crisis scenarios (see section 
2.2).  

Other common requests from the Commission are related to: 

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the limited description of the national electricity crisis scenarios (see section 2.1), 
the  definition  of  electricity  crisis,  as  it  is  necessary  for  stakeholders  and  other 
countries to predict when an emergency could be declared and, more importantly, when 
non-market based measures would be applied, 
the mandatory emergency tests (see section 2.8), 
information  regarding  the  mandatory  stakeholder  consultation  prior  to  the 
establishment of the Plan (Article 10(1) Regulation), 
further information on some national measures, including procedures, triggers and 
conditions  for  their  application,  especially  for  non-market-based  measures  to  be 
activated in an electricity crisis (only as a last resort and in a non-distortive manner),  

•  plans to develop future grids to help to cope with the identified risks,  
• 
the mechanisms used to inform the public about electricity crises,  
• 
the mechanisms for cooperation and coordination with Member States outside of 
their region or with third countries. 

The  plans  are  a  cornerstone  of  the  Regulation.  They  provide  transparency  and  enable  the 
coordination of measures across regions. In fact, ENTSO-E concluded in its Winter Outlook 
2022-202316 that cross-border cooperation and close coordination at all levels would be key 

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The  main  chapters  of  the  plans  are:  i)  the  summary  of  the  electricity  crisis  scenarios,  ii)  roles  and 
responsibilities of the competent authority, iii)  procedures and measures to follow in electricity crisis 
situations,  iv)  the  crisis  coordinator,  and  information  on  v)  stakeholder  consultations  during  the 
preparation process of the plans and on vi) emergency tests the competent authorities are supposed to 
regularly organise. 
By the 5 January 2022 deadline, only 14 Member States had submitted their Plans. 9 more notified by 
the  end of April 2022 and the last Plan was notified in December 2022 after a series of enforcement 
actions were carried out by the Commission. 

https://energy.ec.europa.eu/topics/energy-security/security-electricity-supply/risk-preparedness-plans-

electricity-sector-national-competent-authorities-and-commissions-opinions_en 
ENTSO-E’s Winter Outlook 2022-2023 

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during that winter to ensure that the European power system maintained its balance between 
supply and demand and referred specifically to the exchange on risk preparedness plans.  

However, there is still room for improvement. Given that the scenarios were not described in 
extensive detail, it is not possible to conclude on whether all appropriate measures to address 
the identified risks were included in the plans and adopted. The cross-sectoral link remains also 
weak,  and  it  is  questionable  whether  a  number  of  plans  have  a  future  looking  approach,  as 
evidenced by the limited consideration of future grid developments.  

In terms of procedure, the provisions can be considered unnecessarily heavy, both for the 
adoption of plans, its assessment by the Commission and the reply to the Commission’s request 
for amendments, which was evidenced by numerous delays in spite of enforcement actions. 
Moreover,  while  most  Member  States  included  more  details  in  their  plans  following  the 
Commission’s recommendations, not all issues were addressed showing limited effectiveness 
of the feedback loop. The efficiency of the risk preparedness plans’ administrative process is 
discussed more extensively in the fitness check report. 

2.5 Regional and bilateral measures to cooperate in the prevention or management of a 
crisis 

The Regulation  established  a new mechanism  for Member States to  cooperate in  a spirit of 
solidarity to prevent or manage crises (Article 15). Where the required technical ability exists, 
Member States have to offer each other assistance through ‘regional’ or ‘bilateral’ 17 measures 
with the ultimate purpose to protect public safety and personal security. The technical, legal 
and financial arrangements necessary to implement such regional or bilateral measures need to 
be  agreed  in  advance  among  Member  States,  including  with  regard  to  fair  compensation. 
Subsequently,  each  Member  State  has  to  implement  and  describe  in  its  plan  the  national 
measures that ensure actual implementation and enforcement of the solidarity measures. The 
Commission provided guidance18 to Member States on the key elements of fair compensation 
and other aspects to be included in the technical and financial arrangements between Member 
States for the application of the assistance mechanism. 

The information regarding these measures was largely missing from the Plans. In some cases 
(9),  the  Plans  referred  to  existing  arrangements  for  regional  and  bilateral  cooperation  and 
identified a number of future possible measures, but these were not agreed or adopted yet.  One 
of the most advanced cases was the Pentalateral  Energy Forum19, whose members signed a 
memorandum of understanding in December 2021 with a list of possible common measures 
for further analysis. The Central Eastern European Member States signed a similar MoU in 
2022.  In other cases (15), Member States referred to existing arrangements among TSOs but 
in the absence of further information on the concrete measures, it was unclear whether such 
agreements would meet the requirements of the Regulation. The amended plans following the 

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Regional measures are agreed within a region while bilateral measures are agreed between two countries 
electrically  interconnected  but  not  being  in  the  same  region.  Region  is  defined  in Article  2  of  the 
Regulation  as  a  group  of  Member  States  whose  TSOs  share  the  same  regional  coordination  centre. 
Transitional  provisions applied pending the establishment of the regional coordination centres (Article 
22 of the Regulation) 
OJ L 184, 12.6.2020, p. 79–93 
The  Pentalateral  Energy  Forum  is  a  regional  partnership  that  includes  the  following  Member  States: 
Belgium, the Netherlands, Luxembourg, Germany, France and Austria. 

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Commission’s request for further information did not add significant information and simply 
pointed to ongoing negotiations with their neighbours. This is clearly an area where substantial 
improvement is needed. 

This  mechanism  for  bilateral  and  regional  cooperation  was  designed  in  a  way  that  allowed 
significant flexibility for Member States’ implementation by setting minimum provisions and 
requirements.  While  such  approach  is  beneficial  to  factor  in  different  specific  conditions, 
evidence20 suggests that the practical implementation has been challenging as it requires prior 
agreement and discussion on a number of fundamental areas where Member States had very 
different  departing  points.  Challenges  encountered  include  varying  definitions  of  electricity 
crises, the definition of the competent authority’s scope of actions during a crisis, including in 
support  of  others,  the  development  of  financial  compensation  mechanisms  and  the 
establishment  of  communication  and  coordination  protocols.    While  some  efforts  were 
undertaken by the Commission to support Member States (e.g. clarification of the definition of 
electricity  crisis  beyond  the  Regulation’s  content21,  explaination  of  the  link  between  the 
Regulation and the Emergency and restoration network code22, sharing of existing practices for 
regional  cooperation  and  some  existing  measures23),  no  single  new  bilateral  or  regional 
cooperation mechanism has been fully developed.  

2.6 Exercises  

The Regulation requires periodic testing of the effectiveness of the procedures in the plans for 
preventing electricity crises, including mechanisms on information sharing and cooperation. A 
calendar for biennial regional and, if applicable, national emergency tests has to be included in 
the plans with details on the procedures and actors involved. The lessons from these tests have 
to be reflected in subsequent editions of the plans.  

In general, plans or their amended versions include limited information on the exercises, mostly 
generic  information  on  exercise  procedures  and  stakeholders  involved.  The  mandatory 
calendar for future  regional  and  national  real  time crisis  simulation  exercises is  missing  for 
most  Member  States.  Only  Pentalateral  Energy  Forum’s  Member  States24  have  been  rather 
active in the organisation of electricity crisis exercises, which has resulted in improvements of 
their  plans  (for  example,  the  communication  protocols).  Moreover,  only  one  Member  State 
described a link between the electricity and gas sectors in the emergency tests.  

In conclusion, and based on the information provided, the tests of the procedures in the plans 
have  been  at  best  limited,  even  if  the  benefits  of  such  tests  are  widely  recognised  by 
experts. This would speak in favour of more prescriptive provisions regarding exercises and 
possibly  a  facilitating  role  by  another  actor  in  the  case  of  regional  exercises,  based  on  the 

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Stemming notably from two workshops organized by the Commission with Member States, in May 2023 
and in June 2024. 
The Regulation leaves significant margin for Member States to define as crisis as they determine what 
‘a  significant  electricity  shortage’  is  (Article  2).  In  practice  this  varies  from  detailed  and  specific 
approaches including indicator values to very generic definitions leaving flexibility for Member States 
to declare a crisis depending on the circumstances. 
Commission  Regulation  (EU)  2017/2196  of  24  November  2017  establishing  a  network  code  on 
electricity emergency and restoration, OJ L 312, 28.11.2017, p. 54–85 
Second workshop organised by the Commission in June 2024. 
Belgium, Netherlands, Luxembourg, Germany, France, Austria and Switzerland. 

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example  of  Pentalateral  Energy  Forum’s  Member  States.  At  the  same  time,  a  number  of 
Member States’ delegates have expressed their concerns  at the ECG over a high number of 
exercises planned in different areas and touching upon electricity, which risks creating a certain 
exercise fatigue and could ultimately limit the resources available for exercises as required by 
the Regulation. In this area, there is substantial room for improvement and for better synergies. 

3.  Conclusions  

The implementation of the Regulation has enabled the EU to make relevant progress in 
its security of electricity supply. It has provided the first-ever EU-wide common and uniform 
framework  for  electricity  risk  preparedness,  and  Member  States  have  developed  risk 
preparedness plans, grounded on regional and national electricity crisis scenarios, according to 
unified methodologies and a common template.  

However, this report also highlights some areas for significant improvement. This includes 
the  need  for  more  in-depth  analysis  of  regional  and  national  electricity  crisis  scenarios  to 
support  policy  making  (preventive  and  emergency  measures),  the  development  of  more 
effective regional and bilateral measures to cooperate in the prevention or management of a 
crisis, and the use of exercises and emergency tests to ensure the effectiveness of national plans. 
This report also identifies a lack of system integration approach in relation to security of supply 
and system resilience, which creates some weaknesses in the current framework.  

In addition, the Commission will look at the outcome and recommendations of the Expert Panel 
set up in accordance with EU law to investigate the blackout in the power systems of Spain and 
Portugal on 28 April 2025. These will provide further insights to be considered in the revision 
of the energy security framework with the ultimate goal to ensure that the EU's energy security 
architecture is robust, resilient, and able to shield European citizens and businesses from the 
challenges of the future.  

The energy system has also been deeply impacted by several events since the entry into 
force of the Regulation, such as the full-scale invasion of Ukraine by Russia and increased 
risks on critical energy infrastructure. In reaction to these events, the EU accelerated its work 
on new legislation to protect critical infrastructure from physical and cyber-attacks25, carried 
out stress tests to critical energy infrastructure26 and also strengthened cooperation with other 
actors such as NATO27. Most recently, the EU intensified efforts28 to enhance the security of 
its undersea cable infrastructure in response, among others, to growing threats to submarine 
power  cables29  posed  by  the  illicit  activities  of  the  Russian  shadow  fleet.  These  late 
developments have only been factored in the current energy architecture to a limited extent and 
in the form of recommendations to Member States contained in the Commission opinions on 
the Plans e.g. to implement the results of the stress tests or to increase cooperation between 
authorities responsible for security of supply and cyber security actors. 

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28  
29  

Directive  (EU) 2022/2557  on  the  resilience  of  critical  entities  (CER),  OJ  L  333,  27.12.2022,  p.  164. 
Directive  (EU)  2022/2555  on  measures  for  a  high  common  level  of  cybersecurity  across  the  Union 
(NIS2), OJ L 333, 27.12.2022, p. 80.  
See Point 6 of the Council Recommendation of 8 December 2022 on a Union-wide coordinated approach 
to strengthen the resilience of critical infrastructure, OJ C 20, 20.1.2023, p. 1. 
See the EU-NATO Task Force on the resilience of critical infrastructure 
COM/2025/440 final/2. 
JOIN (2025) 9 final. 

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Similarly, the Commission could only recommend Member States to include climate change 
considerations,  such  as  climate  vulnerability  and  risks,  in  their  plans.  The  European 
Commission  has  now  published  its  first-ever  European  Climate  Risk  Assessment30,  which 
concluded  that  the  energy  sector  is  projected  to  experience  the  strongest  rise  in  economic 
annual damage to critical infrastructure, in comparison to transport, industry, and social sectors 
and  recommended  the  strengthening  of  climate  risk  planning  in  the  electricity  sector31In 
addition, the Commission has presented the European Preparedness Union Strategy32 to boost 
the EU's ability to anticipate, prevent, and respond to the unprecedented threats the European 
Union  is  facing  –  from  geopolitical  tensions  and  conflicts,  cybersecurity  and  information 
manipulation  risks,  to  climate  change  and  increasing  risks  of  natural  hazards.  This  strategy 
foresees the development of EU comprehensive risks and threats assessments. 

Furthermore,  the  European  energy  system  continues  undergoing  a  profound 
transformation driven by the need to decarbonise and electrify the economy, whose effects 
are already tangible. The framework needs to prepare for such changes in order to preserve 
security of supply in the Union. 

In the light of all the above, a revision of the existing framework appears essential to ensure 
it is fit for purpose to address new challenges. The findings of this report and the fitness check 
will inform the Commission's future policy initiatives to enhance security of electricity supply 
at Union level.  

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31  
32  

European Climate Risk Assessment  
COM(2024) 91 final. 
JOIN/2025/130 final. 

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