COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT [European Grids Package] Accompanying the documents Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on guidelines for trans-European energy infrastructure, amending Regulations (EU) 2019/942, (EU) 2019/943 and (EU) 2024/1789 and repealing Regulation (EU) 2022/869 Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives (EU) 2018/2001, (EU) 2019/944, (EU) 2024/1788 as regards acceleration of permit-granting procedures
Date: 2025-12-10
Institutions: Directorate-General for Energy, European Commission
Subjects: EU energy policy, administrative formalities, carbon neutrality, electrical energy, energy grid, energy storage, hydrogen, natural gas, renewable energy, security of supply, trans-European network

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   EUROPEAN COMMISSION  Luxembourg, 10.12.2025  SWD(2025) 2001 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT  [European Grids Package] Accompanying the documents Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on guidelines for trans-European energy infrastructure, amending Regulations (EU) 2019/942, (EU) 2019/943 and (EU) 2024/1789 and repealing Regulation (EU) 2022/869 Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives (EU) 2018/2001, (EU) 2019/944, (EU) 2024/1788 as regards acceleration of permit-granting procedures {COM(2025) 1006 final} - {COM(2025) 1007 final} - {SWD(2025) 2000 final} - {SEC(2025) 2000 final}  
 
 
A.  Need for action  

What is the problem and why is it a problem at EU level? 

Energy network infrastructure plays a crucial role in reinvigorating European competitiveness, in 
ensuring the security of our Union and in the energy transition and decarbonisation. The EU’s 
energy  networks  are  confronted  with  new  and  significant  challenges  in  supporting  an 
increasingly electrified, decentralised, digitalised and flexible electricity system characterised 
by a growing share of variable renewable energy sources. The Impact Assessment identified 
three key problems.  

First, existing and planned infrastructure projects are not sufficiently targeted towards 
achieving the EU’s energy and climate objectives. There is a substantial gap between our 
cross-border electricity infrastructure needs and the current speed and level of infrastructure 
development at both the transmission and distribution grid level. For electricity, half of cross-
border electricity needs for 2030 (32 of 66 GW) are currently not addressed, and this gap is 
expected to increase to 37 GW by 2040. Failing to address infrastructure needs could hinder 
system  decarbonisation,  undermine security of supply  and potentially  lead to  further market 
fragmentation  and  higher  energy  prices.  Further,  improved  hydrogen  network  planning  and 
integration will be crucial to ensure system optimisation and decarbonisation of industry. 

Second, the implementation of infrastructure, renewable energy and storage projects as 
well as recharging stations is too slow, increasing overall project costs and impeding system 
decarbonisation. The completion of electricity infrastructure projects takes up to 7.5 years for 
distribution grids and up to 10 years for transmission grids. For cross-border projects, delays 
can  be  caused  by  difficulties  in  reaching  agreement  on  cost-sharing  when  projects  carry 
benefits  outside  their  hosting  Member  States.  In  addition,  delayed  permitting  procedures 
continue to constitute a key bottleneck.  

Finally, concerns over infrastructure security. Recent physical and cyber security incidents 
have  highlighted  the  risk  of  hostile  actors  targeting  Europe’s  energy  infrastructure,  with 
economic cost implications and consequences for the stability of our energy system. There is 
also  a  rising  interest  from  third-country  actors  to  invest  in  EU  energy  infrastructure,  which 
can increase the EU’s exposure to risks related to energy security. Beyond deliberate acts of 
sabotage, emerging risks including natural hazards and climate-related impacts also affect the 
resilience of the EU’s energy infrastructure. 

Without timely action at EU level, under the current legislative and policy framework these 
problems are likely to persist or further aggravate. 

Objectives: What should be achieved? 

The  general  objective  of  the  European  Grids  Package  is  to  ensure  timely  and  efficient 
development  of  resilient  energy  infrastructure,  renewable  energy  and  flexibility,  including 
storage  and  recharging  stations,  across  the  EU.  This  will  enable  the  EU  to  deliver  on  its 
energy  and  climate  objectives,  including  ensuring  energy  affordability  through  better 
interconnectivity,  leading  to  price  convergence,  reduced  wholesale  electricity  prices  and 
lower  volatility  of  electricity  prices,  as  well  as  to  accelerated  connection  of  generation  and 
demand.  The  specific  objectives  of  the  initiative  are  to  i)  ensure  that  projects  included  in 
network development plans and selected as Projects of Common Interest (PCI) or Projects of 
Mutual  Interest  (PMIs)  address  identified  infrastructure  needs,  ii)  facilitate  the  use  of  cost-
sharing  tools  for  faster  deployment  of  cross-border  infrastructure  projects,  iii)  shorten  and 
simplify  permitting  procedures  for  energy  infrastructure,  renewable  energy  and  storage 

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projects,  as  well  as  recharging  stations  and  iv)  enhance  physical  and  cyber  security  and 
resilience of cross-border energy infrastructure. 

What is the added value of action at the EU level (subsidiarity)?  

Energy  transmission  infrastructure,  and  increasingly  electricity  distribution  grids,  have  a 
trans-European or cross-border nature and impact. The interconnected nature of the European 
energy network requires close coordination of national and EU planning. National regulation 
alone  is  inadequate,  as  national  administrations  are  unable  to  manage  cross-border 
infrastructure planning. Effective EU-level planning can improve integration of clean energy 
sources,  address  electricity  market  needs  and  ensure  security  of  supply,  resulting  in  a  more 
efficient network and reducing grid expansion needs.  

EU action on renewable energy under the revised Renewable Energy Directive (RED) brings 
added value because it is more efficient and effective than individual Member States’ actions, 
avoiding a fragmented approach by addressing the transition of the European energy system 
in a coordinated way. It ensures net reduction of greenhouse gas emissions, fully exploits the 
advantages of economies of scale and technological cooperation in Europe and gives investors 
certainty in an EU-wide regulatory framework.  

B.  Solutions  

What  are  the  various  options  to  achieve  the  objectives?  Is  there  a  preferred  option  or 
not?  

Three  policy  options  have  been  identified  to  achieve  the  objectives  of  this  initiative:  1) 
enhanced  bottom-up  approach  with  minimal  additional  EU-level  intervention  and  limited 
changes  to  the  current  legislative  and  policy  framework;  2)  moving  from  a  bottom-up 
towards  a  more  top-down  approach  with  stronger  steer  from  the  EU  level  and  with  the 
introduction of more significant changes to the legislative and policy framework, and 3) a full 
top-down approach for large-scale cross-border infrastructure and energy projects, including 
substantial  structural  and  institutional  changes  to  the  status  quo  and  a  higher  degree  of 
centralising and streamlining at EU level. 

Without prejudice to political considerations and the final Commission legislative proposal 
for the European Grids  Package, based on the technical  assessment  and the comparison  of 
options (see Section 6 and 7 of the Impact Assessment report), while policy option 3 would 
present  some  benefits,  on  balance,  policy  option  2  (PO2)  appears  as  more  effective, 
efficient  and  coherent  with  the  overall  EU  policy  framework.  It  is  also  considered  to 
perform better in terms of subsidiarity and proportionality. 

PO2  would  entail  several  changes  to  the  EU  legislative  and  policy  framework,  including 
measures to i) ensure greater transparency, scrutiny and coordination of network planning 
both on EU and national levels, introduce a gap filling mechanism to address infrastructure 
needs, and better incorporate non-wired solutions and internal lines, ii) enhance transparency 
and strengthen principles to facilitate cost sharing and establish a framework for voluntary 
bundling  of  projects,  iii)  legislative  amendments  to  further  accelerate  and  simplify 
permitting  procedures  for  cross-border,  national  transmission  and  local  distribution  grids 
as  well  as  renewable  energy  and  storage  projects  and  recharging  stations,  iv)  introduce 
additional requirements to enhance physical and cyber security of cross-border electricity 
infrastructure. 

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What are the different stakeholders’ views? Who support which option?  

The  measures  included  in  the  preferred  option  are  broadly  supported  by  stakeholder  views, 
which  nevertheless  diverge  on  some  issues  (see  Annex  2).  A  majority  of  respondents  agree 
that the current governance framework of the TYNDPs, including stakeholder roles, should 
be  revised  to  enhance  effectiveness.  Further,  about  half  of  the  respondents  state  that  the 
current TYNDP process falls short in identifying infrastructure gaps. Stakeholders have split 
views  on  whether  the  TYNDP  should  have  a  more  top-down  approach  to  infrastructure 
planning, with system operators tending to show a preference for the status quo. A majority of 
stakeholders ranked permitting as the leading obstacle to ensuring Europe’s grid develops as 
needed  for  the  energy  transition.  Stakeholders  also  called  for  further  action  to  accelerate 
permitting for renewable energy and storage projects.  

C.  Impacts of the preferred option  

What are the benefits of the preferred option?  

PO2 is expected to bring about substantial economic, environmental and social benefits, and 
reduce administrative and adjustment costs for stakeholders. 

PO2  is  expected  to  entail  significant  energy  system  cost  savings.  Enhanced  energy 
infrastructure planning would lead to a more optimal and resilient grid which could  bring 
about  EUR  14  billion/year  reduction  of  system  costs  and  annual  net  savings  of  EUR  8 
billion/year  for  2040.  An 
the 
materialisation  and  quicker  implementation  of  cross-border  projects,  with  significant  socio-
economic welfare benefits. Further, PO2 is expected to reduce permitting times and thereby 
project implementation, which would generate benefits in terms of avoided costs of delays for 
project  promoters.  Finally,  through  improved  energy  infrastructure  security,  PO2  could 
bring about benefits in terms of avoided loss of economic welfare and of costs of repairs. 

improved  cost-sharing  framework  would  facilitate 

These  savings  would  benefit  consumers,  electricity  producers  and  system  operators  by 
improving  competitiveness  and  creating  social  benefits.  Lower  energy  system  costs  would 
mitigate  network  tariff  increases  for  consumers,  including  industry.  PO2  would  also  have  a 
positive impact  on  digitalisation, through its  stronger emphasis on non-wired solutions  and 
digitalisation  of  permitting  procedures.  Finally,  PO2  is  expected  to  reduce  administrative 
and adjustment costs for businesses (including energy generators, project promoters, TSOs 
and  ENTSOs)  through  streamlining  infrastructure  planning,  PCI/PMI  application  and 
evaluation  processes  as  well  as  permitting  procedures.  As  regards  environmental  benefits, 
the  preferred  policy  option  could  lead  to  a  reduction  of  CO2  emissions  (around  27 
Mtonnes/year). 

What are the costs of the preferred option?  

hat PO2 is not expected to have significant negative economic, 
The assessment indicates t 
social  or  environmental  impacts.  Some  measures  may,  however,  entail  limited  additional 
compliance  costs  for  certain  stakeholders.  For  businesses,  PO2  may  entail  additional 
administrative and adjustment costs for TSOs and project promoters, relating to their role in 
the  identification  of  infrastructure  needs  and  follow-up  as  well  as  new  security  related 
reporting  requirements.  These  costs  would  either  be  limited  or  be  offset  by  other  measures, 
including  the  Commission  taking  over  certain  planning  tasks  from  ENTSOs,  a  reduced 
frequency and simplification of the TYNDP, and a simplified PCI/PMI application processes. 
Simplified and digitalised permitting procedures would also reduce the administrative burden 
for  businesses.  While  the  annual  costs  savings  for  businesses  cannot  be  fully  estimated  as 

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relevant  data  were  not  available,  it  can  be  concluded  that  PO2  would  lead  to  recurrent  cost 
saving. Further, the initiative is not expected to impose additional costs for citizens. 

For  Member  States  and  national  authorities,  PO2  would  create  additional  administrative 
costs  in  the  short-term,  related  to  the  implementation  of  revised  legislative  framework  (see 
below).  Finally,  PO2  will  entail  additional  costs  for  the  Commission  and  ACER,  which 
would take on a greater role in infrastructure planning. 

What are the impacts on SMEs and competitiveness?  

This  initiative  is  not  expected  to  have  specific  implications  on  SME  competitiveness  in 
addition  to  the  above  considerations  on  competitiveness.  Expanding  and  modernising  the 
EU’s  grid  network  combined  with  increased  deployment  of  renewable  energy  will  improve 
access  to  electricity  and  increase  supply,  benefiting  all  actors  including  SMEs.  This  will 
reduce energy system costs for all consumers and can in turn lower supply costs.  

Will there be significant impacts on national budgets and administrations? 

PO2  is  expected  to  have  a  limited  impact  on  the  budgets  and  administrations  of  relevant 
national authorities. Member States may have to allocate additional resources to support the 
revised  cost-sharing  process,  notably  to  enable  NRAs  to  conduct  assessments  and  take 
decisions on potential projects and engage in the regulation of projects outside their territory. 
Additional resources may also be required to implement the revised  permitting provisions, 
including to equip permitting authorities with necessary staff, skills and tools. However, these 
additional  short-term  costs  are  expected  to  be  offset  by  benefits  in  terms  of  streamlined, 
simpler, quicker and digitalised procedures over the longer-term. 

Will there be other significant impacts? 

No other impacts are expected. PO2 is expected to contribute to a substantial simplification of 
infrastructure planning and governance in the Union, as well as permitting (see Section 8.2.).  

Proportionality  

PO2 is assessed to  be  able to  deliver on the objective of the European  Grids  Package  in  an 
effective  and  efficient  manner,  without  imposing  significant  additional  costs  on  relevant 
actors. It would not go beyond what is needed to achieve the objectives of this initiative and is 
therefore considered proportional. 

D.  Follow up  

When will the policy be reviewed? 

The  Commission  will  monitor  and  evaluate  the  impacts  of  the  legislation  against  a  set  of 
indicators  (see  Section  9)  allowing  to  measure  progress  in  achieving  the  specific  and 
operational objectives A review of the effectiveness of the new legislation could take place by 
the end of 2032, when the second PCI and PMI selection process under the new framework 
should have been completed. 

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