COMMISSION STAFF WORKING DOCUMENT EU energy security - evaluating the EU's security of electricity and gas supply framework
Date: 2025-12-22
Institutions: Directorate-General for Energy, European Commission
Subjects: electrical energy, electricity supply, energy cooperation, energy crisis, energy law, energy market, gas, gas industry, gas supply, security of supply

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 22.12.2025  SWD(2025) 435 final  COMMISSION STAFF WORKING DOCUMENT EU energy security - evaluating the EU's security of electricity and gas supply framework  
 
 
Table of contents 

1. 

INTRODUCTION ................................................................................................................. 1 

1.1.  Purpose and scope of the fitness check ................................................................................... 1 

1.2.  Methodology ........................................................................................................................... 4 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? .................. 6 

2.1.   Description of the intervention and its objectives ................................................................... 6 

2.2  Point(s) of comparison (baseline) ......................................................................................... 17 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? .. 18 

3.1.  Evolution of EU security of gas and electricity supply (2017-2024) .................................... 18 

3.2.  State of play of implementation ............................................................................................ 27 

3.3.  External factors and policy developments: energy crisis 2021-2023 .................................... 34 

4. 

EVALUATION FINDINGS ............................................................................................... 41 

4.1.  To what extent was the intervention successful and why? .................................................... 41 
4.2.  How did EU action make a difference and to whom? ........................................................... 68 
4.3.  Is the EU action still relevant? .............................................................................................. 73 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? .............................. 85 
5.1.  Conclusions ........................................................................................................................... 85 
5.2.  Lessons learned ..................................................................................................................... 88 

ANNEX I:   PROCEDURAL INFORMATION ............................................................................. 90 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ..................................... 93 
ANNEX III. EVALUATION MATRIX ....................................................................................... 110 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ........................................................... 143 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............................. 153 
ANNEX VI. STRATEGIC FORESIGHT - MEGATRENDS WORKSHOP ............................... 174 

 
 
 
 
 
 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

ACER 

Bcm 

CEE 

CEER 

CEF 

Agency for the Cooperation of Energy Regulators 

Billion cubic meters 

Central and Eastern Europe 

Council of European Energy Regulators 

Connecting Europe Facility 

CER Directive 

Critical Entities Resilience Directive 

CRA 

CRM 

CRMA 

DG 

Common Risks Assessment 

Critical Raw Material 

Critical Raw Material Act 

Directorate-General 

DG ENER 

Directorate-General for Energy 

DSO 

ECG 

EnC 

EENS 

ENS 

ENTSO-E 

ENTSOG 

EP 

EU 

EUCRA 

FDI 

FSRU 

Distribution System Operator 

Electricity Coordination Group 

Energy Community 

Expected Energy Not Served 

Energy Not Served 

European Network of Transmission System Operators 
for Electricity 

European Network of Transmission System Operators 
for Gas 

Emergency Plan 

European Union 

European Climate Risk Assessment 

Foreign Direct Investment 

Floating Storage and Regasification Unit 

 
 
GCG 

GFPP 

GWh 

IP 

ISG 

JRC 

KPI 

kWh 

LNG 

LOLE 

Mcm 

MoU 

MS 

NATO 

NECP 

Gas Coordination Group 

Gas-Fired Power Plant 

Gigawatt hour 

Interconnection Point 

Interservice Steering Group 

Commission’s Joint Research Centre 

Key Performance Indicator 

Kilowatt hour 

Liquefied Natural Gas 

Loss Of Load Expectation 

Million cubic meters 

Memorandum of Understanding 

Member State 

North Atlantic Treaty Organisation 

National Energy and Climate Plan 

NIS2 Directive 

Network and Information Security 2 Directive 

NRA 

PACE 

PAP 

PCI 

PMI 

Ppm 

PV 

RCCs 

National Regulatory Authority 

Integrated Resolve Parallel and Coordinated Exercises 

Preventive Action Plan 

Project of Common Interest 

Projects of Mutual Interest 

Parts per million 

Photovoltaics 

Regional Coordination Centres 

ReCo system 

Regional Coordination System 

RSB 

Regulatory Scrutiny Board 

 
 
RPP 

RPR 

SME 

SoS 

SSO 

SWD 

TEN-E 

TSO 

TTX 

TWh 

TYNDP 

UGS 

VIP 

VOLL 

Risk Preparedness Plan 

Risk Preparedness Regulation 

Small and Medium Enterprises 

Security of Supply 

Storage System Operator 

Staff Working Document 

Trans-European Network for Energy 

Transmission System Operator 

Table-top exercise 

Terawatt hour  

Ten Year Network Development Plan  

Underground Gas Storage 

Virtual Interconnection Point 

Value of Lost Load 

 
 
1. 

INTRODUCTION 

1.1.  Purpose and scope of the fitness check 

Energy  security  is  one  of  three  pillars  of  EU  energy  policy,  alongside  sustainability  and 
affordability. It can be defined as the ability of an economy to ensure a constant match between 
its  energy  needs  and  its  energy  supply,  even  under  challenging  circumstances.  This  means 
ensuring both:  

i. 

ii. 

the long-term equilibrium between demand and supply structures (through security and 
diversity of supply and demand-side measures), and; 
the ability of the system to react to sudden shocks.  

The  fundamentals  of  energy  security  are  primarily  ensured  by  well-functioning  and  well-
connected energy markets, which allow the energy to flow where it is the most needed through 
price  signals,  as  well  as  energy  efficiency  and  sufficiency  efforts.  Additionally,  the  EU  has 
developed a robust energy security architecture. It was designed with the objective of limiting 
as much as possible the interactions with the normal functioning of the energy markets. It is 
supposed to work as an insurance, which kicks in mainly in situations where the markets are no 
longer able to deliver (e.g., when high prices do not attract additional supplies). This energy 
security  framework  relies  on  the  following  pillars:  security  of  gas  supply;  electricity  risk-
preparedness;  emergency  oil  stocks;  the  safety  of  offshore  energy  infrastructure;  critical 
infrastructure  protection  (including  critical  entities  resilience);  cybersecurity;  and  access  to 
critical raw materials. 

In 2021-2023, the EU faced one of the worst energy crises since the oil shocks of the 1970s, in 
particular due to the invasion of Ukraine by Russia in February 2022 and Russian weaponisation 
of energy supply. This energy crisis was a stark reminder of how energy security and the clean 
transition towards domestically produced energy are key building blocks of a resilient, future-
proof and competitive economy. At the same time, the energy transition is changing the energy 
system, while it brings new opportunities, it also calls for an updated energy security framework 
that is fit to face new challenges for the EU energy system. Thereupon, in 2024, the European 
Commission  (hereafter:  “the  Commission”)  received  calls  for  action  from  the  European 
Council1, the Council2, and three former EU heads of governments3. More recently, the new 

1  European  Council  conclusions,  22  March  2024:  https://www.consilium.europa.eu/media/70880/euco-

conclusions-2122032024.pdf 

2  Council  conclusions  on  “Advancing  sustainable  electricity  grid 

infrastructure”,  30  May  2024: 

https://data.consilium.europa.eu/doc/document/ST-10459-2024-INIT/en/pdf 

3 Enrico Letta, Much more than a market, April 2024 (https://www.consilium.europa.eu/media/ny3j24sm/much-
more-than-a-market-report-by-enrico-letta.pdf);  Mario  Draghi,  The  future  of  European  competitiveness, 
September 
(https://commission.europa.eu/document/download/97e481fd-2dc3-412d-be4c-
f152a8232961_en);  Sauli  Niinistö,  Safe  Together:  Strengthening  Europe’s  Civilian  and  Military 
Preparedness  and  Readiness,  October  2024  (https://commission.europa.eu/document/download/5bb2881f-
9e29-42f2-8b77-8739b19d047c_en?filename=2024_Niinisto-report_Book_VF.pdf). 

2024 

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Commissioner  for  Energy  and  Housing  has  been  tasked  with  conducting  “a  review  of  the 
security of supply framework”4. This fitness check report is a first step in this review. 

Energy security is also closely linked to economic security and economic competitiveness with 
security of supply threats translating into higher and more volatile energy prices, as pointed out 
by the Draghi report. In addition, dependence on non-euro invoicing for energy imports exposes 
EU companies to foreign exchange risk and disruptions in third-country payment and settlement 
systems, which can amplify volatility and undermine competitiveness. This is why the Clean 
Industrial Deal5 and Affordable Energy Action Plan6 highlight that industrial competitiveness 
and  decarbonisation  strategy  is  also  a  security  imperative.  Similarly,  the  2023  European 
Economic Security Strategy refers to energy security in the context of the assessment and the 
mitigation of supply chains’ risks7. The Affordable Energy Action Plan stresses the need for a 
reviewed  regulatory  framework  that  increases  the  resilience  of  the  EU’s  energy  system  to 
geopolitical tensions, cyberattacks, deliberate attacks or extreme weather events that threaten 
security  and  affordability.  The  most  recent  European  Preparedness  Union  Strategy8  also 
identified the “resilience of vital societal functions” as a priority area for action and highlights 
the  review  of  the  energy  security  framework  as  one  of  the  main  policy  initiatives  in  this 
perspective  for  2026  (Action  23).  Moreover,  the  European  Grid  Package9  addresses  energy 
security  by  cross-border  integrated  planning  and  delivery  of  projects,  to  ensure  an  efficient 
network system that ensures that energy flows to where it is most needed.  

The scope of this fitness check report is to evaluate the Gas Security of Supply Regulation10 of 
2017 and the Electricity Risk Preparedness Regulation11 of 2019. These two Regulations are 
covered by this fitness check because they are the two core Regulations governing EU’s energy 
security, while the gas and electricity markets are highly intertwined. Furthermore, both gas 
and electricity security of supply have been at the centre of the 2021-2023 energy crisis. Their 
similarly designed regulatory frameworks make a joint evaluation more meaningful. This report 
therefore covers the implementation period of the adoption of the first of these Regulations, i.e. 
from 2017 until 2024. 

4 See mission letter: 1c203799-0137-482e-bd18-4f6813535986_en 
5 COM(2025) 85 final  
6 COM(2025) 79 final 
7 JOIN(2023) 20 final 
8 JOIN(2025) 130 final. 
9 See: Commission proposes upgrade of the EU's energy infrastructure to lower bills and boost independence 
10 Regulation (EU) 2017/1938 
11 Regulation (EU) 2019/941 

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Figure 1: Scope of the fitness check on security of gas and electricity supply 

Source: European Commission  

The Oil  Stocks Directive is  outside the scope of this  fitness  check exercise,  given the more 
limited synergies and connections with gas and electricity. At the same time, the EU gas and 
electricity markets  are more  regulated via single market regulations compared to the EU oil 
market. The Offshore Safety Directive, for its part, is mainly focused on the concept of safety, 
including  environmental  and  labour  safety.  Whilst  important,  the  safety  requirements  are 
distinct from the one of security, and this directive is therefore also outside the scope of this 
report.  Whilst  this  fitness  check  will  focus  on  the  core  elements  of  the  EU  energy  security 
framework, oil stocks and the safety of offshore installations could be considered as part of a 
future wider review.  

Critical infrastructure protection, cybersecurity and critical raw materials are also essential for 
the  future  energy  security  framework  and  are  governed  by  recent  horizontal  legislation12. 
Although there is some margin for action in the horizontal regulations, these provisions (critical 
infrastructure protection, cybersecurity) are complemented by sectoral provisions included in 
the Risk Preparedness Regulation and the Gas Security of Supply Regulation. This fitness check 
primarily focusses on the provisions in the Risk Preparedness Regulation and Gas Security of 
Supply  Regulation,  their  coherence  with  the  horizontal  framework,  as  well  as  their  future 
relevance. When it comes to critical raw materials, this is a relatively recent area for EU acquis 
and horizontal legislation is currently being implemented, with significant milestones taking 
place in 2025. The Risk Preparedness Regulation and the Gas Security of Supply Regulation 
did  not  include  concrete  provisions  in  this  area,  but  the  fitness  check  looks  at  the  overall 
relevance of critical raw materials for the future energy system. The coherence of the evaluated 
interventions with these horizontal provisions will also be assessed (c.f. section 4.1).  

12 Notably the Critical Entities Resilience Directive for the protection of critical energy infrastructure (2022), the 
NIS2 Directive for cybersecurity (2022) and the Critical Raw Materials Act (2024). The Net-Zero Industry 
Act (2024) addresses supply chain resilience for clean technologies. 

3 

 
 
 
 
The  energy  crisis,  caused  by  hostile  gas  supply  cuts  from  Russia  following  its  full-scale 
invasion of Ukraine, has led to several EU-level  initiatives that are part of the scope of this 
fitness check. These include:  

i.  Legislative amendments introduced by the Storage Regulation13 and the Hydrogen and 
Gas Market Decarbonisation Package14 to the Gas Security of Supply Regulation.  
ii.  The  temporary  emergency  Regulations  like  the  Gas  Demand  Reduction  Regulation15 

and Solidarity Regulation16.  

The Regulation (EU) 2022/1854 on Emergency Intervention to mitigate the High Energy Prices 
is not part of the scope of this fitness check, because the objective of the Regulation was to 
address high electricity prices, rather than security of supply concerns. 

The objective of this fitness check is to evaluate the effectiveness, efficiency, EU added value, 
coherence and relevance of the EU security of gas and electricity supply framework, in line 
with the Better Regulation guidelines17. This fitness check will assess:  

(1) Whether the above-mentioned EU regulatory framework has been successful in meeting 

its objectives at the time of adoption and is fit for an evolving energy landscape. 

(2) The extent to which the various pieces of legislation have worked together, to increase 

the EU’s security of electricity and gas supply.  

While primarily backward-looking in nature, this report also contains forward-looking aspects, 
to assess the continued relevance of the regulatory framework given the ongoing transformation 
of the energy sector towards decarbonisation. 

1.2.  Methodology 

Most of the findings of this report are based on the activities set out below. 

•  The collection and assimilation of in-house expertise using (among others) experience 
gained from implementing the Regulations. This expertise comes from e.g.: (i) several 
cycles of Commission opinions on various plans18; and (ii) drafting two Commission 
reports  on  the  implementation  of  the  evaluated  Regulations19.  This  experience  also 
includes lessons learnt from the 2021-2023 energy crisis.  

•  Two  table-top  exercises  (“dry  runs”)  to  stress-test  the  EU  framework  against  crisis 
situations were organised in December 2022 and November 2024 by the Commission 

13 Regulation (EU) 2022/1032. 
14 Directive (EU) 2024/1788 and Regulation (EU) 2024/1789. 
15 Regulation (EU) 2022/1369. 
16 Regulation (EU) 2022/2576. 
17 SWD(2021) 305 final. 
18 One cycle for electricity, two cycles for gas. 
19 COM(2023) 572 final and COM(2025) 539 final. 

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to  test:  (i)  emergency  procedures  and  the  gas  system’s  resilience;  and  (ii)  the 
interlinkages between the EU’s gas system and electricity system.  

•  Exchanges with Member States and other key actors (EU Agency for the Cooperation 
of Energy Regulators (ACER), ENTSO-E, ENTSOG, Regional Coordination Centres 
(RCCs)) to estimate the costs linked to the Regulations. 

•  Extensive desk research, with support of the Commission’s Joint Research Centre (JRC) 
and DG ENER’s Chief Economist Team to provide scientific and analytical input. This 
was  based  on  a  set  of  indicators  to  measure  the  performance  of  the  evaluated 
Regulations  and  the  overall  security  of  electricity  and  gas  supply  situation.  It  also 
incorporates findings from reports from external sources such as ACER, IEA, ENTSOG 
and ENTSO-E. 

•  A  cross-DG  strategic  foresight  exercise  was  organised,  using  the  JRC’s  Megatrends 
tool20, to collectively reflect on potential risks and opportunities for security of gas and 
electricity supply. More details can be found in Annex VI. 

•  A  12-week  call  for  evidence  and  public  consultation,  as  well  as  other  consultation 
activities, were carried out to gather citizens and stakeholders’ views. A synopsis report, 
summarising all of them, can be found in Annex V. 

At the same time, this fitness check report also displays methodological shortcomings: 

o  Exogenous factors influence EU security of gas and electricity supplies. Energy security 
is  a  complex  interplay  of  global  dynamics,  including  geopolitical  events,  market 
fluctuations, and dependency on external suppliers. Quantifying the impacts on both EU 
security of supply and the performance of the evaluated interventions therefore proved 
challenging.  Establishing  causality  between  the  two  Regulations  and  the  subsequent 
outcomes is often not possible due to the variety of factors influencing the EU’s security 
of gas and electricity supply. 

o  The difficulty of quantifying benefits of security of supply. Energy security policy acts 
as insurance for severe but unlikely events. Several provisions in the Regulations will 
hopefully  never  have  to  be  used,  making  their  related  benefits  difficult  to  assess. 
Moreover,  energy  prices  get  influenced  by  factors  beyond  security  of  supply  (e.g. 
market dynamics, tariffs and (global) competition), although having an adequate level 
of supply is a precondition for affordable prices.  

o  Data  availability  and  key  performance  indicators  (KPIs)  on  certain  aspects  to  be 
assessed were not sufficiently available. The Regulations prepare for many hypothetical 
scenarios  in  order  to  avoid  the  occurrence  of  such  scenarios.  Due  to  this  so-called 
‘preparedness-paradox’21,  it  is  not  possible  to  determine  which  crises  have  been 
prevented and what their impact would have been. 

20 See: https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en 
21 The ‘preparedness paradox’ means that the more an entity prepares for crises, the likelier that crises get avoided 
which results in fewer consequences. In turn, this makes continuing investing in preparedness harder to justify 
because the benefits are no longer tangible. 

5 

 
 
 
 
2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. Description of the intervention and its objectives 

This section provides an overview of the rationale, provisions and expected effects of the two 
evaluated interventions. While it could have been an option to create one unified intervention 
logic for the two Regulations, this report has two separate ones, because:  

(i)  Even if similar in their set-up, the two Regulations were designed as two distinct policy 

interventions, responding to different political contexts and needs.  

(ii) Gas and electricity markets, although increasingly integrated, still work differently.  

Given  that  the  Regulations  reacted  to  different  problems  in  different  years,  the  intervention 
logics  are  kept  separate.  However,  section  4  presents  the  evaluation  findings  from  a  cross-
sectoral perspective, as much as possible. Similarly, the crisis measures were not included in 
this section, as they were adopted as an add-on in a very different context, responding therefore 
to  different  needs:  they  were  therefore  treated  as  policy  developments  and  are  extensively 
described in section 3. 

Box 1: Lexical clarifications about the intervention logic 

According to tool #46 of the Better Regulation toolbox, an intervention logic of an evaluation 
or fitness check is supposed to summarise “how the intervention was expected to work (i.e. 
at the time of adoption by the Commission or later by the co-legislators, or at the time of 
implementation), including the underlying assumptions”.  

The intervention logic should reflect the following elements: 

❖  The  problems/needs  it  responds  to:  what  was  the  rationale  behind  the  original 

intervention? 

❖  The objectives (general and specific): what were the expected changes that the EU 

was aiming to achieve? What was the positive desired situation? 

❖  The  inputs:  how  were  these  changes  supposed  to  be  achieved?  What  kind  of 

resources were expected to be used? 

❖  The activities: which events were expected to happen? What tasks were planned in 

order to transform the inputs into outputs? 

❖  The outputs: what were the short-term operational achievements that were expected 

to be delivered? 

❖  The results: what were the medium-term specific achievements that were expected 

to be delivered? 

❖  The  impacts:  what  were  the  expected  long-term  general  achievements  that  were 

expected to be delivered? 

❖  The external factors: what were the factors, apart from the implementation of the 

interventions, that may have affected the final performance? 

6 

 
 
2.1.1 Intervention logic for the Gas Security of Supply Regulation  

The origin of the Gas Security of Supply Regulation can be traced back to the first EU-level 
gas security of supply intervention22, adopted in 2004. 

The  general  objective  of  this  directive    was  to  establish  measures  to  safeguard  an  adequate 
security of gas supply level,  contributing  to  the functioning  of the internal  gas market.  This 
addressed the need to ensure a coherent and non-discriminatory approach among security of 
supply policies during the liberalisation of the energy market dominated by largely state-owned 
energy monopolies.  

This intervention aimed to avoid socio-economic consequences of supply disruptions, by:  

(1) establishing a common framework within which Member States were to define and align 

general, transparent and non-discriminatory security of supply policies;  
(2) clarifying the roles and responsibilities of the different market players, and;  
(3) implementing  non-discriminatory  procedures  to  safeguard  security  of  gas  supply,  by 

coordinating and information exchange in the Gas Coordination Group.  

In  2009,  the  Commission  proposed  a  revision  to  address  the  immediate  risk  of  disruptions 
resulting  from  the  Russian-Ukrainian  gas  crisis  of  200923.  This  second  intervention 
complemented the existing objectives and was meant to make the EU less vulnerable to external 
supply shocks and clarify roles and responsibilities.  

Its specific objectives therefore were to: 

(1) Achieve  flexibility  in  the  internal  gas  market  to  mitigate  most  supply  disruptions,  by 

creating sufficient infrastructure to deal with such disruptions.  

(2) Have more effective crisis management and cooperation during emergencies, with pre-
defined plans. This meant fostering solidarity among Member States, aligning national 
measures and ensuring they did not harm other Member States. 

(3) Guarantee  supplies  to  vulnerable  customers  via  supply  and  infrastructure  standards 
during  challenging  climatic  episodes,  constrained  supply  conditions,  or  disrupted 
infrastructure scenarios. 

The general objective of the latest revision resulting in Regulation (EU) 2017/1938 (the Gas 
Security of Supply Regulation), and the focus of this fitness check, was to make the EU more 
resilient, with an adequate level of preparedness to supply disruptions and mitigate any effect 
of severe crises in a spirit of solidarity24.  

More specifically, it aimed to:  

22 Directive 2004/67/EC 
23 See impact assessment COM(2009) 363, accompanying the proposal for Regulation (EU) No 994/2010. 
24 See impact assessment SWD(2016) 25, accompanying the proposal for Regulation (EU) 2017/1938. 

7 

 
 
 
(1)  enhance regional cooperation, as well as ensure EU-wide cooperation during crises, in 

a spirit of solidarity; 

(2)  improve transparency, by sharing information of contracts with non-EU countries; 
(3)  improve  the  infrastructure  standard  and  reverse-flow  obligations  to  improve  the 

flexibility of the system;25 

The proposed EU action primarily included the legislative input for the Gas Security of Supply 
Regulation, as well as financial and human resources needed to implement the Regulation, in 
particular for Member States. More specifically, these inputs encompassed financial and human 
resources needed by:  

(1) Member States and the Commission to implement the objective of the Gas Security of 

Supply Regulation. 

(2) ENTSOG to comply with regulated tasks such as the security of supply simulation. 
(3) Energy  undertakings  to  comply  with  obligations  such  as  the  supply  standard  and 

increased reporting requirements if a crisis level would be declared.  

Several activities were planned to be conducted as part of the regulatory intervention set by the 
Gas  Security  of  Supply  Regulation  to  assess  risks,  establish  plans,  ensure  adequate 
infrastructure, and create effective crisis management procedures, such as: 

•  An EU-wide security of supply simulation was performed by ENTSOG based on which 
national  and  common  risk  assessments  by  Member  States  were  established  and 
coordinated in the regional risk groups. The main supply disruption scenarios have been 
updated annually in the ENTSOG’s Winter Supply Outlook since 2018. 

•  Preventive  Action  Plans  (PAPs)  and  Emergency  Plans  (EPs)  were  required  to  be 
established  by  Member  States  by  1  March  2019,  based  on  the  risk  assessments.  The 
plans must be updated at least every four years.  

•  For the infrastructure standard, Member States, national regulatory authorities (NRAs), 
ACER, and the Commission were expected to assess and check the possible investment 
needs to implement the N-126 and bidirectionality requirements.  

•  Crisis management procedures were established, and crisis management was expected 
to be discussed regularly in the Gas Coordination Group (GCG), in addition to regular 
coordination and information exchange that took place in these meetings.  

•  Bilateral solidarity agreements were expected to be established by Member States with 

each other, by 1 December 2018.  

25  A  fourth  specific  objective  of  the  2016  Impact  Assessment  accompanying  the  Commission  proposal  was 
enlarging  the  geographical  scope  to  the  Energy  Community.  However,  in  the  final  Regulation  these 
obligations  were  replaced  by Article  16,  only  stating  areas  where  Member  States  may  cooperate  with  the 
Energy Community. Given that the objective has not really been taken up in the final Regulation, it has largely 
been left out of this fitness check.  

26 The N – 1 formula describes the ability of the capacity of gas infrastructure to satisfy total gas demand in the 
calculated area in the event of disruption of the single largest gas infrastructure during a day of exceptionally 
high gas demand occurring with a statistical probability of once in 20 years. 

8 

 
 
 
•  A report reviewing the Regulation was required to be published by the Commission, by 

1 September 2023. 

The expected outcome of the Gas Security of Supply Regulation in the short-term, medium-
term and long-term were: (i) to increase the EU’s preparedness for crises; (ii) improved security 
of  supply;  and  (iii)  enhance  the  resilience  of  the  EU  gas  system  to  crisis  situations.  Further 
details on these outputs, results, and impacts are set out below.  

•  Short-term  outputs  included:  (i)  regular  GCG  meetings  and  established  regional 
cooperation in regional risk groups; (ii) the security of supply simulation and seasonal 
outlooks  by  ENTSOG;  (iii)  developed  bi-directional  capacities;  (iv)  updated  risk 
assessments and plans; (v) established bilateral solidarity agreements. 

•  Medium-term results and long-term impacts included: (i) increased regional and EU-
wide cooperation; (ii) enhanced preparedness and resilience to crises through the supply 
standard; (iii) improved plans and crisis management procedures. Other expected results 
and impacts included: (i) increased transparency of measures taken by Member States; 
(ii) improved reverse flow capabilities; (iv) and a coordinated EU response to potential 
supply cuts.  

There were several external factors and other policy interventions that affected the outcomes, 
results and impacts  of the evaluated Regulations, as will be explained  the section “External 
factors  that  influenced  security  of  electricity  and  gas  supply  beyond  the  Regulations”.  In 
addition to those, the rules governing EU gas markets, and in particular  the old Gas Market 
Regulation and Gas Market Directive27, as well as their revised versions following the adoption 
of the Hydrogen and Gas Market Decarbonisation Package in 2024, also had direct implications 
for the EU security of gas supply28.  

27 Regulation (EC) 2009/715 and Directive (EC) 2009/73. 
28 Regulation (EU) 2009/1789 and Directive (EU) 2024/1788. 

9 

 
 
 
Figure 2: Intervention logic: Gas SoS Regulation  

10 

 
 
 
2.1.2. Intervention logic: Electricity Risk-Preparedness Regulation 

The EU’s policy on security of electricity supply has evolved alongside the development of a 
more  interconnected  and  decarbonised  energy  system.  The  urgency  for  greater  coordination 
became evident after a major blackout in Italy in September 2003. In response, the Commission 
proposed  a  directive  that  became  Directive  2005/89/EC,  which  required  Member  States  to 
secure  reliable  supply,  assess  potential  risks,  and  ensure  adequate  generation  capacity  and 
transmission  infrastructure.  Largely  non-prescriptive  and  limited  to  general  principles,  the 
provisions  of  this  Directive  were  found  insufficient  to  cope  with  the  growing  integration  of 
electricity markets. 

Four general problems were identified in the impact assessment as part of the Clean Energy 
Package29, which led to the repeal of the old Security of Electricity Supply Directive. Out of 
these four, only two were related to security of supply: (i) uncertainty around future investment 
in power generation; and (ii) the fact that Member States were not adequately considering the 
impact  of  their  actions  on  neighbouring  countries  during  electricity  crises30.  Two  general 
objectives  were  formulated  to  remedy  these  problems  (i)  promoting  the  development  of 
necessary  resources  to  ensure  security  of  supply;  and  (ii)  enhancing  cooperation  and 
coordination among countries to better handle system stress and crises31.  

The first general problem  was taken up in the Electricity Regulation and  is thus beyond the 
scope of this fitness check (except from a consistency perspective, cf. section 4.1). 

The second general problem was further broken down into three sub-problems:  

(1) “Crisis plans and actions solely national in focus”,  
(2) “Lack of information sharing and transparency”,  
(3) “No common approach to identify and assess risks”.  

Consequently, 3 sub-objectives had been derived:  

(1) “Improving risk assessments and preparedness”,  
(2) “Improving transparency and information sharing”,  
(3) “Improving coordination in an emergency”.  

These objectives were all taken up in the Risk Preparedness Regulation. 

29 COM(2016) 860 final 
30 The exact wording in the impact assessment was: (1) “Uncertainty about sufficient future generation investments 
and uncoordinated capacity markets”, and (2) “Member States do not take sufficient account of what happens 
across their borders when preparing for and managing electricity crisis situations. 

31 The exact wording in the impact assessment was: (1) “Facilitate investments in the right amount and type of 
resources  to  ensure  security  of  supply,  whilst  limiting  the  distortive  effects  of  uncoordinated  capacity 
mechanisms”, and (2) “Improve Member States’ reliance on each other in times of system stress and reinforce 
their coordination and cooperation at times of crisis situations”. 

11 

 
 
 
The  proposed  EU  action  included  the  legal  input  of  the  Electricity  Risk  Preparedness 
Regulation,  as  well  as  financial  and  human  resources  to  implement  the  Regulation.  These 
resources  encompass:  (i)  financial  and  human  resources  needed  by  Member  States,  the 
Commission and ACER to implement the legislative input of the Risk Preparedness Regulation; 
and  (ii)  financial  and  human  resources  needed  by  ENTSO-E  and  RCCs  to  comply  with 
regulated tasks, such as elaborating various methodologies and performing various adequacy 
assessments. While the Commission  and ACER were reinforced in  previous  years, it is still 
insufficient to accomplish all the tasks.  

Several activities were planned to achieve the Regulation’s goals: 

the designation by Member States of a competent authority; 

• 
•  ENTSO-E’s  elaboration  of  methodologies  for  identifying  regional  electricity  crisis 

• 

scenarios and for short-term and seasonal adequacy assessments32 ; 
• 
the identification and update by ENTSO-E of regional electricity crisis scenarios; 
•  Seasonal adequacy assessments by ENTSO-E twice per year (the so-called winter and 
summer supply outlooks), and by RCCs of short-term adequacy assessments on a daily 
basis for the next seven days; 
the  identification  by  Member  States  of  the  national  electricity  crisis  scenarios, 
preceding the establishment of Risk Preparedness Plans; 
the  support  provided  by  the  Commission  to  Member  States  (e.g.,  opinions  on  risk 
preparedness plans, Electricity Coordination Group’s (ECG) secretariat, and guidance 
on the cooperation and assistance provisions);  
the  monitoring  by  ACER  of  security  of  supply  measures  on  an  ongoing  basis,  with 
regular reports to the ECG; 
• 
the effective monitoring of security of supply in the EU via the ECG; 
•  a Commission report reviewing the Regulation by 1 September 2025. 

• 

• 

To mitigate the risk of external shocks and spillovers, Energy Community Contracting Parties33 
were  encouraged  to  collaborate  with  EU  Member  States  in  assessing  risks,  developing 
preventive plans, and establishing emergency response plans. 

There  were  several  expected  outcomes.  In  the  short-term,  the  outputs  included  28  Risk 
Preparedness Plans (with 28 Commission’s opinions)34, one methodology to identify regional 
electricity  crisis  scenarios,  an  assessment  of  regional  electricity  crisis  scenarios,  one 
methodology for short-term and seasonal adequacy assessments, seasonal adequacy outlooks, 

32  Article  9  of  the  Regulation  requires  “all  short-term  adequacy  assessments,  whether  carried  out  at  national, 
regional or union level”, which also include the adequacy assessments performed under the System Operation 
Guidelines, according to which each TSO need to perform summer and winter outlooks as well as day-ahead 
and intraday adequacy assessments (art.105-107). 

33  Contracting  parties  are  Albania,  Bosnia  and  Herzegovina,  Kosovo,  Montenegro,  North  Macedonia,  Serbia, 

Moldova, Ukraine, Georgia. 

34 27 EU Member States + Northern Ireland. 

12 

 
 
 
weekly and daily adequacy assessments, and regular ACER reports on security of electricity 
supply. 

In the medium-term, the expected result was better preparedness of Member States for crises at 
a lower cost through enhanced regional coordination and harmonised methodologies for risk 
assessments.  It  was  expected that  this  would translate into long-term  impacts,  such  as more 
transparency and legal certainty for businesses and investors or a strengthening of the “internal 
electricity  market  by  enhancing  trust  and  confidence  across  Member  States  and  ruling  out 
inappropriate  state  interventions  in  electricity  crises”.  The  2016  impact  assessment  also 
forecasted that, thanks to enhanced coordination, “the overall cost of the system would decrease 
(…) and could have a positive impact on prices for consumers”. Ultimately, the main long-term 
impact foreseen was an enhanced EU-wide resilience to possible electricity crises. 

The Clean Energy Package included other policy interventions, which were also intended to 
support EU security of electricity supply notably through market-based measures, such as the 
Electricity Directive, the Electricity Regulation and the ACER Regulation35 that were proposed 
simultaneously with the Risk Preparedness Regulation. Later, some other policy interventions 
in  response  to  the  2021/2023  also  may  have  impacted  the  results  of  the  Risk  Preparedness 
Regulation, in particular: (i) the Energy Storage Recommendation; (ii) the revamped electricity 
market design rules; (iii) the emergency intervention to address high electricity prices. Lastly, 
it should be noted that some technical aspects of EU’s security of electricity supply are governed 
by network codes36.  

35 Respectively Directive (EU) 2019/944, Regulation (EU) 2019/943 and (Regulation (EU) 2019/942). 
36 Regulation (EU) 2017/2196 establishing a network code on emergency and restoration; and Regulation (EU) 

2017/1485 establishing a guideline on electricity transmission system operation. 

13 

 
 
 
Figure 3: Intervention Logic: Risk Preparedness Regulation 

14 

 
 
2.1.3. Other energy policies and external factors that influenced security of electricity and 
gas supply beyond the Regulations 

There are a number of other energy policies that influenced the security of electricity and gas 
supply. The most significant of these were:  

•  The  Energy  Efficiency  Directive,  Renewable  Energy  Directive,  and  various  climate 
initiatives  adopted  in  2018,  which  accelerated  the  clean  energy  transition,  thereby 
reducing the need to resort to imported fossil fuels like natural gas.  

•  Other  important  interventions  are  the  Regulation  on  guidelines  for  trans-European 
energy  infrastructure  (TEN-E),  amended  in  2022,  which  provides  the  framework  for 
identifying and developing cross-border energy infrastructure projects of common and 
mutual interest (PCIs and PMIs) in the EU. One of its objectives is to enhance security 
of  supply  by  supporting  construction  of  energy  infrastructure  and  improving 
interconnectivity  of  Member  States37.  The  Connecting  Europe  Facility  (CEF)  may 
provide financial support to such projects, helping to accelerate their implementation 
and bridge investment gaps. 

•  Moreover,  the  Governance  Regulation38  from  2018  endowed  the  Energy  Union  with 
common  rules  for  planning,  reporting  and  monitoring,  through  national  energy  and 
climate  plans  (NECPs)  or  long-term  strategies.  Commission  guidance  to  Member 
States39  also  underlined  the  need  for  updated  NECPs  to  reinforce  preparedness  and 
strengthen measures for collective energy security. 

In  addition  to  changes  to  the  energy  acquis,  other  EU  interventions  had  an  impact  on  EU 
security of gas and electricity supply:  

• 

In the field of critical infrastructure protection for instance, the Recommendation on a 
Union-wide coordinated approach to strengthen the resilience of critical infrastructure 
(2023/C20/01)  asked  Member  States  to  support  operators  of  critical  energy 
infrastructure in conducting stress tests, and the Directive on the Resilience of Critical 
Entities (EU) 2022/2557 put forward new rules to strengthen the resilience of critical 
entities in several sectors, including energy.  

•  Moreover, Directive 2022/2555 on measures for a high common level of cybersecurity 
across  the  Union  (the  NIS2  Directive)  aims  to  ensure  the  cybersecurity  resilience  of 
entities from the energy sector. In addition, products with digital elements, including 
hardware  and  software  deployed  by  energy  operators  falls  under  the  newly  adopted 

37 The TEN-E Regulation excludes natural gas projects since its revision in 2022. 
38  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. 

39 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and 

climate plans (2022/C 495/02). 

15 

 
 
 
Cyber  Resilience  Act  (Regulation  (EU)  2024/2847),  which  entered  into  force  on  10 
December 2024. 

Several external factors have also affected the actual results and impacts of both interventions 
since their adoption. The COVID-19 pandemic (2019-2021) exerted considerable pressure on 
the whole energy sector, both on the demand side (by causing a wide departure from normal 
consumption patterns) and on the supply side (for example, through delayed maintenance on 
power plants due to COVID-19 related measures). In response to these events, the Commission 
published a staff working document in June 2020 on good practices and lessons learnt for the 
energy sector40.  

The  second  external  event  was  the  energy  crisis  that  started  towards  the  end  of  2021  and 
affected  the  results  of  the  interventions  by  putting  the  EU’s  energy  sector  under  historical 
pressure due to a combination of three unrelated events:  

(1) Russia’s full-scale invasion of Ukraine which resulted in considerable uncertainty over 
gas supply, with an indirect impact on electricity supply, due to the weaponisation of gas 
(the impacts on gas security of supply will be further detailed in chapter 3 “How has the 
situation evolved over the evaluation period?”). 

(2) Low hydro reservoir levels due to droughts and low precipitation levels, with the worst 

conditions materialising during winter 2022/2023 (cf. Figure 4). 

(3) The stress corrosion crisis that affected the French nuclear fleet, which, in combination 
with maintenance delays due to COVID-19, resulted in a historical drop in the output 
from nuclear plants, from 361 TWh in 2021 to 279 TWh in 202241. 

Figure 4: Minimum aggregated filling rate of water reservoirs and hydro storage plants in 
all ENTSO-E members 

Source: JRC, based on ENTSO-E. 

40 SWD(2020) 104 final. 
41 See: https://www.senat.fr/rap/r23-714-1/r23-714-149.html#toc1641 

16 

 
 
 
 
 
The additional policy interventions and external events listed have had an important impact on 
the EU security of supply, and have to be taken into account when assessing the effectiveness 
of the Gas Security of Supply Regulation and the Electricity Risk-Preparedness Regulation. 

2.2 Point(s) of comparison (baseline) 

This fitness check evaluates the performance of the EU-level interventions against its policy 
objectives,  in  line  with  the  Better  Regulation  Guidelines.42  The  policy  objectives  that  the 
performance of the EU-level policy intervention will be evaluated against, have been further 
elaborated on in the intervention logic of section 2.1. 

In  addition,  this  fitness  check  uses  the  prior  impact  assessments  carried  out  in  2016  for  the 
evaluated Regulations to construct a qualitative point of comparison. In particular, the expected 
results and impacts of the policy action will be used to compare the actual results and impacts 
of the regulations. The points of comparisons have been adapted where the final act adopted by 
the  co-legislators  differs  significantly  from  the  impact  assessments  accompanying  the 
Commission’s original proposal. 

The  expected  results  and  impacts  of  the  Risk  Preparedness  Regulation  and  Gas  Security  of 
Supply Regulation have been further detailed in the respective intervention logics (c.f figure 2 
and figure 3). These expected results and impacts notably include: 

• 

• 

Improved preparedness of EU Member States and undertakings to possible gas supply 
shocks or electricity crises at lower costs, especially to ensure protection of critical and 
vulnerable energy consumers. 
Increased transparency of measures taken by Member States during crises, in particular 
in case they have a cross-border dimension during crises. 

•  Enhanced European resilience to crises due to coordination and information sharing via 

• 

e.g. the Gas and Electricity Coordination Groups. 
Improved regional  cooperation through  e.g.  regional  risk groups and developing and 
assessing regional crisis scenarios. 

•  Harmonised methodologies and risk assessments among Member States. 
• 

Increased awareness and monitoring of extreme weather situations and potential fuel 
shortages for electricity. 

•  Flexibility  in  gas  infrastructure  and  effective  reverse  flows  due  to  bi-directional 

capacities in case of supply disruptions. 

•  Coordinated EU response to crises due to possible supply shocks and crises. 

42  Better  Regulation  Guidelines  (SWD  (2021)  305)  p23  states:  “A  fitness  check  assesses  whether  a  set  of 

interventions is fit for purpose by assessing its performance against its policy objectives.” 

17 

 
 
 
 
3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1.   Evolution of EU security of gas and electricity supply (2017-2024) 

Since 2017, the EU’s energy landscape has undergone significant changes, with an ongoing rise 
in  deployment  of RES. The share of renewables has  risen from 18.4% in 2017 to  24.5% in 
202343. At the same time, the use of fossil fuels has been substantially reduced: coal for instance 
decreased from 18.6% in 2000, to 14.7% in 2017, declining further to 9.6% in 2023.44 Fossil 
fuels remain however dominant in the EU energy mix. 

Figure 5: EU energy mix (gross inland consumption) 

Source: ENER Chief Economist Unit based on Eurostat (nrg_bal_c) 

There is a similar trend in electricity power generation, where domestically produced renewable 
energy is increasingly replacing imported fossil fuels, with a significant increase in electricity 
generated from solar PV (from 3.6% in 2017 to 9.4% in 2024) and wind (11.2% in 2017 to 
18.5% in 2024).  

At the same time, electrification has not seen much progress. While the electrification rate of 
final consumption has risen by ca. five percentage points since the ‘90s, it has remained stable 
throughout  the  evaluation  period,  at  slightly  below  24%  (Figure  6).  As  of  2024,  electricity 
accounts  for  approximately  23%  of  the  European  Union's  final  energy  consumption.45 
Electrification rates per sector and per country show similar patterns.  

43 Most recent annual data available at the time of writing on Eurostat is from 2023. Energy mix is measured in 
terms of the share in gross inland consumption (nrg_bal_c). The figures for the share of RES is in contrast 
taken from Eurostat’s nrg_ind_ren, based on the definition of the Renewable Energy Directive. 

44 Based on Eurostat (nrg_bal_c) 
45 COM(2025) 79 final 

18 

 
 
 
 
 
Figure 6: Electrification rate of final consumption in the EU 

Source: ENER Chief Economist, based on EUROSTAT data. 

In  parallel,  the  interconnectedness  of  the  EU  electricity  market  continued  to  grow  over  the 
implementation period for most regions46. As shown in figure 7, for instance, the share of cross-
border exchanges over EU electricity demand significantly improved on average, from 34% in 
2017 and 31% in 2019 (when the Risk Preparedness Regulation came into force) until 40% in 
2024  with  a  peak  at  43%  in  2022.  At  the  same  time,  some  bottlenecks  for  cross-border 
exchanges remain, in particular for the Iberian Peninsula as well as islands. Several Member 
States are still below the Governance Regulation’s 15% interconnection target, while ACER 
finds that 32 GW of cross-border capacity needed by 2030 remain unaddressed.  

Figure 7: Evolution of the share of cross-border exchanges (net positions) over electricity 
demand in EU bidding zones – EU-27 average (2016-2024) 

Source: ACER 

46 For example, work is ongoing to  have more interconnections between the Iberian  Peninsula with the rest of 
Europe. A High-Level Group on interconnections for South-West Europe exists and adopted an Action Plan 
for  extended  cooperation  in  the  High-Level  Group  on  Interconnections  for  South-West  Europe  to  be 
completed by 2030. 

19 

 
 
 
 
 
Most  of  the  installed  electricity  generation  capacity  remains  centralised,  with  decentralised 
generation  accounting for around 18% of the total  installed capacity in  2024 (c.f. table  2  in 
Annex  2)47.  It  should  be  noted  however  that  there  are  some  uncertainties  regarding  the 
exactitude of the figures, because of high discrepancies across databases. 

The  EU  is  largely  import-dependent  for  natural  gas,  which  has  been  further  exacerbated  by 
declining domestic production48. Russia has historically been the dominant supplier to the EU, 
mainly via pipeline, representing 45% of overall EU imports (ca. 150 bcm) before its full-scale 
invasion of Ukraine. Norway has since then become the EU’s main supplier, representing 33% 
of imports in 2024 (ca. 91 bcm/y), followed by Russia with 19% (ca. 52 bcm/y) and the US 
with  17%  (ca.  45  bcm/y).  Despite  declining  gas  demand,  EU  import  dependency  of  gas 
increased  from  60%  in  2017  to  79%  in  202349,  with  a  peak  of  85%  in  2022,  largely  due  to 
decreasing domestic production, which decreased from 89 bcm/y in 2017 to 39 bcm/y in 2023. 
Currently, several Member States have successfully decreased their dependence on Russian gas 
imports or managed to entirely eliminate them.50   

Figure 8: EU natural gas imports (pipeline and LNG) 

Source: ENER Chief Economist Unit, based on ENTSOG and Refinitiv  

LNG has become increasingly important  since Russia’s full-scale invasion of Ukraine, with 
37%  of  gas  imports  coming  from  LNG  in  2024,  compared  to  10%  in  2017.  This  has  been 
facilitated by a significant increase in LNG import capacity, which grew significantly in recent 
years (e.g. by 70 bcma in 2023-2024). The EU’s main LNG supplier in 2024 was the US (46% 
of LNG imports). Russia still covered 20% of the EU’s LNG imports in  2024, followed by 
Qatar  with  12%.51  In  this  light,  the  Commission  adopted  in  May  2025  the  REPowerEU 
Roadmap52, followed by a legislative proposal in June 202553, in order to end dependency on 
Russian gas by 2027.  

47 Decentralised capacities refers to capacities that are connected to low and medium voltage networks. 
48 Eurostat – nrg_cb_gas 
49 European Commission Joint Research Centre calculation, based on Eurostat– nrg_cb_gas 
50 For example, Estonia, Lithuania and Latvia prohibited the supply of natural gas from Russia.  
51 Increased overall LNG imports have been facilitated by additional regasification capacities through new FSRUs, 

as further detailed in section 3.3. 

52 COM(2025) 440 final 
53 COM(2025) 828 final 

20 

 
 
 
 
 
Figure 9: Natural gas imports share LNG/pipeline 

Source: Commission’s Joint Research Centre, based on ENTSOG TP and GIE ALSI+  

The EU significantly diversified gas supplies over the evaluation period, as indicated by Figure 
1054. This improvement is significant in pipeline supply diversification due to the phase out of 
the dependence on Russian gas but partly mitigated by an increase in concentration of LNG 
supplies.  The  main  reason  for  the  improved  diversification  is  the  completion  of  key 
infrastructure projects that allowed Member States to eliminate or reduce their dependence on 
Russian pipeline supplies which used to be the main cause of the relatively high concentration 
pre-crisis.  

Figure 10: HHI index for gas import origins 

Source: Commission Joint Research Centre, based on Eurostat nrg_ti_gas and nrg_te_gas 

54 The gas import origin concentration index shows in one figure how varied import origins of energy sources are. 
It is based on the Herfindahl-Hirschman index (HHI) principle, i.e. adding the square of the shares of every 
origin in the total import.  This indicator lies in the  interval [0, 1]. Lower values of this index mean more 
diversified origins, higher values mean more concentrated origins. Calculations based on EUROSTAT data 
nrg_ti_gas and nrg_te_gas. 

21 

 
 
 
 
 
 
Since 2000, the EU's annual demand for natural gas has fluctuated between 446 bcm (2010) 
and ca. 330 bcm (2024).55 Before the turbulence in energy markets in 2022, the use of natural 
gas  was  relatively  stable.  Overall  gas  consumption  in  the  EU  was  408  bcm  in  2017,  which 
varied  in  the  following  years  mostly  due  to  temperature  variations  during  winter,  before 
reducing drastically to 363 bcm in 2022 and further to 330 bcm in 2024. It should be noted that 
there  are  large  geographical  discrepancies  in  natural  gas  consumption.  For  example,  the  5 
largest  gas  consuming  Member  States  (Germany,  Italy,  France,  the  Netherlands  and  Spain) 
represented more than 70% of EU gas consumption in 2022.  

Figure 11 : EU27 absolute natural gas demand (LHS) and its share in the energy mix (gross 
inland consumption) (RHS) 

y
/
m
c
b

 500
 450
 400
 350
 300
 250
 200
 150
 100
 50
 -

30%

25%

20%

15%

10%

5%

0%

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

Absolute gas demand (LHS)

Gas in energy mix (RHS)

Source: Eurostat (nrg_cb_gas) 

While in 2000 natural gas represented 20.6% of the EU’s energy mix56, it first rose to 22.3% in 
2017, and then started to decline from 23.9% in 2021 to 20.9% in 202357. As will be discussed 
in greater detail in chapter 4, the most significant change in gas consumption was caused by the 
crisis response to supply cuts from Russia, driven by efforts to reduce gas demand to counter 
the dwindling pipeline supplies from Russia.  

55 Annual gas consumption data from Eurostat nrg_cb_gas series for the years of 2000 to 2023. Annual statistics 
for  2024  where  not  yet  available  at  time  of  writing,  so  were  calculated  by  adding  monthly  values  of  the 
nrg_cb_gasm series, which may lead to a slight discrepancy from the 2000-2023 data.  

56 Gross inland consumption. 
57 Annual statistics for 2024 are not yet available at the time of writing on Eurostat. 

22 

 
 
 
 
 
 
Figure 12: Trends in final gas prices for household and industrial consumers in the EU – 
2008-2023 (EUR cents/kW index change, 2008=100) 

Source: ACER calculations based on Eurostat58  

High energy prices in the last four years have been an important concern for consumers, both 
industries and households. While prices are influenced by many factors, having an adequate 
level of supply is one of the preconditions for affordable energy prices. EU average retail gas 
prices for households increased by almost  two thirds between 2021 and 2023. As shown by 
Figure  12,  the  energy  component  has  been  the  main  driver  of  the  surge  of  gas  prices  for 
consumers: its share was 15 percentage points higher in 2022 and 2023 compared to 2021. The 
increase was even higher in absolute terms, as in 2023 the energy component had more than 
doubled compared to 2021 levels (7.2 EUR cents/kWh versus 3 EUR cents/kWh respectively). 

Figure 13: Breakdown of average gas price for households in EU-27 – 2019-2023 (%) 

Source: ACER calculations based on Eurostat data59 

58 The index change tracks the percentage change in nominal prices since 2008, where the base year equals 100 %. Eurostat 
data: Band DC, 2 500–5 000 kWh (household electricity consumption, nrg_pc_204), and Band IE, 20 000–70 000 MWh 
(industrial electricity consumption, nrg_pc_205); updated in October 2025. 

59 Band D2, 20-200 GJ (Gas prices components for household consumers – annual data, nrg_pc_202_c) 

23 

 
 
 
 
 
There  has  been  a  significant  but  stable  degree  of  sectoral  integration  between  the  gas  and 
electricity  systems  over  the  evaluation  period.  This  is  notably  captured  when  looking  at  the 
share of natural gas used to produce electricity and the share of electricity production stemming 
from natural gas. Both indicators have slightly increased over the evaluation period, but have 
remained relatively stable, as shown in Figure 1460. In addition, despite accounting for 14 % of 
the electricity mix, natural  gas was the electricity price-setter in  40% of  hours in  the EU  in 
2024.61 This shows that security of gas and electricity supply remained closely interconnected 
over the evaluation period. 

Figure 14: electricity produced with gas (%) & gas used for producing electricity (%) 

Source: JRC, based on Eurostat data62 

Assessing  the  evolution  of  the  robustness  of  the  EU  electricity  system  requires  looking  at 
diverse and not always comparable data, given that there has been no crisis declaration since 
the entry into force of the Risk Preparedness Regulation. Seasonal outlooks prepare now with 
a common methodology to assess potential resource adequacy risks for the upcoming season 
and  provide  a  review  of  the  situation  in  the  previous  season.  However,  they  provide  this 
information based on estimations of two indicators, Energy Not Served (ENS) and Loss of Load 
Expectation  (LOLE).  Regarding  real  situation,  and  covering  not  only  short-term  resource 
adequacy  issues,  the  Nordic  and  Baltic  Regions,  publish  a  joint  annual  report  on  the 
disturbances observed on the electricity grids63. These figures, show that the power systems in 
these regions have evolved positively in the latest years as it is shown in Figure 15. No similar 
information  is  found  for  other  regions  to  do  a  factual  analysis  on  the  evolution  of  the 
disturbances, the impacted assets, the reason of them and their effect on electricity users. 

60  The  graph  does  not  refer  to  absolute  values.  The  volumes  of  gas  used  for  electricity  generation  logically 

decreased (since the total gas consumption has decreased, while the share remained stable). 
61 See: Key developments in European electricity and gas markets - 2025 ACER Monitoring Report 
62 From  supply, transformation and consumption of gas annual balance (nrg_cb_gas), the following categories 
were  used  to  calculate  the  share  of  natural  gas  used  to  produce  electricity:  TI_EHG_MAPE_E, 
TI_EHG_MAPCHP_E, TI_EHG_APE_E, TI_EHG_APCHP_E and IC_CAL 

63See: HVAC_NORDIC_AND_BALTIC_GRID_DISTURBANCE_STATISTICS_2023.pdf 

24 

 
 
 
 
 
Figure 15: year moving average - ENS divided by consumption (ppm), 2014-2023. Parts per 
million (ppm) represents ENS (MWh) as proportion of consumed energy (TWh) 

Source: Commission, based on HVAC Nordic and Baltic grid disturbance statistics 2023.  

On 28 April 2025, Spain and Portugal were affected by a  major incident  on their electricity 
systems, which resulted in one of the biggest blackouts64 in recent EU history affecting both 
countries and parts of France65. Both Iberian countries immediately declared a crisis. Both Spain 
and Portugal  submitted a report  within 3 months  assessing  the causes,  impacts  and possible 
improvements, based on the Risk Preparedness Regulation. Spain and Portugal presented their 
findings on 30 July to the Electricity Coordination group, in line with the Risk Preparedness 
Regulation.  Both  Spain  and  Portugal  noted  that  the  incident  had  a  multifactorial  origin, 
including  insufficient  voltage  control  capability,  constraints  from  power  oscillations,  and 
disconnections caused surge in voltage.  

Additionally, an expert panel has been set up to investigate this event in accordance with EU 
law. It is chaired by representatives of two TSOs from non-affected countries and involves other 
TSOs as well as ACER and NRAs. A factual report with all the data was published on 3 October 
202566. A final report with conclusions and explanations of the reasons for the incident as well 
as recommendations will be published in the coming months. 

Public  information  on  absolute  numbers  of  cyberattacks  on  the  energy  sector  is  scarce. 
Information on cyberattacks is usually not published openly. Most public reports in the past two 
years  point  to  financially  driven  motivation  (ransomware)  without  relevant  impact  in  the 
reliability  of  energy  supply.  Nevertheless,  the  sector  defines  scenarios  for  incidents  that  are 

64 This incident has been classified as Scale 3 in the Incident Classification Scale from ENTSO-E (ranging from 0 

to 3). 

65 https://www.entsoe.eu/news/2025/04/28/grid-incident-in-the-power-systems-of-spain-and-portugal/ 
66 

https://eepublicdownloads.blob.core.windows.net/public-cdn-container/clean-

documents/Publications/2025/entso-e_incident_report_ES-PT_April_2025_06.pdf 

25 

 
 
 
 
much broader than ransomware with the intention of protecting the infrastructure against, for 
example, interruption of supply or cyberespionage. ENISA provides trends on a quarterly or 
yearly  basis  (see  Figure  16)  and  other  authoritative  sources  like  the  Danish  SektorCERT,67 
reported successful cyberattacks every year against a European energy or utility company since 
2015, with at least 20 attacks in 2022. 

Figure 16: Targeted sectors per number of cybersecurity incidents (July 2023-June 2024) 

Source: ENISA Threat Landscape 2024 report68 

Since 2022, the number of incidents involving sabotage or suspected sabotage have risen, in 
particular for critical undersea energy infrastructure, with three high profile cases (Nord Stream 
1 and 2 explosions, the Balticconnector pipeline and Estlink-2 power cable disruptions caused 
by dragged anchors).  

Additionally, the full-scale invasion of Ukraine has shown how vulnerable energy can be in 
conflict  scenarios.  Russia  is  conducting  systematic  attacks  on  Ukraine's  energy  facilities, 
including power plants and dams. These assaults have so far led to widespread power outages 
and significant challenges in maintaining energy stability. 

The number of extreme weather events of different sizes has increased significantly in the last 
years in Europe, as shown in Figure 17. Europe is warming faster than any other continent, with 
extreme heat becoming more frequent and contributing to wildfires. Precipitation patterns are 
changing, and droughts and floods are increasing in severity. Climate change will impact both 
energy  consumption  (e.g.  due  to  peak  consumption  periods  during  heat  waves),  as  well  as 

67  Cyber-attacks  against  European  energy  &  utility  companies,  September  2022.  https://sektorcert.dk/wp-
content/uploads/2022/09/Attacks-against-European-energy-and-utility-companies-2020-09-05-v3.pdf  

68 See: https://www.enisa.europa.eu/publications/enisa-threat-landscape-2024  

26 

 
 
 
 
electricity  generation  (e.g.  reduced  hydro  and  nuclear  generation  during  droughts  or  heat 
waves). The European Climate Risk Assessment69 concludes that the energy sector is projected 
to experience the strongest rise in infrastructure damage compared to transport, industry and 
the social sector.  

Figure 17: Number of extreme weather events in Europe 

Source: European Environment Agency70  

3.2.   State of play of implementation 

This section provides a summary of the implementation of the two evaluated regulations by 
Member States, the Commission and other regulated entities. More detailed overviews can be 
found in the dedicated reports reviewing the respective Regulations71. 

Looking at the EU’s neighbourhood, the Energy Community Secretariat releases annual reports 
and country-specific assessments on the implementation of the energy security acquis in the 
Energy Community Contracting Parties72. According to the 2024 report, the Contracting Parties 
have  achieved  an  overall  implementation  score  of  36%  on  energy  security  (a  decrease  of  5 
percentage points compared to 2023). This score reflects the implementation of the Electricity 
Risk-Preparedness Regulation (41%), the Gas Security of Supply Regulation (37%) and the Oil 
Stocks Directive (23%)73.  

3.2.1.  Gas Security of Supply Regulation 

The  Gas  Security  of  Supply  Regulation  included  several  requirements  and  instruments  to 
implement the Regulation. This section provides a state of play of the implementation of: 

•  The preparation and submission of preventive action plans, emergency plans, national 

risk assessments by Member States. 

69 See: European Climate Risk Assessment | Publications | European Environment Agency (EEA) 
70  Climate  Change,  impacts  and  vulnerability  in  Europe  2022,  European  Severe  Weather  Database  (ESWD), 
Copernicus  Emergency  Management  Service  (CEMS)  2022  Annual  report  and  International  Disaster 
Database (EM-DAT). (2022). EM-DAT Data. 
71 COM(2023) 572 final and COM(2025) 539 final. 
72 Albania, Bosnia and Herzegovina, Kosovo, Montenegro, North Macedonia, Serbia, Moldova, Ukraine, Georgia. 
73  See  EnC  2024  Implementation  report  -  Implementation  Report  -  Energy  Community  Homepage  (energy-

community.org) 

27 

 
 
  
 
 
•  The  preparation  and  submission  of  common  risk  assessments  by  Member  States  in 

regional risk groups. 

•  The publication of the Union-wide security of supply simulations by ENTSOG. 
•  Gas Coordination Group meetings.  
• 
•  The declaration of crisis levels by Member States. 
•  The solidarity agreements that were signed during the evaluation period. 

Implementation of the infrastructure standard and bi-directionality requirements. 

As one of the obligations of the Regulation Member States were required to submit their plans 
(gas Preventive Action and Emergency Plans) by 1 March 2019, as well as an update four years 
later on 1 March 2023. However, as part of the temporary Gas Demand Reduction Regulation74, 
Member States had to anticipate the update of their plans by 31 December 2022, in order to 
reflect  any  demand  reduction  measures  taken.  The  plans  had  to  be  developed  based  on  the 
national risk assessments, as well as the common risk assessment. All plans and all Common 
Risk Assessments have been submitted. However, only 7 of the two plans in the two cycles 
were  submitted  on  time  by  Member  States  and  only  1  out  of  12  Risk  Groups  submitted  a 
Common Risk Assessment on time in two cycles. Member States also were required to test their 
Emergency Plans, but the submitted EPs contain little information on the conclusions of these 
tests. This has been further elaborated on in the Commission’s report SWD(2023) 323.  

ENTSOG published 3 Union-wide security of supply simulations, on 21 November 201775, on 
30  November  2021  and  on  22  January  202576.  These  simulations  were  key  inputs  to  the 
Common  Risk  Assessments.  Moreover,  ENTSOG  published  two  seasonal  supply  outlooks 
every  year,  as  required  by  the  Gas  Regulation  (EU)  2024/1789,  including  an  extra  yearly 
outlook on 20 July 2022, to simulate a full Russian supply disruption. 

A  total  of  27  GCG  meetings  were  held  in  full  format  since  the  Gas  Security  of  Supply 
Regulation entered into force until the end of 202477. This was complemented by a series of 
meetings in restricted format78. During the energy crisis, meetings were held on a monthly or 
even weekly basis, mostly in restricted format.  

In 2023, the Commission launched 26 EU Pilots79 due to missing Common Risk Assessments 
(CRAs), Preventive Action Plans (PAPs) and Emergency Plans (EPs). In the meantime, 25 EU 
Pilots have been closed since the missing CRAs, PAPs and EPs have been submitted. 

74 Regulation (EU) 2022/1369 
75 Including an addendum to the Union-wide simulation published on 8 October 2020 
76 See: https://www.entsog.eu/security-of-supply-simulation  
77 See: Register of Commission expert groups and other similar entities (europa.eu) 
78 A priori a meeting in restricted format is limited to Member States and Commission only, with ad hoc invitations 

being extended to other participants when relevant.  

79 Cyprus is exempted from the obligation. 

28 

 
 
 
The infrastructure standard has been largely implemented by Member States, as indicated in 
Member States’ Plans. Only three Member States did not meet the N-1 standard in 202380, since 
Luxemburg, Sweden and Slovenia have an exemption from this obligation.  

The bi-directionality of EU infrastructure has significantly improved since 2017. As is further 
detailed  in  chapter  4  and  in  Figure  27,  the  average  bi-directionality  increased  steadily  since 
2017, which facilitated flows that reversed eastwards since the supply cuts from Russia in 2022. 
The Commission keeps an updated list of ongoing exemptions to the requirement on its website: 
23 IPs currently have an exemption.81 In 2020, the Commission decided82 that four exemptions 
had to be reviewed, as further outlined in Commission Report reviewing the Gas Security of 
Supply Regulation.83 Out of these four, two (Mosonmagyarovar, between Austria and Hungary; 
and  Murfeld  –  Ceršak,  between  Austria  and  Slovenia)  were  prolonged,  with  ACER  giving 
positive opinions84. One exemption (Karksi, between Estonia and Latvia) became obsolete, as 
a result of a PCI project; and for the fourth one (Blaregnies – Tasnières (H), between Belgium 
and  France),  no  request  for  prolongation  was  officially  submitted  yet  by  the  Competent 
Authorities, despite the deadline set by the abovementioned decision of 31 January 2022.85  

On 23 July 2024, Bundesnetzagentur adopted a decision regarding the expiring86 exemption for 
the  interconnection  point  "Deutschneudorf  EUGAL"  between  Germany  and  the  Czech 
Republic, arguing that there was no need to pursue the exemption, based on an alleged revised 
understanding  of  the  concept  permanent  physical  bi-directional  capacity.  Following  an 
invitation to react in ACER’s opinion87, the Commission adopted88 a decision requesting the 
modification of the coordinated decision and clarifying that “in the context of Regulation (EU) 
2017/1938,  the  concept  of  ‘physical  bi-directional  capacity’  means  the  physical  capacity  to 
transport gas in both directions in any circumstances, as it cannot be considered without the 
element of permanence required by the Union legislator.”. 

Lastly,  in  December  2023,  Czech  and  Polish  authorities  requested  an  extension  of  the 
exemption until December 2025, to provide enough time for the TSO to identify and implement 
the best infrastructure solutions to implement the reverse flow obligation. On 9 December 2024, 
ACER  adopted  a  positive  opinion89  on  the  matter  but  recommended  “NET4GAS  to  follow 
developments regarding the understanding of the concept of permanent physical bi-directional 

80 See Figure 41 in Annex II 
81 See https://energy.ec.europa.eu/system/files/2021-05/table_reverse_flows_-for_publication_0.pdf  
82 See Commission Decision C(2020) 6600 
83 See Staff Working Document SWD(2023) 323 accompanying Report COM(2023) 572. 
84 ACER opinions No 01/2022 and 02/2022 from February 2022. 
85  Moreover,  two  pairs  of  Member  States  have  merged  their  national  networks  into  single  balancing  zones: 

Denmark and Sweden, and Latvia and Estonia. 

86 Exemption expired February 2024 
87 Opinion No 06/2024. 
88 Commission decision requesting  modifications of the coordinated decision between Germany and the Czech 
Republic regarding the permanent physical bi-directional capacity at the cross-border interconnection point 
“Deutschneudorf EUGAL Brandov”, 26 February 2025, C(2025) 1337 final. 

89 Opinion No 08/2024. 

29 

 
 
 
capacity”. On 10 April 2025, the Commission adopted a new decision confirming that “merely 
allowing physical reverse flows at an interconnection point in the event of a gas supply crisis 
(…) is neither in line with the text nor with the objectives of the Regulation (EU) 2017/1938” 
and requesting the competent authorities to modify the coordinated decision so as to ensure that 
the  duration  of  the  exemption  covers  the  period  for  which  the  gas  can  only  be  flown  in 
emergency situations90. 

Following these Commission’s decisions, the two coordinated decisions were revised by the 
competent authorities accordingly. 

A  total  of  13  ‘Early  Warnings’,  2  ‘Alerts’  and  1  ‘Emergency’  were  declared  during  the 
evaluation period from 2017 until 2024. The majority were declared during the energy crisis, 
notably due to supply cuts from Russia that occurred in 2022, as outlined in Figure 18. The only 
emergency was declared by Italy in 2017 after the explosion  at the Baumgarten compressor 
station in Austria, which was lifted 3 days later.  

Figure 18: crisis level declaration by Member States (2017-2025) 

Source: European Commission, based on Member States’ notifications 

A total of 9 bilateral solidarity agreements were signed between Member States, falling short 
of the total of 40 agreements required. Member States were required to conclude these bilateral 
solidarity agreements by 1 October 2018. Solidarity agreements were signed between: 

•  Germany and Denmark (14 December 2020); 
•  Germany and Austria (2 December 2021); 
•  Estonia and Latvia (4 January 2022); 

90 Commission decision requesting modificatins of the coordinated decision between Poland and Czech Republic 
regarding  the  permanent  physical  bi-directional  capacity  at  the  cross-border  interconnection  point 
“Cieszyn/Český Těšín Stork I”, 10 April 2025, C(2025) 2243 final. 

30 

 
 
 
 
•  Lithuania and Latvia (10 March 2022); 
• 
Italy and Slovenia (22 April 2022); 
•  Finland and Estonia (25 April 2022); 
•  Denmark and Sweden (8 May 2023); 
•  Slovenia and Croatia (14 July 2023), and; 
•  Germany, Italy and Switzerland (19 March 2024). 

The Commission launched 27 infringement procedures91 in 2021 due to the lack of bilateral 
solidarity agreements. Several of them were put on hold when the obligation turned into a “best 
efforts” clause after the application of default solidarity provisions, since the entry into force of 
Regulation (EU) 2024/1789. All these cases were closed on 12 February 2025. 

3.2.2.  Electricity Risk Preparedness Regulation 

The Electricity Risk Preparedness Regulation included several requirements and instruments to 
implement the Regulation. This section provides a state of play of the implementation of: 

•  Appointment by Member States of a Competent Authority. 
•  Development of methodologies for short-term and seasonal adequacy assessments and 

regional crisis scenarios by ENTSO-E. 
Implementation of regional or bilateral arrangements for assistance during crises. 

• 
•  The risk-preparedness plans of Member States. 
•  Declaration of crisis levels by Member States. 
•  Electricity Coordination Group meetings.  

One of the very first steps in the implementation of the Electricity Risk Preparedness Regulation 
was the appointment by Member States of a Competent Authority. While the deadline was set 
for 5 January 2020, several Member States missed it, and in April 2021 the Commission had to 
launch two EU pilots. Ultimately, all Member States had designated their competent authority 
by August 2021. The full list is available on the Commission’s website92. 

Secondly, the implementation of the new Regulation entailed the development of harmonised 
methodologies for short-term and seasonal adequacy assessments and crisis scenarios. Firstly, 
ENTSO-E  had  to  submit  a  proposal  to  develop  a  methodology  for  short-term  and  seasonal 
adequacy assessments, which was approved by ACER in 202093. This methodology is now used 
for all seasonal outlooks (winter and summer outlooks) and short-term adequacy assessments. 

91 This includes the UK, which as of 2020 is no longer an EU Member State but excludes CY which is exempted 

from the obligation.  

92 

See: 

https://energy.ec.europa.eu/document/download/86e16360-3984-4c25-bb31-

bbe5c4f20222_en?filename=competent_authorities_-_risk_prep_-_october_2021.pdf 

93See: 

https://eepublicdownloads.entsoe.eu/clean-documents/sdc-

documents/seasonal/Methodology%20for%20Short-
term%20and%20Seasonal%20Adequacy%20Assessment%20-%20ACER%20Decision%2008-
2020%20on%20the%20RPR8%20.pdf 

31 

 
 
 
 
ENTSO-E  also  had  to  submit  its  proposal  for  a  methodology  for  identifying  regional  crisis 
scenarios,  which  was  approved  by  ACER  in  202094,  allowing  ENTSO-E  to  perform  its  first 
regional  crisis  scenarios  assessment95.  The  ECG  adopted  a  recommendation  requesting 
ENTSO-E to make specific amendments to its regional crisis scenario assessment96. Following 
its legal obligation to update it where significant new information is available, and based on the 
lessons learnt, an updated methodology was proposed and approved in 202497. Consequently, 
ENTSO-E presented a new assessment of the regional risk scenarios to ECG, which made new 
recommendations  in  April  2025  on  topics  like  the  cooperation  with  stakeholders  or  the 
reassessment of certain concrete scenario. These scenarios are being used for the development 
of the new RPPs due in 2026. 

Following the identification of regional crisis scenarios by ENTSO-E, Member States had to 
identify risks related to the ownership of infrastructure relevant to security of electricity supply 
within four months. Most Member States met the deadline, and an ECG meeting was dedicated 
to  the  discussion  of  these  assessments.  A  new  assessment,  based  on  updated  regional  crisis 
scenarios, was performed and presented during an ECG meeting. 

In parallel, in June 2020, the Commission adopted a non-binding guidance to assist Member 
States  in  the  implementation  of  the  regional  or  bilateral  arrangements  for  assistance98.  It 
concerns  the  obligation  to  agree  on  technical,  legal  and  financial  issues  in  the  regional  or 
bilateral arrangements and describe them in their risk-preparedness plans, to operationalise the 
newly introduced assistance mechanism as required by the Regulation. 

Competent  Authorities  had  to  submit  their  draft  risk-preparedness  plans  for  consultation  to 
neighbouring  Member States.  According to  the Regulation, the  draft risk preparedness  plans 
had to be submitted by 5 April 2021. A three-days seminar was organised in the ECG in June 
2021,  where  Member  States  could  present  and  discuss  their  draft  plans. However,  only  two 
Member States met the deadline (Germany and Estonia). All but five of the draft plans had been 
submitted by the end of the second quarter of 2021. Two infringement procedures were initiated 
in 2022 against Member States who never submitted their draft plan: they instead submitted 
directly their final plan, which was then subject to ECG consultation. 

94See:https://www.acer.europa.eu/sites/default/files/documents/Official_documents/Acts_of_the_Agency/Annex
es%2520to%2520the%2520DECISION%2520OF%2520THE%2520AGENCY%2520FOR%2520THE%25
20C7/ACER%2520Decision%252007-2020%2520on%2520RPR%2520ART%25205%2520-
%2520Annex%2520I.pdf 

95 This document is not for publication. 
96 This document is not publicly available. 
97 

See: 

https://acer.europa.eu/sites/default/files/documents/Individual%20Decisions/ACER_Decision_02-

2024_Regional_Electricity_Crisis_Scenarios_Methodology_Amendment.pdf 

98 

Commission 

Recommendation 

(EU) 

2020/775 

https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX:32020H0775 

32 

 
 
 
According  to  the  Regulation,  Member  States  were  required  to  submit  their  final  Risk 
Preparedness Plan by 5 January 2022. Only 13 met the official deadline (all the national plans 
were ultimately submitted by the end of 2022).  

Following the Commission’s opinions, Member States had to submit amended plans or notify 
the Commission why they object to the recommendation, within three months. Most Member 
States  replied  by  sending an amended Plan or indicating that missing  information  would be 
provided  in  subsequent  updates.  As  of  February  2025,  two  Member  States  (Belgium  and 
France) and Northern Ireland had not complied with the obligation.  

Member States were also required to regularly test the procedures and measures developed in 
the  RPPs.  Yet,  the  submitted  plans  contained  little  information  on  these  tests,  as  is  further 
detailed in the Report on the implementation of the Regulation99.  

A total of 4 early warnings were declared during the implementation period (Cyprus in May 
2020, Greece in August 2021, France in December 2021, Ireland in October 2022). On 28 April 
2025, following the events described in section 3.1, Spain was the very first Member State to 
declare an electricity crisis since the adoption of the Regulation. The timeline of the different 
early warning declarations is further detailed in the figure below. 

Figure 19: crisis level declaration by Member States (2019-2023) 

Source: European Commission, based on Member States’ notifications 

Lastly,  a  total  of  41  ECG  meetings  have  been  held  since  the  Electricity  Risk  Preparedness 
Regulation entered into force (until February 2025)100. During the energy crisis, in particular in 
2022, the group met more than once a month on average.  

99  
100 

COM(2025) 539 final. 

See: 

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

groups/consult?lang=en&do=groupDetail.groupDetail&groupID=2735 

33 

 
 
 
 
 
 
3.3.   External factors and policy developments: energy crisis 2021-2023 

The weaponisation of gas supplies from Russia radically altered the EU’s security of gas supply 
landscape, on top of external events highlighted in section 2.1.2. The energy crisis that followed 
constituted the main external factor influencing the implementation of the Regulation. As will 
be  further  detailed  in  this  section,  the  main  difficulties  experienced  during  the  energy  crisis 
were supply cuts from Russia, which resulted in record high prices (wholesale gas prices peaked 
over €300/MWh in August 2022 – see figure 21).  

Yet, even before Russia’s full-scale military invasion of Ukraine in 2022, Gazprom used gas 
supplies as political leverage by not filling storage capacities in the EU which it owned or had 
primary user rights to (see Figure below). This affected the EU’s preparedness for the winter 
2021-2022 as EU storages were filled at 72% on 1 October 2021 compared to an average of 
90% in the five preceding years.  

Figure 20: Gas in storage (%) in Gazprom Storages vs non-Gazprom storages 

Source: European Commission Joint Research Centre101 

Thereafter, due to unjustified demands, Gazprom:  

•  Unilaterally suspended gas supply to Poland and Bulgaria102 on 27 April 2022.  
•  Stopped flows via Yamal pipeline for transit to and via Poland on 12 May 2022. 
•  Cut gas supplies to Shell Deutschland GmbH, Denmark’s Ørsted and the Netherlands’ 

GasTerra on 31 May 2022103. 

•  Suspended supplies to Finland on 21 May 2022104. 
•  Cut supplies to Italy’s state-controlled ENI and Austrian energy company OMV105.  

101 See: https://doi.org/10.1016/j.esr.2024.101297 
102 See: https://www.bbc.com/news/business-61237519  
103 See: https://www.reuters.com/business/energy/gazprom-cuts-gas-supply-orsted-shell-energy-2022-06-01/  
104 

https://www.gasum.com/en/news-and-customer-stories/news-and-press-releases/2022/natural-gas-

See: 

imports-from-russia-under-gasums-supply-contract-will-be-halted-on-saturday-21-may-at-07.00/ 

105 See: https://www.bloomberg.com/news/articles/2022-06-15/gazprom-cuts-gas-flows-to-italy-by-about-15-eni-

says 

34 

 
 
 
 
Another important external factor is the disruption of two critical gas infrastructures in the EU. 
In September 2022, the Nord Stream-1 (NS-1) pipeline, which used to transport gas from Russia 
to Germany, was sabotaged. While NS-1 was a major pipeline to import gas to Europe, flows 
via NS-1 were already reduced by Gazprom in July 2022 and even completely halted by the 
end of August 2022.  After flows were stopped,  Russia stressed that  flows would not  restart 
unless the “collective West” would lift its sanctions106. The EU’s critical gas infrastructure was 
also disrupted in October 2023, when a ship’s anchor damaged the Balticconnector connecting 
Estonia and Finland107. The disruption of the Balticconnector meant that  Finland was for the 
duration of the repair no longer connected to neighbouring Member States, relying on the LNG 
terminal in Inkoo to satisfy its demand, leading the Competent Authority of Finland to declare 
the ‘alert’ crisis level.108  

Dependencies of Member States on Russian gas, in particular in Central and Eastern Europe, 
had already been significantly reduced, e.g. through several EU-supported PCIs and through a 
well-integrated gas network. Between 2017 and 2024 key infrastructure projects, often with EU 
financial  support  under  CEF  or  regulatory  support,  were  commissioned,  allowing  Member 
States  to  respond  to  supply  cuts  from  Russia.  These  were  among  others  the  Baltic  Pipe, 
interconnectors between Greece and Bulgaria, Poland and Slovakia, Poland and Lithuania, the 
Balticconnector,  enhancement  of  gas  interconnector  between  Lithuania  and  Latvia  and  the 
FSRU terminal in Alexandroupolis.  

The reduced flows of Russian gas and its replacement by gas from alternative sources led to a 
radical  change in  the flow patterns of natural  gas. Even if this initially led to  high levels  of 
congestion, notably in North and Western Europe, it did not lead to curtailments. Flowing large 
quantities of natural gas from West to East, rather than East to West was possible because of 
the mature and highly integrated natural gas market reinforced by bi-directional capacities, as 
well as high levels of interconnectivity.  

3.3.1. The EU’s policy response to the energy crisis 

To tackle the immediate security of supply concerns due to Russia’s weaponisation, the EU 
adopted several measures that aimed to improve the EU’s security of supply, namely: 

•  The REPowerEU Plan in May 2022. 
•  The Gas Storage Regulation in June 2022. 
•  The Gas Demand Reduction Regulation in August 2022. 
•  The Solidarity Regulation in December 2022. 

106 See: Russia switches off Europe’s main gas pipeline until sanctions are lifted 
107 See: https://poliisi.fi/en/-/national-bureau-of-investigation-has-clarified-technically-the-cause-of-gas-pipeline-

damage  

108  See:  https://gasgrid.fi/en/2023/10/27/finnish-national-emergency-supply-agency-raises-the-risk-assessment-

of-gas-supply-security-finnish-gas-market-remains-stable/  

35 

 
 
 
Moreover, the EU adopted several measures in that had an impact on security of supply, even 
if their primary objective was market reform or addressing high prices: 

•  Regulation on an emergency intervention to address high electricity prices. 
•  The reform of the Electricity Market Design. 
•  The Hydrogen and Gas Decarbonisation Package. 

The  REPowerEU  plan  was  a  cornerstone  of  the  EU’s  response  to  the  crisis.  REPowerEU, 
launched in May 2022, aimed to reduce the EU's dependence on Russian fossil fuels as soon as 
possible. The plan focused on three pillars: diversifying energy supplies and routes, accelerating 
deployment of renewable energy, and promoting energy savings. Several Member States have 
taken early actions to reduce or even ban Russian gas imports, including by terminating existing 
contracts  with  Russian  gas  suppliers.109  In  May  2025,  the  Commission  presented  the 
REPowerEU Roadmap110 followed by a legislative proposal in June 2025111, to end the EU’s 
dependency on Russian energy by stopping the import of Russian gas and oil and phasing out 
Russian nuclear energy, while ensuring stable energy supplies and prices across the Union. 

To  implement  REPowerEU  and  phase  out  dependency  on  Russian  gas  imports,  it  was 
instrumental to reduce demand and find alternative supplies from reliable partner countries. As 
highlighted in section 3.1, there has been a significant increase in for example LNG imports 
from the US (45% of all LNG imports in 2024) and sustained imports from Qatar and Algeria 
(12% and 8% respectively of all LNG imports in 2024), as well as pipeline gas from Norway, 
Algeria and Azerbaijan  (50%, 18% and 7% of all  pipeline imports respectively  in  2024).  A 
Memorandum  of  Understanding112  was  signed  with  Azerbaijan  to  establish  a  strategic 
partnership for energy. This includes e.g. doubling the capacity of the Southern Gas Corridor 
and cooperation to accelerate the development of renewable energy. The volumes supplied by 
alternative suppliers were crucial to replace missing supplies from Russia.  

The realisation of the additional infrastructure identified under REPowerEU allows the EU’s 
network to accommodate new gas flows, notably from LNG terminals, to replace Russian gas 
imports. Some of these projects received financial support under the Recovery and Resilience 
Facility given their significant regional importance.113  

109 Estonia, Lithuania, Latvia, Denmark, Finland, Sweden, Germany, Poland, Croatia, Malta, Ireland, Luxembourg, 
Austria  and  Czechia  have  prohibited  or  stopped  gas  supplies  from  Russia.  Some  Member  States  could, 
however, be indirectly supplied with gas of Russian origin through wholesale market purchases. 

110 COM(2025) 440 final 
111 COM(2025) 828 final 
112 See: STATEMENT_22_4583_EN.pdf  
113 For example, Krk LNG terminal in HR was expanded to a capacity of 6.1 bcma, together with reinforcements 
of the gas network to accommodate the expansion of the regasification facility, thereby facilitating access to 
the global LNG market. See: 604ab3a8-7919-4a6d-b05f-f52a844f0c55_en 

36 

 
 
 
Figure 21: gas PCIs map 

Source: European Commission 

Moreover, to address immediate supply concerns, the EU adopted the Gas Storage Regulation114 
in June 2022, setting a 90% storage target. The EU acted to ensure storages were sufficiently 
filled to prepare for supply disruptions from Russia during winter. The 90% target was exceeded 
each year (95% in 2022, 99% in 2023, 95% in 2024).  

The most common measures taken by Member States to ensure the 90% filling include115:  

•  Minimum volume in gas storage: imposing an obligation on Storage System Operators 

(SSOs) on minimum filling levels; 

•  Reduction of storage tariffs for capacities; 
•  Requiring SSOs to tender capacities to market participants (via capacity auctions); 
•  Appointing a dedicated last resort filling entity; 
• 
Instruments to purchase and manage strategic stocks by public or private entities; 
•  Ensuring that booked capacities are used by applying use-it-or-lose-it mechanisms. 

The Storage Regulation also introduced a certification mechanism for storage system operators. 
Certificating SSOs aimed to mitigate potential risks to security of supply from operators who 
might act in ways contrary to EU interests. The certification process is ongoing, but Gazprom 
no  longer  owns  EU  storages.  At  the  time  of  writing,  40  certifications  were  submitted  (18 
pending)  and  17  Commission  opinions  were  adopted.  On  5  March  2025,  the  Commission 

114 Regulation (EU) 2022/1032 
115 COM (2025) 98 

37 

 
 
 
 
adopted  a  proposal116  to  prolong  the  Storage  Regulation  by  two  years,  accompanied  by  a 
Recommendation117 inviting Member States to use flexibility when refilling storages, to avoid 
market  distortions.  In  July  2025,  the  extension  of  the  Storage  Regulation  by  two  years  was 
adopted118, ensuring that there are additional flexibilities for Member States to meet the targets. 

In response to potential gas shortages, the Gas Demand Reduction Regulation119 was adopted 
in  August  2022,  setting  a  15%  gas  demand  reduction  target.  The  voluntary  15%  target  was 
introduced to reduce gas demand compared to the average consumption over the previous five 
years. In case of severe supply disruptions, this target could become mandatory if an “EU Alert” 
was  declared.  The  Demand  Reduction  Regulation  encouraged  Member  States  to  implement 
demand-side measures, such as switching to alternative fuels, improving energy efficiency, and 
promoting behavioural changes among households and industries. The Regulation also required 
Member  States  to  update  their  EPs  to  reflect  voluntary  demand-reduction  measures.  This 
coordinated effort across the EU contributed to reducing gas consumption by 15% for the first 
time in August 2022 (see figure 22), in combination with the record high wholesale gas prices 
which also put pressure on gas demand. The Regulation was prolonged by 1 year by means of 
Regulation  (EU)  2023/706  until  31  March  2024,  after  which  Council  Recommendation 
C/2024/2476  recommended  Member  States  to  continue  reducing  demand  by  15%  in  the 
following year. Since August 2022, the EU reduced gas consumption by 18% until December 
2024 (compared to the 5-year reference period). 

Figure 22: EU27 monthly gas demand reduction compared to 5-year reference period120 

0%

-5%

-10%

-15%

-20%

-25%

-30%

Aug 2022:
implentation of gas 
demand regulation

Source: Eurostat (nrg_cb_gasm) 

116 COM(2025) 99 final 
117 C/2025/1481 
118 Regulation (EU) 2025/1733. 
119 Council Regulation (EU) 2022/1369. 
120 The reference period is defined as the average of the previous 5 years for the period August 2022 to May 2023 
(as laid out in the demand reduction regulation). Therefore, for August-December it refers to 2017-2021, but for 
January-May to 2018-2022. 

38 

 
 
 
 
In  December  2022  the  EU  adopted  the  Solidarity  Regulation121,  to  strengthen  the  collective 
ability  of  Member  States  to  manage  gas  supply  crises  by  ensuring  that  gas  flows  between 
countries are maintained even in  emergencies. The  Regulation  also  reinforced the solidarity 
mechanisms by setting default solidarity rules applicable in absence of bilateral agreements. It 
also included the EU’s demand aggregation mechanism AggregateEU.  

In May 2024, the EU adopted its Hydrogen and Gas Market Decarbonisation package, in which 
the  solidarity  mechanism  was  further  operationalised122.  This  package  consisted  of  a  new 
Regulation (EU) 2024/1789, amending the Gas Security of Supply Regulation (EU) 2017/1938, 
which created a set of default rules in case Member States could not agree on bilateral solidarity 
arrangements.  

In parallel,  the EU addressed electricity market  challenges exacerbated by the energy crisis, 
with provisions also affecting security of electricity supply. The Regulation on an emergency 
intervention  to  address  high  electricity  prices  was  introduced  in  October  2022123,  which 
positively impacted security of electricity supply. Member States agreed to reduce electricity 
demand, through a binding demand reduction target of 5% during peak hours, and an indicative 
10% monthly gross electricity consumption reduction. Aside from  a cold  spell in December 
2022  and  peaks  in  Southeastern  Europe  in  2024,  average  EU  electricity  prices  started  a 
generally downward trend afterwards and did not return to the peaks observed in summer 2022. 

Figure 23: EU energy prices €/MWh (April 2021 - April 2025)  

Source: DG ENER Chief Economist Unit, based on Eurostat data 

Furthermore, in March 2023, the Commission adopted a reform of the EU electricity market 
design,  which  included  several  elements  of  the  Recommendation  on  energy  storage124.  The 
resulting Regulation125 facilitates the deployment of non-fossil flexibility solutions, in particular 
demand response and storage, and introduced provisions to streamline Commission procedures 

121 Regulation (EU) 2022/2576. 
122 The ‘solidarity mechanism’ is an obligation for EU Member States to offer each other assistance during an 

emergency by providing gas volumes to a neighbouring Member State in need. 

123 Regulation (EU) 2022/1854. 
124 Recommendation C/2023/1729. 
125 Regulation (EU) 2024/1747. 

39 

 
 
 
 
for  a  quicker  adoption  of  capacity  mechanisms.  The  impact  of  these  provisions  will  be 
highlighted in an upcoming Commission’s report126. 

The proper functioning of the electricity market during the crisis considerably minimised the 
impact on security of supply, thanks to cross-border flows. The electricity market allows an 
optimisation of the use of resources across Member States, enabling to avoid scarcity situation 
and soften peak prices. Where cross-border interconnectors are not used at maximum capacity 
or  are  under-developed,  Member  States  can  experience  a  tight  supply  and  demand  balance, 
leading to high prices, like the South-East region witnessed during summer 2024. Completing 
market integration will further strengthen security of supply, even if higher interconnectedness 
of energy markets also raises the risk of transnational supply crises and requires stronger and 
proactive coordination. 

During  the  evaluation  period,  EU  energy  law  was  also  marked  by  the  “OPAL  case”.  The 
General Court (case T-883/16 Poland v Commission) and then, on appeal, the Court of Justice 
(case C-848/19 Germany v Poland) found that the “energy solidarity” principle is not only a 
guiding principle for EU institutions when drafting EU energy legislation. Instead, it found that 
it is also directly applicable for applying EU energy law that should be “read” in relevant legal 
provisions  (in  that  case,  Article  36  of  the  Gas  Directive)  as  an  additional,  “unwritten” 
requirement. This indirectly impacted the area of security of supply, as both the Gas Security 
of  Supply  Regulation  and  Risk  Preparedness  Regulation  are  largely  based  on  the  energy 
solidarity principle, and so were the emergency regulations adopted during the crisis. 

126 COM(2025) 65 final. 

40 

 
 
 
 
 
4.  EVALUATION FINDINGS  

4.1.  To what extent was the intervention successful and why?  

4.1.1.  What is the situation of the EU’s security of energy supply today? 

The  EU  security  of  gas  and  electricity  supply  situation  significantly  deteriorated  during  the 
energy crisis in 2021-2023 but has since then substantially improved. While unilateral supply 
cuts from Russia created severe challenges for security of supply in 2022, the EU now has a 
more  diversified  and  secure  gas  supply,  as  was  illustrated  in  Section  3.1.  In  addition,  the 
challenging situation experienced on the electricity markets in 2022 due to droughts affecting 
hydro and nuclear production has improved. Average gas storage filling levels are significantly 
higher since the adoption of the Gas Storage Regulation, as illustrated by Figure 24. 

Figure 24: gas in storage - daily filling percentage 

Source: Commission’s Joint Research Centre, based on GIE AGSI data127 

The EU’s preparedness to various security of gas supply  disruptions is further illustrated by 
ENTSOG’s  security  of  supply  simulation128,  a  requirement  of  the  Gas  Security  of  Supply 
Regulation. The report concludes that: “gas infrastructure, including projects commissioned 
since 2022 following the invasion of Ukraine and projects to be commissioned over the next 
year,  increases  energy  security  in  the  EU  and  significantly  improves  possible  cooperation 
among  Member  States  during  extreme  climatic  conditions  and  individual  supply  route 
disruption  scenarios.”  Despite  that  gas  infrastructure  allows  for  an  efficient  European  gas 
market, a combination of extreme climatic conditions and supply disruptions may still result in 
security of supply concerns that may require demand response, according to the report. The 
improvement in the security of gas supply situation since 2022 due to e.g. the development of 
gas infrastructure can be further illustrated by the improvement of the EU-wide N-1 situation 
(see figure 25). 

127 JRC SoS Dashboard 
128 See: ENTSOG EU-wide Security of Supply Report 2024.pdf 

41 

 
 
 
 
Figure 25: N-1 situation, EU average 

Source: Commission’s Joint Research Centre, based on Member States’ PAPs 

Regarding  electricity,  ENTSO-E’s  winter  adequacy  outlook  for  2025/2026  highlighted  an 
“overall  favourable  adequacy  situation  in  Europe”129.  Identified  adequacy  risks  are  mostly 
concentrated in  remote areas  such  as Cyprus,  Ireland, and Malta.  In continental Europe, the 
only  countries  for  which  risks  were  found  are  Lithuania,  Finland  and  Estonia,  in  case  of 
exceptionally adverse operational  conditions. This is a notable improvement compared to  in 
particular  winter  2022/2023,  due  to  generation  fleet  expansion  combined  with  electricity 
demand moderation. Even in that winter, ENTSO-E130 recognised the value of the coordination 
and  cooperation  among  European  countries  and  acting  on  their  national  Risk  Preparedness 
Plans as key to overcome the risks identified for the winter. 

Figure 26: results electricity 2024/2025 winter outlook (left) vs 2022/2023 winter outlook  

Source: ENTSO-E131 

129 Winter_Outlook_2025-2026_Report.pdf 
130 Winter Outlook 2022-2023_Report.pdf 
131 See: Winter Outlook 2024-2025_Report.pdf, and: Winter Outlook 2022-2023_Report.pdf 

42 

 
 
 
 
 
4.1.2.  Effectiveness 

This  section  looks  at  the  effectiveness  of  the  EU’s  security  of  electricity  and  gas  supply 
framework, i.e. whether it has met its original objectives: 1) to safeguard an adequate security 
of  supply  level,  contributing  to  the  functioning  of  the  internal  market,  and  to  2)  enhancing 
cooperation and coordination among  countries to better handle system  stress  and crises (see 
section 2.1). This section also examines if the various measures in the Regulations contributed 
to meeting the specific objectives. These measures are: 

•  Protected customers and the gas supply standard. 
•  The various risk assessments, simulations and plans required by the Regulations. 
•  The  infrastructure  standard  and  bi-directionality  requirement  for  gas  and  ownership 

risks for infrastructure for electricity.  

•  The crisis management procedures and the solidarity/assistance provisions 
•  The crisis measures adopted during the 2021-2023 energy crisis.  

The  Electricity  Risk-Preparedness  Regulation  and  Gas  Security  of  Supply  Regulation  were 
partially  effective  in  achieving  their  objectives.  The  Regulations  increased  the  EU’s  overall 
preparedness  and  made  the  EU  more  resilient  to  gas  supply  disruptions  and  electricity 
blackouts. The feedback received to the public consultation is in line with this statement, as the 
performance of both regulations was graded moderately positively on all their objectives. More 
than half of the actual respondents gave them a grade between 3 (average) and 5 (excellent) on 
all seven objectives that had been identified.  

The  categories  of  ‘protected  customers’  (gas)  and  ‘consumers  entitled  to  special  protection 
against  disconnection’  (electricity)  were  considered  adequate  by  Member  States  and 
stakeholders  to  protect  vulnerable  or  critical  consumers  to  supply  shocks.  However,  their 
effectiveness proves difficult to assess, given that fortunately neither for gas nor for electricity 
there was a situation that required curtailment.  

•  In  the  gas  sector,  the  report  reviewing  the  implementation  of  the  Regulation132  had 
shown  that  Member  States  did  not  report  difficulties  in  implementing  the  provision. 
Some Member States had requested further harmonisation of the definition of protected 
customers at EU level, while others pointed towards difficulties in estimating protected 
customers’ demand, when daily metering is not available.  

•  In  the  electricity  sector,  the  feedback  received  through  the  public  consultation  was 
generally positive towards this provision. Member States took varied approaches in the 
definition133 of the categories of consumers that are entitled to receive special protection 
against disconnection in their RPPs and the Commission had to request clarifications in 
eleven cases. Still, because of this provision, Member States were required to review 

132 COM(2023) 572 final. 
133 The Risk Preparedness Regulation leaves this definition to national legislation. 

43 

 
 
 
manual load shedding plans, which is a positive step to avoid potential propagation of 
an electricity crisis to essential social services.  

Concerning the gas supply standard, which requires undertakings to ensure supply to protected 
customers under a number of pre-defined situations, no particular issues have been identified 
regarding  the  implementation134.  Nonetheless,  in  the  public  consultation,  some  respondents 
expressed concerns regarding the perceived  vagueness for the enforcement of the provision. 
Some respondents suggested that stronger monitoring could reduce the need for other type of 
measures (notably storage filling targets). 

The risk assessments required by the Gas Security of Supply Regulation and Electricity Risk-
Preparedness Regulation have improved the way Member States analyse risks.  

•  For electricity, a first common methodology for the identification of electricity crisis 
scenarios was established and two assessments at regional level were carried out, which 
was  not  the  case  before  the  Regulation  entered  into  force.  This  is  a  considerable 
improvement and therefore contributed to the objective of improving and harmonising 
risk assessments and preparedness.  

•  The situation is comparable for gas, where two cycles of common risk assessments have 
been  carried  out.  These  assessed  among  others  the  risk  of  a  full  Russian  supply 
disruption  at  regional  level,  which  contributed  to  the  policy  objectives  of  ensuring 
adequate  levels  of  regional  cooperation  and  enhancing  preparedness  through  a  risk-
based  approach.  This  was  supported  by  the  EU-wide  simulation  by  ENTSOG  (done 
three times in the evaluation period), which also contributed to adapt the assessment to 
new risks, including the full disruption of Russian supplies. 

Despite  these  improvements  compared  to  the  situation  before  the  implementation  of  the 
regulations,  risk  assessments  still  feature  some  substantial  weaknesses,  such  as  a  lack  of 
consideration of cross-sectoral and cross-border risks. This is further developed in the sections 
about relevance and EU added value criteria135. 

Similarly,  the  plans  are  a  useful  measure  that  foster  transparency  and  establish  national 
procedures  and  mechanisms  in  case  of  a  gas  or  electricity  crisis.  Thanks  to  this  provision, 
Member States are obliged to make the necessary crisis arrangements, take into account their 
neighbouring  Member  States  when  designing  them  and  ultimately  also  consult  domestic 
stakeholders and neighbouring Member States on the measures they intend to take in case of a 
crisis.  

•  Regarding the gas plans, the Commission opinions recognised the overall quality and 
completeness of the Member States’ plans, in particular as regards the description of the 
specificities of the national gas systems, as well as the roles and responsibilities during 

134 See SWD(2023) 323 for further details. 
135 These weaknesses however also affected the effectiveness of these provisions. 

44 

 
 
 
a crisis. All Member States now have preventive and crisis measures in place, which is 
a positive outcome of the Regulation.  

•  For the electricity plans, the quality of national measures in the plans was satisfactory 
(e.g., double fuel obligation for gas-fired power plants) and the link with national crisis 
scenarios was well-established. 

However, as was indicated in the Commission opinions on the plans, there are shortcomings:  

•  The gas plans are often insufficiently linked to risks identified in the risk assessments. 
While it is a requirement of the Regulation, in practice this has not been  sufficiently 
applied  by  Member  States,  making  the  sequence  of  deliverables  less  effective.  The 
identification  of  critical  gas-fired  power  plants,  distinction  between  measures  to  be 
taken in different crisis levels, the identification of (solidarity) protected customers and 
the regional dimension are also often lacking.  

•  For the electricity plans, in 16 cases the Commission considered that the plans had to 
be  amended  to  include  further  information  on  national  measures,  including  on 
procedures  and  corresponding  information  flows,  triggers,  and  conditions  for  their 
application (in particular for non-market-based measures).  

Infrastructure  needs  have  been  adequately  assessed  based  on  the  Gas  Security  of  Supply 
Regulation  and  TEN-E  Regulation.  The  evolution  of  the  infrastructure  standard  of  the  Gas 
Security  of  Supply  Regulation,  in  particular  the  N-1  requirement136,  has  shown  significant 
improvement  since  the  Regulation  entered  into  force  (see  section  3.2).  Until  revision  of  the 
TEN-E  Regulation,  each  project  of  common  interest  (PCI)  process  had  to  identify  gas 
infrastructure needs, resulting in project specific assessments in order to establish the PCI list. 
Five Union lists were adopted137, always containing crucial infrastructure projects for security 
of supply. In the Electricity Risk Preparedness Regulation, Article 5 only requires ENTSO-E 
to  consider  “accidental  hazards  going  beyond  the  N-1  security  criterion138  and  exceptional 
contingencies” in the identification of regional crisis scenarios. While the Regulation requires 
Member  States  to  include  in  their  RPPs  “information  on  related  and  necessary  plans  for 
developing the future grid that will help to cope with the consequences of identified electricity 
crisis  scenarios”,  several  Member  States  did  not  do  so.  As  part  of  the  first  RPPs  cycle,  the 
Commission requested more information on this point in 14 cases.  

136 The N – 1 formula describes the ability of the gas infrastructure to satisfy total gas demand in a Member State 
in case of a disruption of the single largest gas infrastructure during a day of exceptionally high gas demand 
occurring with a statistical probability of once in 20 years. 

137 Since 2014, the CEF programme has awarded Union co-funding worth €6.8 billion to infrastructure projects of 
common interest (PCIs) in the energy sector. Out of this, €1.6 billion were for 43 gas PCIs, 19 of which have 
already been commissioned.  

138 The System Operation Guideline (Commission Regulation (EU) 2017/1485) sets a N-1 criterion for electricity, 
by which “the elements remaining in operation within a TSO's control area after occurrence of a contingency 
are capable of accommodating the new operational situation without violating operational security limit”. 

45 

 
 
 
The  ownership  risks  identified  related  to  protection  of  critical  energy  infrastructure  were 
inconclusive, particularly for gas.  

•  For gas, Member States were required (if relevant) to consider risks for the control of 
infrastructure  in  the  updated  national  risk  assessment  (e.g.  due  to  third  country 
ownership). In only 5 out of 25 national risk assessments, the risk related to control of 
critical  infrastructure  was  assessed,  with  no  significant  impacts  identified.  Assessing 
ownership risks has become increasingly important during the evaluation period since 
Gazprom’s  manipulation  of  EU  gas  storages  (cf.  chapter  3).  Consequently,  the  EU 
introduced  an  obligation  for  Member  States  to  certify  their  gas  SSOs  under  the  Gas 
Storage Regulation. There is currently no longer a direct risk stemming from ownership 
of storage facilities that could put the security of gas supply of the EU at immediate 
risk.139 There are no such certification provisions for LNG terminal operators.  

•  For  electricity,  Member  States  assessed  risks  related  to  the  ownership  relevant  to 
electricity security of supply and notified the Commission in January 2021. While no 
major risks were identified, the assessments did not sufficiently cover the generation 
sector as well as risks related to the ownership of relevant infrastructure in the gas sector, 
despite their importance for security of electricity supply.  

The bi-directionality requirement was an instrumental measure of the Gas Security of Supply 
Regulation for preparedness. As Figure 27 shows, the median IP bi-directionality has increased 
steadily from 0.05 in 2017 to 0.45 in 2023. This has helped facilitating reverse flows during the 
energy crisis. When Russia cut gas supplies to the EU, flows had to be redirected for example 
from  West  to  East,  instead  of  the  traditional  East  to  West  direction.  This  was  precisely  the 
objective  of  the  bi-directionality  requirement,  adding  necessary  infrastructure  flexibility  in 
times of crisis. However, a legal uncertainty arose during the implementation period regarding 
the  concept  “permanent  physical  bi-directional  capacity”  concerning  virtual  interconnection 
points, following the decision from German authorities regarding Deutschneudorf EUGAL IP 
(cf. section “current state of implementation”). Conceptual clarification may be required in the 
future. 

139 This is confirmed by Commission reports reviewing the Storage Regulation COM(2023) 182, COM(2024) 89. 

46 

 
 
 
Figure 27: Boxplot of bi-directionality of all borders inside the EU from 2016 to 2023140 

Source: Commission’s Joint Research Centre, based on ENTSOG capacity data 

While  the  EU  would  have  arguably  been  worse-off  without  them,  in  retrospect  the  two 
Regulations  displayed  clear  weaknesses  regarding  upfront  preparedness  for  the  2021-2023 
energy crisis.  

•  In the gas sector, despite the risk of Russian supply disruptions being recognised in 
most national risk assessments, the Regulation was not designed to mitigate prolonged 
supply disruptions from the EU’s main supplier. Therefore, the regulatory framework 
had to be complemented with emergency measures to refill storages, reduce demand 
and  improve  the  solidarity  mechanism.  The  Regulation  did  not  have  the  appropriate 
tools to prevent manipulation from Russian operators on the storage market, resulting 
in security of supply concerns and high prices due to historically low storage levels in 
Autumn 2021.  

•  In the electricity sector, the RPPs’ scenarios proved to be too shallow, in particular 
regarding gas crisis spillover risk, with some Member States having to elaborate ad hoc 
scenarios or perform stress tests in the midst of the crisis. 

To  mitigate  the  impacts  of  the  crisis,  the  EU  complemented  its  security  of  gas  supply 
framework, notably through the REPowerEU Plan of May 2022141. Building on the REPowerEU 
plan, the EU adopted the Gas Demand Reduction Regulation,142 to reduce gas demand by 15%. 
Reducing gas demand was essential to preserve the delicate gas supply-demand balance amid 
the  crisis.  It  is  estimated  that  surpassing  the  objectives  of  the  Gas  Demand  Reduction 
Regulation  (18% demand reduction)  allowed to  replace  65 bcm  of Russian gas in 2023 (cf. 

140 The boxplot shows the degree of EU gas interconnections between MSs have capacities in both directions. If 
the indicator is 1, all interconnections would have the same capacity in both directions. If the indicator is 0, 
all interconnections could only flow one direction. The orange line is the median. 

141 COM(2022)230 
142 Regulation (EU) 2022/1369, prolonged for a year in March 2023 by Regulation (EU) 2023/706. In March 2024, 

the Regulation was replaced by Council Recommendation C/2024/2476. 

47 

 
 
 
 
figure below), thereby being the biggest contributor to phasing out Russian gas in 2023.143 As 
further detailed in the reports144 reviewing the Demand Reduction Regulation, the objectives of 
the  Regulation  were  surpassed  by  a  combination  of  policy  driven,  weather  driven  and  price 
driven  factors.  As  a  result  of  this  Regulation,  Member  States  took  measures  to  pro-actively 
reduce  demand  through  communication  campaigns  to  raise  awareness  of  saving  energy, 
introduce  heating  and  cooling  limitations  in  public  buildings,  facilitate  fuel  switching  and 
electrification, prolonging lifespans of power plants to substitute gas for power consumption or 
subsidise energy efficiency.  

Figure 28: Russian pipeline gas phase-out progress 2023 vs. pre-crisis145 

Source: European Commission, based on ENTSOG data 

After the adoption of the Storage Regulation, gas storage filling levels exceeded the 90% target. 
While storages were only filled until 77% by 1 November 2021 due to Gazprom not filling its 
EU storage facilities (see section 3.3), storage levels after adoption of the Storage Regulation 
reached record heights of 95% in 2022, 99% in 2023 and 95% in 2024. The measures taken by 
Member States highlighted in section 3.2, significantly contributed to storage filling, as were 
favourable market conditions in those years. This was instrumental to prepare the EU to face 
the winter season, when supplies from Russia were dwindling. In addition to the immediate 
security  of  supply  benefits  this  had,  full  storages  also  helped  to  reassure  the  market  and 
contributed to driving prices down.146  

However, the fact that additional measures were needed to combat the energy crisis reflects the 
insufficiency of the Gas Security of Supply Regulation in tackling a protracted crisis of such a 

143 Further information on the functioning and effectiveness of the Demand Reduction Regulation can be found in 

the reports reviewing the Regulation COM(2024) 88, COM(2023) 173 and SWD(2023) 63. 

144 COM(2023) 173, SWD(2023) 63 and COM(2024) 88 
145 COM(2024) 88 final. 
146 See  Commission Report  COM(2024) 89, or  ACER  report which concluded that: “Storage filling levels are 
significantly  above 
to  driving  prices  down.” 
https://www.acer.europa.eu/sites/default/files/documents/Publications/ACER_MMR_Key_Developments_G
as_2023.pdf  

last  years’  average  and  have  contributed 

48 

 
 
 
 
magnitude. The Gas Security of Supply Regulation was designed to tackle time-limited supply 
crises and was therefore not sufficiently effective in tackling prolonged disruptions of the EU’s 
single  largest  supplier.  However,  combined  with  the  effective  implementation  of  the  crisis 
measures through filling storages to over 90% and reducing demand by more than 15%, the 
supply disruptions from Russia did not lead to curtailments, meaning that with the framework 
in its entirety shortages were avoided.  

In the electricity sector, the response was more focused on limiting price increases as the risks 
for supply were more limited than in gas. Council Regulation (EU) 2022/1854 on emergency 
interventions to address high energy prices also introduced measures to cut electricity demand 
however, through a binding demand reduction target of 5% during peak hours as well as an 
indicative  one  10%  monthly  gross  electricity  consumption  reduction,  which  had  a  positive 
effect on security of supply. While reporting Member States overall reached the former target, 
they faced more difficulties with the latter147. 

The EU’s crisis management procedures are designed to mitigate high-impact low-probability 
emergencies. Due to the low likelihood, most crisis management procedures have never been 
applied  in  practice.  However,  several  crisis  levels  have  been  declared  throughout  the 
implementation  period148,  the  majority  of  which  during  the  energy  crisis  in  2022.  While  the 
activation  of  national  crisis  levels  was  generally  well-coordinated  via  the  GCG  and  ECG, 
several Member States considered the criteria for lowering crisis levels post-crisis unclear in 
the gas sector. For both gas and electricity there is an EU definition for crisis levels, but these 
definitions  leave  significant  margin  of  discretion  to  Member  States  as  they  rely  on  when 
Member States introduce non-market-based measures (gas) or when an electricity shortage is 
considered  significant  (electricity)149.  Until  the  Iberian  incident  of  April  2025,  no  electricity 
crisis  had  been  declared  under  the  Risk  Preparedness  Regulation.  During  this  incident,  the 
Commission  was  notified  of  the  crisis  declaration  in  the  afternoon,  contacts  at  expert  level 
started  in  the  early  moments  of  the  incident,  and  the  neighbouring  Member  States  were 
informed.  

The EU’s crisis  management procedures proved  effective when tested in  table-top  exercises 
(‘dry  runs’)  for  gas  organised  by  the  Commission  in  December  2022  and  November  2024. 
However, the EU emergency level for gas security of supply was considered unclear during the 
2022  exercise,  in  contrast  to  e.g.  the  EU  alert  that  was  established  as  part  of  the  Demand 
Reduction  Regulation,  where  the  role  of  the  Commission  was  more  clearly  defined.  The 
identification of critical gas-fired power plants and the estimation of critical gas volumes for 
electricity differs per Member State, so the importance of aligning emergency response systems 
between  gas  and  electricity  was  a  key  learning  (e.g.  ENTSOG’s  ReCo  and  the  Regional 

147 COM(2023) 302 final. 
148 Gas: 13 Early Warnings, 2 Alerts and 1 emergency declared since 2017. Electricity: 4 Early warnings declared 

since 2019, no electricity crisis declared. 

149 As part of the RPPs exercise, the Commission requested additional information on definitions in 16 cases. See 
notably the report on the implementation of the Risk Preparedness Regulation for further details (COM(2025) 
539 final). 

49 

 
 
 
Coordination  Centre  for  electricity).  It  also  showed  the  need  to  further  clarify  coordination 
procedures between critical infrastructure protection and energy security competent authorities 
and highlighted the importance of gas demand reduction measures to overcome a supply crisis.  

The  two  dry  runs  organised  in  December  2022  and  November  2024  tested  the  solidarity 
mechanism, which showed it is an adequate framework to activate a crisis response150. It also 
identified areas for that require further consideration:  

(1) The  2022  exercise  showed  the  complexity  of  establishing  fair  compensation  for 
solidarity. This has been partially addressed through amendments introduced in 2024 by 
Article 84 of the Hydrogen and Gas Market Decarbonisation Package.  

(2) There is a potential usefulness to incorporate LNG solidarity, as LNG can play a key role 
during a solidarity request through outreach to relevant LNG suppliers. However, legal 
tools to enforce redirecting LNG cargoes remains a challenge and it ultimately depends 
on contractual arrangements between concerned parties.  

(3) The  extension  of  solidarity  to  indirectly  connected  Member  States  on  market-basis 
introduced in 2024151 allows access to a larger and likely cheaper pool of solidarity. The 
effectiveness  would  benefit  from  a  clearer  identification  of  procedures  and  of  actors 
responsible  for  collecting  and  transferring  gas  and  clearer  guidelines  on  monitoring 
actions taken before requesting solidarity. 

By  contrast,  no  such  pan-European  exercise  has  been  organised  for  the  electricity  sector. 
However,  the  Risk  Preparedness  Regulation  requires  Member  States  to  carry  out  biennial 
regional crisis exercises. Some regions have been active, performing exercises even before the 
Regulation came into force or performing the exercises on annual basis. Member States will 
have to describe the tests carried out and how their results have been included in updated risk 
preparedness plans (to be submitted in 2026), with Pentex 2023 as a recent example. The overall 
evaluation of the exercise was positive, and it was widely agreed among participants that the 
regular Penta exercises are beneficial for the preparation for regional crises. Electricity supply 
disruptions due to critical energy infrastructure damage related to physical and cyber-attacks 
was  also  considered  in  horizontal  EU  crisis  management  exercises  such  as  EU  Integrated 
Resolve Parallel and Coordinated Exercises (PACE). The latest example, PACE 2024, which 
is  done  in  cooperation  with  NATO,  considered  simultaneous  hybrid  threats  crises  affecting 
critical energy infrastructure from several Member States. Other table-top exercises with NATO 
also address critical energy infrastructure resilience, including maritime infrastructure damage 
(gas pipelines, power cables and offshore wind farms). The Coherent Resilience 2023 – Baltic 
(CORE 23- B) that focused on the Baltics energy system is an illustrative case. Some Member 
States  suggested that the Commission  should organise EU-wide or regional  electricity crisis 
exercises, mirroring the gas dry runs. 

150  Commission’s  press  release:  https://energy.ec.europa.eu/news/eus-energy-security-framework-successfully-

tested-ensure-winter-preparedness-2024-11-08_en 

151 Introduced through the amendments of Article 84 of the Decarbonised Hydrogen and Gas Package. 

50 

 
 
 
This fitness check used a public consultation to corroborate the findings on effectiveness. The 
Gas Security of Supply Regulation received the following average grades in terms of meeting 
its objectives152:  

a)  3.47/5 for the objective “Secure an adequate level of preparedness in Europe for gas 

supply disruptions, e.g. through assessing risks and sufficient infrastructure”; 

b)  3.18/5 for the objective “Ensure that all necessary measures are taken to safeguard an 

uninterrupted supply of gas, in particular to protected customers”; 

c)  3.43/5 for the objective “Enhance regional and EU-wide cooperation, including in times 

of supply emergencies”.  

The Electricity Risk Preparedness Regulation received the following average grades:  

a)  3.19/5 for the objective “Improving prevention and preparedness”;  
b)  3.48/5 for the objective “Improving transparency and information sharing”;  
c)  3.27/5 for the objective “Improving coordination in electricity crisis”;  
d)  2.76/5  for  the  objective  “Reducing  the  risk  of  negative  spillover  effects  that  purely 

national measures could have in neighbouring Member States”. 

These grades, although not representative of the EU population, show an overall satisfaction 
from responding citizens and stakeholders with the functioning of both Regulations. Yet, they 
also  suggest  that  improvement  is  possible,  in  particular  regarding  objective  b)  of  the  Gas 
Security  of  Supply  Regulation,  and  objective  d)  of  the  Electricity  Risk-Preparedness 
Regulation. Overall, the level of satisfaction seems to be slightly lower for the latter. 

4.1.3.  Efficiency 

This section assesses the efficiency of the EU’s security of supply framework. It considers the 
costs needed to drive the benefits generated by the Regulations. It specifically looks at: 

•  The costs to develop infrastructure that are a direct result of the two Regulations. 
•  The administrative burden of the various reporting requirements, risk assessments and 

plans. 

•  The  administrative  burden  and  costs  of 

the  crisis  management  provisions, 

solidarity/assistance mechanism and the crisis measures.  

This section also illustrates the benefits of a functional security of supply framework. The costs 
of past or potential future crises are used as a proxy for the benefits of avoiding such crises from 
happening.  

An assessment of the efficiency of both Regulations reveals a mixed picture. While the direct 
financial  costs  associated  with  compliance  for  energy  undertakings  have  been  relatively 
contained,  the  administrative  burden  imposed  on  Competent  Authorities  by  reporting 

152 The maximum grade possible was 5 (Excellent). 

51 

 
 
 
requirements  and 
lengthy  procedures  has  been  significant,  especially  for  national 
administrations. This is a finding shared both by stakeholders and Member States, as expressed 
through responses to  the public consultation  or bilateral  exchanges, and by the Commission 
based  on  its  experience  with  the  implementation  of  the  regulation.  A  mapping  of  the  costs 
induced by the implementation of these Regulations is provided in Annex IV of this document. 
The main costs are linked to the development of infrastructure and to the various administrative 
costs  (e.g.,  reporting  requirements,  enforcement  costs,  obligations  to  negotiate  bilateral 
agreements,  etc.).  In  the  public  consultation,  some  measures  were  praised  for  their  low 
implementation costs combined with a large effectiveness, such as the two coordination groups. 

As  regards  infrastructure,  the  main  costs  were  borne  to  meet  the  Gas  Security  of  Supply 
Regulation infrastructure requirements (N-1 and reverse flows). These costs were borne mainly 
by TSOs, often with the financial and regulatory support from the EU and public authorities 
(and thus indirectly by both consumers, network users and citizens), alleviating the exponential 
growth of transmission and storage tariffs. Assessing the exact costs linked to the fulfilment of 
these obligations is not possible because it would require isolating all infrastructure projects 
that were completed for security of supply purposes only, that are directly attributable to the 
Regulation (a share of them were undertaken also partly for market integration purposes). It is 
however possible to take projects as case studies (cf. Box 1), which gives an order of magnitude 
of the costs that may have been caused by these provisions. In the public consultation, when 
asked about the costs of the infrastructure obligations, the majority of respondents gave a grade 
of 1 (negligible) or 2 (low).  

BOX 1: TWO CASE STUDIES OF THE COSTS INDUCED BY THE GAS SOS 
REGULATION INFRASTRUCTURE REQUIREMENTS 

A  CEF  Action  with  significant  externalities  for  security  of  supply  was  the  Bilciurești 
underground  gas  storage  (largest  storage  in  Romania).  It  was  confirmed  during  the  CEF 
evaluation that the CEF Action would increase daily withdrawal capacity of the facility by 
over 40% and improve its overall capacity, mitigating risks of gas disruptions during peak 
consumption periods. The assessment confirmed  security of supply benefits  for Romania, 
Bulgaria, Hungary and Moldova. The project would improve the N-1 indicator from 106.3% 
to 114.6%. The project received CEF funding of 38 mln EUR, directly contributing to the 
implementation of the Gas Security of Supply Regulation. 

Another example is  the PCI project  Estonia-Latvia gas interconnection enhancement. The 
Karksi project was supported with a CEF grant of 18.7 mln EUR (covering half of the total 
cost)  to  construct  a  gas  metering  station;  a  border  valve  and  a  bidirectional  compressor 
station. The CEF grant provided to this PCI project allowed for bidirectional flows between 
Estonia and Latvia, as well as solidarity since the project’s impact was identified for Estonia, 
Latvia, Finland and Lithuania. The implementation of the Karksi project was closely linked 
with  the  gas  interconnector  between  Finland  and  Estonia  ('Balticconnector')  which  ended 
Finland's gas isolation. The implementation of the project is directly attributable to the Gas 

52 

 
 
 
 
Security  of  Supply  Regulation,  as  it  followed  Commission’s  Decision  C(2020)  6600 
requiring to review the exemption for this IP. 

The  benefits  of  having  reverse  flow  capability  have  surpassed  the  costs  of  developing  bi-
directional capacities that are directly attributable to the Gas Security of Supply Regulation. 
First, the project cost of establishing reverse flow on existing pipelines is relatively low (EUR 
5-15 mln) compared to the cost of pipeline or interconnection projects (hundreds of millions). 
Second, most reverse flow  projects  were built  during the years following  the 2008/09  crisis 
where significant EU funds were dedicated to it. Third, since the obligation is in place, any new 
pipeline or interconnection project needs to be able to allow flows in both directions by design, 
therefore the cost of reverse flow is included in the overall cost of those projects. The marginal 
cost of that ability is relatively limited.  

A  total  of  23  reverse  flow  projects  were  identified  in  the  ENTSOG  Ten-Year  Network 
Development  Plans  (TYNDP)  that  were  carried  since  2017,  of  which  ten  have  been 
commissioned during the evaluation period. Other projects were cancelled, temporarily halted, 
or  an  exemption  was  granted.  One  project  will  be  commissioned  in  2028.  Of  the  ten 
commissioned  projects,  six  projects  included  a  capital  expenditure  figure  (CAPEX)  in  the 
TYNDP, which totals 286 mln EUR153. Other projects’ CAPEX were either confidential, or not 
reported. Two of these reverse flow projects received CEF funding, namely the Karksi project 
described in Box 1 and the TENP reverse flow project, which received 8.7 mln EUR in support 
for  procurement  and  execution  of  the  works154  and  0.4  mln  EUR  for  studies155.  It  should  be 
noted, however, that the costs of these projects cannot be solely attributed to the Gas Security 
of Supply Regulation, as some of the projects may also have been carried out for other reasons, 
such as market integration. Compared to the benefits of a flexible system in case of a supply 
disruption, these costs are reasonable. This is illustrated by the need to reverse the gas flows 
from West to East during the energy crisis of 2022, when supplies from Russia largely stopped.   

However, the process to request an exemption from the obligation of enabling bi-directional 
flows156  is  cumbersome  and  imposes  unnecessary  administrative  burden  on  energy  utilities, 
national  administrations,  and  EU  institutions  and  agencies.  This  process  requires  TSOs  to 
submit exemption requests to competent authorities, followed by consultations with national 
regulatory authorities, potentially affected Member States, ACER, and the Commission. Upon 
receiving the proposal or request, competent authorities must consult various stakeholders and 
allow  them  to  issue  opinions,  which  can  prolong  decision-making.  The  process  could  be 
simplified keeping in mind the objective of not compromising the integrity of the regulatory 
oversight, by deleting for instance the possibility for both ACER and the Commission to adopt 

153  Figure  based  on  CAPEX  figures  reported  for  reverse  flow  or  bidirectional  capacity  purposes  in  ENTSOG 
TYNDPs Annex A in 2018, 2020, 2022 and 2024, that were commissioned in between 2017 and 2024. See: 
https://www.entsog.eu/tyndp 

154 See https://ec.europa.eu/energy/infrastructure/transparency_platform/map-viewer/main.html 
155 See: https://ec.europa.eu/assets/cinea/project_fiches/cef/cef_energy/5.10-0010-DE-S-M-15.pdf 
156 As outlined in Annex III of the Gas Security of Supply Regulation 

53 

 
 
 
 
a first opinion before the coordinated decision (paragraph 3 of Annex III of the Regulation), 
which was never used during the evaluation period. 

Figure 29: process to request exemption from the bi-directional capacity obligation 

Source: European Commission 

In fact, most of the provisions in both Regulations relate to planning and reporting, resulting in 
administrative  costs.  They  are  borne  mostly  by  national  administrations,  as  well  as  by  the 
Commission, and more marginally by ACER, TSOs and ENTSOs. A mapping of these costs, 
with tentative estimations of the amounts based on data provided by Member States, ACER, 
ENTSOG and ENTSO-E, is provided in Annex IV.  

The  deadlines  stemming  from  the  Gas  Security  of  Supply  Regulation  and  Electricity  Risk 
Preparedness Regulation lead to a logical sequence in deliverables. The sequence is based on 
first conducting simulations, followed by risk assessments, based on which plans are developed. 
The deadlines largely do not overlap, unless this is necessary to ensure consistency between 
deliverables  (e.g.  national  and  common  risk  assessments  being  delivered  at  the  same  time). 
However, deadlines proved difficult to comply with. In gas only one Common Risk Assessment 
(out 24) and 10 plans (out of 104) were delivered on time and in electricity two draft and 13 
final RPPs (out of 28) were delivered on time. This is mainly due to reporting fatigue as well 
as to burdensome and inoperative procedures. Besides, the updates of the PAPs and EPs come 
shortly  before the draft  NECPs have to  be issued, while the latter also  include a mandatory 
section about energy security157. Overlaps are limited between the Plans and the NECPs, as they 
arguably cover different timeframes. In this regard, several Member States have adequate cross-
references to their security of supply plans in their NECPs. 

157 In particular, according to the Governance regulation, Member States have to set national objectives with regard 
to:  “increasing  the  diversification  of  energy  sources  and  supply  from  third  countries  (…);  increasing  the 
flexibility  of  the  national  energy  system;  and  addressing  constrained  or  interrupted  supply  of  an  energy 
source”. 

54 

 
 
 
 
Figure 30: Timeline of reporting deadlines 

Source: European Commission 

While  the  deadlines  should  not  create  unnecessary  administrative  burden,  the  number  of 
deliverables leads to high administrative burden for national authorities. Member States may 
have to submit two versions of their electricity RPPs (original and updated) in addition to the 
exchange of drafts for consultation. For gas there are two risk assessments in addition to 2 sets 
of two plans and the drafts for consultation. Some of the information requirements in the various 
deliverables for gas also show duplication, for example regarding the N-1 calculation or the 
description of the regional gas system which are required in both the risk assessments and the 
PAPs. At the same time, the common risk assessments had to be developed for 12 regional risk 
groups, which has led to heavy duplication. The risk assessment of the Belarus risk group was 
merged with the North-Eastern risk group, while also the Norway and UK risk groups were 
merged to alleviate administrative burden. Given the high degree of interconnectedness of the 
EU’s energy system, fewer regional risk groups would be justifiable to lower administrative 
burden on Member States. All electricity RPPs158, as well as the gas PAPs and EPs159, along 
with the corresponding Commission’s opinions have been made publicly available in different 
languages.  

These  late  submissions  and  a  lack  of  administrative  capacity  were  considered  hurdles  for 
assessing risks effectively, especially for the update of the gas risk assessments and plans due 
during the energy crisis. For this reason, to complete the risk assessments, the Commission’s 
JRC had to carry out the modelling efforts for the majority of risk groups, which ordinarily 
should be done by Member States.  

Regarding  the  solidarity/assistance  provisions,  the  results  achieved  are  not  seen  as 
commensurate with the efforts by some respondents to the public consultation. While time has 

158  See:  Risk  preparedness  plans  in  the  electricity  sector  by  national  competent  authorities  and  Commission's 

opinions 

159 See: Commission's opinions on the preventive action plans and emergency plans 

55 

 
 
 
 
been invested by public authorities in the negotiations, only 9 gas solidarity agreements were 
reached (out of 40), and the results in electricity are also far from being satisfactory (cf. section 
about effectiveness). This issue was also highlighted by some respondents, while others also 
raised concerns regarding the clarity of defaults solidarity provisions, which may hinder their 
operationalisation. However, data sent by Member States regarding the costs of implementing 
various  provisions  of  the  Regulations  did  not  point  to  a  high  additional  workload  due  to 
negotiating solidarity agreements (see Annex IV). The difference between perception and time 
spent  may  indicate  an  inaccuracy  in  the  data,  or  that  there  are  ‘hassle  costs’,  caused  by 
frustration of spending time on a file that sees only marginal progress. It should be noted that 
the  default  solidarity  rules  adopted  as  part  of  the  measures  to  combat  the  energy  crisis  via 
Regulation (EU) 2022/2576 and later via Regulation (EU) 2024/1789, lifted the obligation to 
conclude bilateral solidarity agreements, alleviating these costs.  

Some of the measures adopted during the energy crisis are at times seen as expensive. This is 
notably  the  case  of  gas  storage  filling  requirements.  In  the  public  consultation,  the  storage 
targets were the only measure where most respondents gave a grade of 4 (high) or 5 (very high) 
to  the  question  about  whether  the  provision  had  created  disproportionate  burden  (e.g., 
administrative, financial or other). Market participants usually see this measure as particularly 
costly, and some highlight that forcing operators to fill storages regardless of market conditions, 
increases costs. This view is supported by an ACER study, which assessed that certain national 
measures in three Member States to establish strategic reserves cost €19 billion, with total cost 
of the 2022 injection season exceeding that by some margin160. The unprecedentedly high costs 
of this injection season were also partly offset by the volumes sold during withdrawal season, 
due to falling prices after summer 2022. However, these costs are also due to the exceptional 
circumstances of 2022/2023, with record high prices on the gas market, largely due to external 
circumstances.  Drawing  lessons  from  the  implementation  of  the  gas  storage  regulation,  and 
the  Commission  published  a 
taking 
recommendation161 inviting Member States to consider current market conditions and introduce 
flexibility  when storage facilities are being  refilled in  summer 2025, to  optimise purchasing 
conditions. The extension of the Storage Regulation by two years came into force in September 
2025162, ensuring that there are additional flexibilities for Member States to meet the targets to 
alleviate any potentially high costs associated with storage filling. 

into  account  evolving  market  conditions, 

In terms of overall distribution of costs of the Regulations, most of the burden lies on public 
administrations and TSOs. This was also recognized in the responses to the public consultation. 
One other marginal  issue that was identified, specific to  the  electricity sector, is  the lack of 
“fairness” requirements for the design of manual load-shedding plans. This may raise questions 
in terms of the social acceptability of those plans. 

160 See https://acer.europa.eu/sites/default/files/documents/Publications/VIS-Study_Gas_Storage_Report.pdf  
161 C/2025/1481 
162 Regulation (EU) 2025/1733 

56 

 
 
 
On the other hand, the benefits tied with the implementation of these Regulations are difficult 
to quantify. Security of supply functions as  an insurance. This implies that there are always 
costs while the benefits are often never fully quantifiable, unless an actual supply disruption 
occurs. Therefore, making a rough assessment of the benefits requires to use proxies, such as 
past crises. Even if they use quantitative figures, such assessments need to be used with caution, 
and only in a qualitative manner, since each crisis is sui generis. It is generally recognised that 
the benefits linked to these Regulations outweigh the costs, because of the significant societal 
benefits (e.g., minimising forced energy supply cuts to citizens and industries).  

In the past decades, several examples of energy crises have occurred. In the gas sector, the 2009 
crisis  following  the  Ukraine-Russia  gas  dispute  gave  a  tangible  flavour  of  potential 
consequences of a gas supply crisis in Europe. A 14-days complete cut of Russian gas along 
the Ukrainian corridor resulted in deep economic hardships in several European countries, with 
a collapse in industrial output and severe stress on power systems. For Bulgaria, which was 
among the most affected countries, a 30% shortage of gas supply for a month has been estimated 
to have led to a “total GDP shortfall due to the cut was 0.35% of 2009 GDP, equivalent to a 
9.1% GDP shortfall for the 14-day period of the disruption”163. Similarly, preventing damage 
to critical energy infrastructure is a potential benefit of the EU’s security of supply framework, 
as these incidents can create significant costs, as further detailed in Box 2. 

BOX 2: CASE STUDY – COST OF A PHYSICAL ATTACK ON ENERGY 
INFRASTRUCTURE 

The EstLink2 interconnector is a critical undersea cable linking Finland and Estonia with 
a  capacity  of  650  MW.  It  was  disconnected  from  the  grid  on  26  January  and  on  25 
December 2024, due to damage within the Finnish economic zone. The second disruption 
is  considered  part  of  a  series  of  frequent  incidents,  possibly  systematic  attacks  against 
critical infrastructure in the Baltic Sea.164 The suspected vessel is sanctioned due to it being 
part of the Russian shadow fleet165.  

The Estonian authorities informed the Commission that the first damage of EstLink2 led 
to repairs for a 9 month-period, costing EUR 30 million. According to Estonian authorities, 
at  the time the disruption had significantly  impacted Estonian  consumers due to  higher 
prices, resulting in an additional cost of EUR 94 million. The second outage  resulted in 
total repair costs of ca. EUR 50-60 million. 

163 

https://www.fiw.ac.at/wp-
content/uploads/2023/02/03.ResearchReport.Christie_etal.Vulnerability_and_Bargaining_Power_in_EU_Ru
ssia_Gas_Relations-1.pdf  

See: 

164  See:  Joint  Statement  by  the  European  Commission  and  the  High  Representative  on  the  Investigation  into 

Damaged Electricity and Data Cables in the Baltic Sea | EEAS 

165 The vessel Eagle S is sanctioned through Council Decision (CFSP) 2025/931 of 20 May 2025: Decision - CFSP 

- 2025/931 - EN - EUR-Lex 

57 

 
 
 
 
 
 
There  have  been  several  instances  of  crises  with  severe  economic  impacts  on  society  in 
electricity as well. The 2016 Impact Assessment referred to cases summarised in Table 7, which 
illustrate  the  severity  of  such  incidents  within  the  EU.  Evidence  from  outside  the  EU  also 
illustrates  the  huge  costs  associated  with  severe  energy  supply  disruptions.  For  example,  a 
severe winter storm in Texas caused numerous electricity outages and over 200 deaths, partly 
because of outages of gas-fired power plants.166 The cost was estimated to be $80 billion–$130 
billion in direct and indirect economic loss, with estimates of more easy to quantify insured 
losses ranging between $10 billion to $20 billion.167 It should be noted that this crisis occurred 
in a different socio-economic context, with different market rules and preventive measures in 
place, making a direct comparison with the EU challenging. Nevertheless, both EU examples 
that occurred pre-2016 and extra-EU examples provide case studies to illustrate the impact that 
supply disruptions can have, including in terms of major economic costs.  

Table 1: Overview of significant historical blackouts in Europe168 
Country & Year 

Number of end-
consumers interrupted 

Sweden/Denmark, 2003  0.86 million (Sweden), 
2.4 million (Denmark) 
1.4-3.5 million 

France, 1999 

Italy/Switzerland, 2003 
Sweden, 2005 

55 million 
0.7 million 

Central Europe, 2006 
Source: SESAME  

45 million 

Duration energy not 
served 
2.1 hours, 18 GWh 

2 days – 2 weeks, 400 
GWh 
18 hours 
1 day – 5 weeks, 11 
GWh 
Less than 2 hours 

Estimated costs to 
whole society 
EUR 145-180 million 

EUR 11.5 billion 

EUR 400 million 

More recently, on 28 April 2025, the EU was affected by a very severe blackout in the Iberian 
Peninsula. The blackout  lasted 15 hours 25 minutes in Portugal  and 18 hours 27 minutes in 
Spain. A total of 6.4 million and 44.6 million people were respectively affected.  

There are tools to assess the costs of electricity crises too, as further illustrated in Box 3. The 
‘blackout’ simulator, a software tool co-funded by the Commission, can estimate the economic 
loss associated with electricity blackouts. See Box 3 for further details.  

BOX 3: CASE STUDY - COST OF AN ELECTRICITY CRISIS 

The authors of blackout simulator, an online tool co-funded by the Commission169, show 
a case study of the outage of 28 September 2003, in Italy170. The incident impacted all 
of Italy except for Sardinia. The duration of the blackout was 3, 9, 12 and 16 hours in 
the north of Italy, the centre of the country, the South, and Sicily respectively. The total 
economic losses were EUR 1.2 billion, equivalent to 0.08% of annual GDP. 

166  See  Final  Report  on  February  2021  Freeze  Underscores  Winterization  Recommendations  |  Federal  Energy 

Regulatory Commission 

167 See https://www.dallasfed.org/research/economics/2021/0415  
168 See 2016 Impact Assessment SWD(2016) 410 final. 
169 More information is provided in Annex II on methodology. 
170 See http://blackout-simulator.com/methodology.  

58 

 
 
 
 
 
 
For  this  report,  the  socio-economic  impacts  of  a  second  historical  black-out  were 
simulated,  namely  a  blackout  that  occurred  in  the  Balearic  Islands  on  13  November 
2008. The blackout was triggered by a lightning strike that hit the 260 MW power plant 
in Alcudia, resulting in a power outage that affected ca. 500,000 inhabitants for seven 
hours171. According to the simulator, the black-out would have resulted in 5.29 GWh of 
Energy  Not  Served  (ENS),  and  in  damage  costs  of  EUR  38.48  million172,  which 
represents ca. 0.14% of  annual GDP of the Balearic Islands in 2008173. These results 
indicate that, despite the relatively limited duration and small geographical area affected, 
the economic impacts of the blackout were substantial. 

The importance of preventing gas supply crises is also illustrated by the price impacts of such 
energy crises. As highlighted in Figure 31, the supply cuts from Russia disturbed the supply-
demand  equilibrium  significantly  in  2022.  While the  market  equilibrium was  comparatively 
stable  in  2022  with  pre-crisis  price  levels  at  ca.  25  EUR/MWh  in  2021174,  prices  rose 
significantly directly after a series of Russian supply cuts, peaking in August 2022 at over 300 
EUR/MWh. These record high  wholesale gas prices in  turn created price spikes in  both  the 
retail gas markets (negatively affecting e.g. households), as well as the wholesale electricity 
prices given that gas was the primary price setter for electricity, as shown in Figure 23. The 
effect  of  supply  shocks  on  gas  and  electricity  prices  highlights  the  socio-economic 
consequences of such crises, which the security of supply framework aims to avoid. In contrast, 
the high prices resulting from Russia’s weaponisation of gas supplies also highlights that the 
security of supply framework was not sufficient to shield EU citizens and industries from gas 
supply shocks. 

171 https://www.elmundo.es/elmundo/2008/11/19/baleares/1227133309.html &  
     https://www.elconfidencial.com/mundo/2008-11-13/el-apagon-ha-afectado-a-574-000-clientes-de-mallorca-

y-menorca_933339/  

172 The results are roughly adjusted for inflation, by using an average annual rate of 2%. 
173 See Annex II for more information on the methodology 
174 TTF Day Ahead in January 2021 – June 2021. This period is chosen because from July 2021 onwards prices 

started to rise due to low gas storage levels because of a lack of storage filling by Gazprom.  

59 

 
 
 
 
Figure 31: price impacts of Russian gas supply disruptions in 2022 

Source: Commission, based on S&P Global Platts and ENTSOG Transparency Platform 

The  prevention  of  such  energy  crises  would  be  a  benefit  of  the  EU’s  security  of  supply 
framework but it is difficult to establish causality between the Regulations and the prevention 
of such crises. This is exacerbated by the ‘preparedness-paradox’, meaning that it is impossible 
to know which crises have been prevented by the Regulations, since they have not occurred in 
practice. Overall, however, it can be argued that the potential benefits of these Regulations and 
preventing  potentially  devastating  crises  substantially  outweigh  the  costs,  and  that  the 
interventions improve social welfare. However, there is scope to decrease administrative burden 
(e.g.,  simplifying  administrative  procedures  and  reporting  obligations,  reducing  the  regional 
risk groups) and thus to improve the cost-benefit balance. 

4.1.4.  Coherence 

In  line  with  the  Better  Regulation  toolbox,  the  coherence  criterion  assesses  the  consistency 
within and across the different  provisions  in  the Gas Security of Supply  Regulation  and the 
Electricity Risk-Preparedness Regulation. To this end, this section analyses:  

• 

Internal  coherence, i.e. the coherence between different  measures  (a) within  a single 
Regulation, and (b) within the security of supply framework as a whole 

•  External  coherence,  i.e.  the  coherence  between  the  evaluated  Regulation  and  other 

Regulations, both from (a) the EU energy acquis and (b) beyond. 

Internal coherence (within the regulations per se) 

No  significant  internal  incoherence  was  detected  in  the  Electricity  Risk-Preparedness 
Regulation, nor in the Gas Security of Supply Regulation. The various measures within the two 
Regulations  work  well  together  and  follow  a  logical  sequence,  as  was  further  elaborated  in 
section 4.1.3.  

60 

 
 
 
The  only  incoherence  detected  for  gas,  is  that  the  Crisis  Management  Group  and  the  Gas 
Coordination Group may overlap. While the Crisis Management Group should consist of the 
crisis managers assigned in Member States’ Emergency Plans and should only be active during 
an emergency, in practice they will mostly consist of similar representatives as the GCG which 
operates in pre-emergency. The GCG was instrumental in addressing the energy crisis and has 
been a widely appreciated forum, as supported by several responses to the public consultation. 
Therefore, there is room either for simplification or clarification as regards the role of the Crisis 
Management Group.  

Internal coherence (within the security of supply framework) 

The Regulations were largely coherent with one another and were mostly aligned with the EU’s 
wider  policy  objective.  The  Electricity  Risk-Preparedness  Regulation  and  Gas  Security  of 
Supply  Regulation  were  designed  in  a  similar  way;  they  both  follow  a  risk-based  approach 
using risk assessment and plans, transparency and cooperation is fostered through coordination 
groups,  while  they  both  have  crisis  management  provisions  containing  crisis  levels  and 
emergency cooperation procedures.  

Furthermore,  the  Gas  Security  of  Supply  Regulation  is  also  largely  coherent  with  the  crisis 
measures adopted in 2022. The crisis measures aimed to tackle the Russian gas supply cuts in 
2022 and were specifically designed to complement shortcomings of the Regulation. While the 
Gas Security of Supply Regulation was well equipped to deal with short-term and smaller scale 
supply cuts, it was not designed to tackle prolonged and full supply cuts from the EU’s biggest 
gas supplier. As two Commission reports show175, the 90% storage target could only be met 
through  continued  subdued  gas  demand  due  to  reduced  Russian  supplies.  The  necessity  of 
reducing demand by 15% to reach the storage target and avoid demand curtailment in case of a 
Russian supply disruption was also stressed by ENTSOG, for example in ENTSOG’s Winter 
Supply  Outlook  2024176.  While  the  storage  and  demand  reduction  targets  aimed  to  address 
immediate  security  of  supply  concerns,  the  default  solidarity  provisions  introduced  by 
Regulation  (EU)  2022/2576  ensured  that  if  these  targets  were  not  sufficient,  the  crisis 
management mechanisms would be operational to address a severe emergency. 

However, this fitness checks identifies a number of areas where coherence can be improved, 
most notably: 

1.  The definitions of ‘protected customers’; 
2.  The frameworks for gas storage and electricity storage; 

175 COM(2023) 173 and COM(2024) 88. 
176 "In case of full disruption of Russian pipeline supplies during winter, additional measures might be needed to 
save significant volumes of the gas for the end of the season, and to avoid risk of demand curtailment in case of 
cold winter and peak demand situations. Simulation results showed that the introduction of possible measures, 
such  as  enhanced  capacities,  additional  supplies,  and  a  15%  decrease  in  gas  demand,  would  avoid  demand 
curtailment 
level.” 
reaching 
See: 
https://www.entsog.eu/sites/default/files/2023-10/SO0052-23_Winter%20Supply%20Outlook%202023-
24%20with%20Summer%202024%20Overview.pdf 

adequate 

storage 

allow 

risks 

and 

for 

an 

61 

 
 
 
3.  The coherence between gas supply standards and gas storage targets. 

The coherence between the two legislations can be further improved by aligning the concepts 
of “protected customers” and “special protection against disconnection”. Protected customers 
are defined in the Gas Security of Supply Regulation at EU level and include households, and 
under certain conditions district heating, essential social services and SMEs177. The objective is 
to protect a critical energy need (heating), as well as protect consumers who do not have the 
possibility to negotiate their security of supply conditions (e.g. households). In the Electricity 
Risk-Preparedness Regulation, ‘users entitled to special protection against disconnection’ are 
defined  nationally  to  protect  public  safety  and  personal  security,  which  usually  include 
consumers in e.g. the transport, health, and public security sectors, in line with Commission 
Recommendation (EU) 2020/775. While there are reasons for this difference stemming from 
the differences in the management of gas and electricity grids, there is a risk that both concepts 
could become un-operational in case of a cross-sectoral or cascading crisis. For example, gas 
boilers  in  households  need  electricity  to  function,  meaning  that  misalignment  may  result  in 
lower overall protection of households. The fact that households do not necessarily qualify as 
‘protected customers’ in electricity, while they do in gas, could arguably constitute a hurdle to 
electrification in the longer term. Customers may feel less protected and could be more reluctant 
to change. Similarly, it should be noted that there is no mandatory supply standard in electricity 
legislation. 

The  coherence  between  the  frameworks  on  gas  storage  and  electricity  storage  could  be 
improved. While the former is an already existing security of supply tool of EU energy policy, 
the latter is less regulated at EU-level. However, the solutions to store electricity (e.g., batteries, 
thermal  storage,  hydrogen)  are  developing  fast  and  will  be  essential  for  the  reliability  and 
stability of the future energy system. Electricity storage is crucial to manage peak loads and 
integrate variable renewables e.g. during ‘dunkelflaute’ events such as the ones in November 
and December 2024178. The Commission estimated in 2023 that “the need for flexibility in the 
electricity system will increase significantly in all Member States, reaching 24 % (288 TWh) of 
total electricity EU demand in 2030 and 30 % (2 189 TWh) by 2050 across all timescales”179. 
The new Electricity Market Design introduced an obligation for Member States to perform a 
national assessment of flexibility needs, based on an EU methodology, and to set an indicative 
national  objective  for  non-fossil  flexibility  (including  energy  storage).  In  the  public 

177 Essential social services, district heating and SMEs can be included, provided that they do not jointly represent 
more  than  20  %  of  annual gas  consumption  in  a  Member State.  SMEs  are  excluded  from  the  category  of 
‘solidarity protected customers’, which are the consumers that are eligible to receive solidarity volumes during 
an emergency.  

178 IEA report of 2025 included a case study on dunkelflaute events, temporary periods with reduced wind and 
solar PV generation, stressing the importance of having sufficient flexibility measures, such as dispatchable 
capacity, 
interconnections: 
as 
https://iea.blob.core.windows.net/assets/0f028d5f-26b1-47ca-ad2a-5ca3103d070a/Electricity2025.pdf  

demand-side 

(long-term) 

flexibility 

as  well 

storage, 

and 

179 SWD(2023) 57 final. 

62 

 
 
 
consultation, some participants called for a more unified energy storage policy, defining storage 
needs for security of supply adapted to end user consumption, irrespective of the energy carrier.  

There  is  also  a  certain  overlap  between  the  supply  standard  and  the  90%  gas  storage  target 
adopted in 2022180. The supply standard and storage target lead to similar outcomes, namely 
that sufficient gas volumes are available to ensure security of supply during challenging times. 
Storage booking is one of the main options available to energy undertakings to comply with the 
supply standard. The layer of storage filling obligations had to be added because of the severity 
of the crisis in 2022. While they are not inconsistent with one another, there may be scope for 
alignment and simplification. 

The views of the participants to the public consultation were varied when asked about whether 
inconsistencies had arisen in the recent years between the two Regulations. Around 30% of the 
respondents answered “yes”, 20% answered “no”, while around half of the respondents did not 
express  any opinion. Participants notably stressed that interdependence between the gas and 
electricity sectors was insufficiently addressed in the existing Regulations, and that an increased 
focus on cross-sectoral integration would create a more cohesive and efficient energy system. 
Integrated  risk  assessments,  harmonised  crisis  declaration  procedures,  and  cross-sectoral 
exercises were notably mentioned as possible areas for improvement. Participants also stressed 
that  the  analysis  of  critical  gas  volumes  within  electricity  adequacy  outlooks  was  an 
improvement to build cross-sectoral scenarios. The Commission has also raised the insufficient 
coordination  between  gas  and  electricity  measures  in  several  opinions  on  national  gas  and 
electricity plans (e.g. insufficient assessment of spillover effects of a gas crisis in the electricity 
sector or the justification of why that assessment would not be relevant). 

When  asked  about  potential  policy  areas  where  synergies  between  the  electricity  and  gas 
security of supply frameworks can be sought, respondents predominantly answered “yes” to all 
proposed  options  (cf.  Figure  32).  This  tends  to  show  that  there  is  a  perception  among 
respondents to the public consultation that the complementarities between the two frameworks 
could be improved. The policy areas that received most support in this regard were the plans 
and the risk assessments/scenarios.  

180 In June 2025, a political agreement was reached to extend the Gas Storage Regulation until 2027. 

63 

 
 
 
Figure 32: Public consultation: answers to question on the potential areas where synergies 
between gas and electricity framework could be improved 

Source: DG ENER, based on public consultation responses181 

External coherence (other energy legislation) 

While there are clear interactions between the Risk Preparedness Regulation and the Electricity 
Regulation,  there  is  limited  overlap  between  the  two.  The  Electricity  Regulation  looks  at 
medium-to-long term adequacy (up to 10 years ahead) of the electricity system and provides a 
framework for Member States to be able to introduce schemes to procure capacity for security 
of supply (‘capacity mechanisms’). By contrast the Risk Preparedness Regulation focuses on 
short-term  adequacy  (‘seasonal  outlooks’)  and  the  measures  that  can  be  taken  to  tackle 
imminent electricity crises.  

However,  for  example  ACER  argued  that  there  is  room  to  strengthen  the  complementarity 
between  the  two  frameworks.  In  its  2023  report  on  security  of  electricity  supply,  ACER 
recommended  “exploring synergies between the  two frameworks, i.e., Electricity Regulation 
and the Risk Preparedness  Regulation,  informed  inter alia by  early lessons drawn from the 
energy crisis. Such synergies may in turn illustrate the utility or otherwise of further guidance 
on  the  types  of  measures  that  could  be  introduced  under  the  latter  framework”182.  Some 
participants to the public consultation also expressed concerns regarding the lack of attention 
to long-term electricity security of supply in the Risk Preparedness Regulation.  

181See: 

https://eepublicdownloads.entsoe.eu/clean-

documents/SOC%20documents/Nordic/Nordic%20SOA_Annex%20OS.pdf 

182See:https://acer.europa.eu/sites/default/files/documents/Publications/Security_of_EU_electricity_supply_2023

.pdf 

64 

 
 
 
 
Figure 33: visual representation of Risk Preparedness Regulation interaction with System 
Operation Guidelines and Emergency and Restoration Network Code 

Source: European Commission 

Other  electricity-specific  regulations  that  have  interactions  with  security  of  supply  notably 
include the System Operation Guidelines and the Emergency and Restoration network code. In 
the  public  consultation,  some  participants  highlighted  the  unclear  links  between  the  two 
frameworks as a potential loss of effectiveness. However, a cautious assessment tends to show 
limited  overlap.  Recital  5  of  the  Risk  Preparedness  Regulation  asserts  that  the  two  network 
codes  are  “a  detailed  rulebook  governing  how  transmission  system  operators  and  other 
relevant stakeholders should act and cooperate to ensure system security (…) [to] ensure that 
most electricity incidents are dealt with effectively at operational level”. By contrast, the Risk 
Preparedness Regulation deals with events with larger scale and impact, for which operational 
rules no longer suffice, and should fully respect operational rules even in times of electricity 
crisis. In fact, no inconsistency was experienced during the implementation. 

The  EU  framework  on  security  of  electricity  and  gas  supply  and  energy  infrastructure 
complement each other by ensuring a secure and interconnected energy system. While the TEN-
E  Regulation  supports  the  development  of  cross-border  energy  infrastructure  projects  to 
strengthen security of supply, the EU security of electricity and gas supply framework oversees 
security of supply at Union level and strengthens emergency preparedness.  

The Electricity Risk Preparedness Regulation requires Member States to “include information 
on related and necessary plans for developing the future grid” (even if the first RPPs contained 
little  information  on  this  aspect)  and  ECG  to  discuss  the  results  of  Ten-Year  Network 

65 

 
 
 
development plan (TYNDP). This is meant to ensure a forward-looking approach to security of 
supply at EU level. Also, under the TEN-E Regulation183, “security of supply” is included as a 
specific  criterion  for  the  assessment  of  Projects  of  Common  Interest  (PCIs)  and  Projects  of 
Mutual  Interest  (PMIs).  Supporting  such  projects  –  particularly  through  CEF  funding  for 
infrastructure such as  interconnectors  – strengthens cross-border networks and enhances  the 
security  of  electricity  supply.  Article  4  of  TEN-E  Regulation,  which  provides  general 
definitions of the “security of supply” criterion for each infrastructure category, notably refers 
to LOLE indicator. The methodology for assessing electricity projects’ contribution to security 
of  supply  developed  by  ENTSO-E  in  the  guidelines  for  cost-benefit  analyses  of  grid 
development projects explicitly includes EENS as an indicator. Hence, both Regulations are 
consistent in their approaches to assess electricity security of supply. 

The synergy between the Gas Security of Supply Regulation and the previous version of the 
TEN-E Regulation was evident until the latter's update in 2022. The Gas Security of Supply 
Regulation's emphasis on resilient and diversified infrastructure was reinforced by the TEN-E 
Regulation,  granting  them  highest  national  priority  status  and  ensuring  their  inclusion  in 
national network development plans. The European Grids Package proposed on 10 December 
aims  at  accelerating  the  development  of  grids  and  other  physical  infrastructure,  while 
strengthening the security and resilience of cross-border infrastructure. In addition, the TEN-E 
framework  provides  regulatory  support,  guidance  on  cross-border  cost  allocation  and  risk-
sharing, and access to CEF funding, thereby enabling the timely development of key energy 
infrastructure projects. These projects contributed to N-1 and reverse flow standards outlined 
in the Gas Security of Supply Regulation. However, the current TEN-E framework no longer 
covers  natural  gas  infrastructure  development.  Some  respondents  to  the  public  consultation 
highlighted  this  as  an  inconsistency.  While  being  consistent  with  the  EU’s  decarbonisation 
commitments, it makes fulfilling the N-1 indicator more difficult. 

External coherence (other policy areas) 

Both Regulations are coherent with wider EU policy objectives, in particular with the Green 
Deal and ensuring European competitiveness. The energy crisis showed that without securing 
the availability of sufficient energy supplies, the competitiveness of the EU is at risk, as also 
emphasised  by  the  Draghi  Report184.  On  this  basis,  the  Commission’s  Competitiveness 
Compass185 has introduced security as one of the three pillars for the Commissions’ upcoming 
activities. As such, security, and energy security more specifically, will be a key element that 
will be considered in  the future Commission  activities as  announced in  the Clean  Industrial 
Deal and Affordable Energy Action Plan.  

183 Regulation (EU) 2022/869. 
184 

See: 

https://commission.europa.eu/document/download/ec1409c1-d4b4-4882-8bdd-

3519f86bbb92_en?filename=The%20future%20of%20European%20competitiveness_%20In-
depth%20analysis%20and%20recommendations_0.pdf 

185 See: 10017eb1-4722-4333-add2-e0ed18105a34_en 

66 

 
 
 
Similarly,  the  energy  transition  and  energy  security  are  two  sides  of  the  same  coin.  Energy 
security  is  needed  to  facilitate  an  orderly  phase  out  of  fossil  fuels  and  to  ensure  public 
acceptance of the energy transition. However, specific provisions of the Gas Security of Supply 
Regulation may require adaptation to ensure it stays aligned with the EU’s climate objectives 
and to avoid a carbon lock-in. This includes in particular the infrastructure standard and the gas 
storage target (as further outlined in section 4.3.2.).  

Both  the  evaluated  Regulations  are  coherent  with  wider  EU  crisis  response  mechanisms, 
notably  the  EU  Civil  Protection  Mechanism  and  the  Commission’s  Emergency  Response 
Coordination  Centre  (ERCC).  While  the  measures  in  the  Electricity  Risk-Preparedness 
Regulation and Gas Security of Supply Regulation are aimed at mitigating root causes of an 
energy crisis, the ERCC focuses on providing instant (humanitarian, financial or other) relief. 
The  ERCC  has  to  be  notified  by  Member  States  in  case  of  a  declaration  of  national  gas 
emergency,  while  the  Risk  Preparedness  Regulation  clearly  states  that  the  actions  for  risk 
prevention, preparedness and planning should be consistent with the risk assessments required 
under the Union Civil Protection Mechanism.  

Both evaluated Regulations are coherent with the EU’s wider security and resilience policy. 
The Gas Security of Supply Regulation includes risk assessments that consider relevant risk 
factors such as natural disasters, technological, political and other risks. Likewise, the Risk-
Preparedness Regulation establishes a methodology for the identification of electricity crisis 
scenarios based on, among others, risks such as rare and extreme natural events and malicious 
attacks. The Directive on the Resilience of Critical Entities186 (CER Directive) is the main piece 
of EU legislation enhancing the resilience of the operations of critical infrastructure protection, 
including energy sector infrastructure. The Directive explicitly states that Member States must 
take into account in their risk assessments other risk assessments carried out in accordance with 
the  requirements  of  relevant  sector-specific  legislation.  This  includes  the  Gas  Security  of 
Supply Regulation and the Risk-Preparedness Regulation, ensuring overall coherence between 
the frameworks. The CER Directive is in the early stages of implementation187 and therefore it 
is yet not possible to assess more concretely the synergies with the energy security framework. 
Regarding  the  predecessor  of  the  CER  Directive,  the  European  Critical  Infrastructure 
Directive188 no inconsistency had been detected. 

The protection of infrastructure also expanded to the digital space. The EU aims for an energy 
system that is smarter and more interactive than it is today189. This implies a different way of 
managing the network, relying on more real-time data access and exchange as well as digital 
technologies. The electrification of end-use sectors, and the more pro-active role that electricity 
consumers will play in the electricity system, will add many new stakeholders and consequently 
new entry points for cybersecurity concerns. The digitalisation of the energy system can deliver 

186 Directive (EU) 2022/2557 
187 Most Member States are still in the process of transposing the Directive into national legislation, despite the 

deadline having passed in October 2024. 

188 Directive 2008/114/EC 
189 See notably the EU Action plan for Digitalising the energy system (COM(2022) 552 final). 

67 

 
 
 
a strong contribution to energy security and climate goals  but also brings new cybersecurity 
challenges for EU energy infrastructure.  

For the energy sector, the NIS2 Directive190, covers electricity, district heating and cooling, oil, 
gas and hydrogen. This includes notably to take all appropriate and proportionate measures to 
manage the risks posed to the network and information systems that they use for their services, 
including  in  relation  to  their  supply  chain  and  to  report  significant  incidents  under  this 
Directive.  The  NIS2  Directive  also  provides  an  empowerment  for  the  Commission  to  adopt 
implementing  acts  among  other  further  introducing  sectorial  requirements.  In  addition,  the 
Regulation on horizontal cybersecurity requirements for products with digital elements, known 
as  the  Cyber  Resilience  Act,  bolsters  cybersecurity  rules  to  ensure  a  more  secure  hard-  and 
software. 

The Network Code on sector specific rules for cybersecurity aspects of cross-border electricity 
flows191 builds on the above-mentioned horizontal EU cybersecurity framework. This Network 
Code entered into force 13 June 2024 and includes rules on common minimum requirements, 
planning, monitoring, reporting and crisis management. This network code is fully compatible 
with  the  horizontal  framework  and  intends  to  make  efficient  use  of  existing  reporting 
obligations.  As  a  rule,  the  scope  of  application  is  aligned  with  the  NIS2  Directive  but  the 
Network Code could also include entities that might not fall within the size-cap criteria of the 
Directive, while being critical or important for electricity. For the gas sector, the amendments 
to the Gas Security of Supply Regulation introduced by Regulation (EU) 2024/1789 include an 
empowerment to adopt network codes establishing gas sector-specific cybersecurity rules for 
cross-border gas flows.  

Critical raw materials (CRMs) are indispensable for the EU’s clean energy transition, especially 
for  key  technologies  such  as  wind  turbines,  solar  panels,  and  batteries.  Their  secure  and 
sustainable supply is critical to achieve the EU's climate and energy targets. The EU Critical 
Raw  Materials  Act  (CRMA)  aims  to  diversify  sourcing,  boost  domestic  production,  and 
promote recycling of CRMs to reduce dependency on third countries. The CRMA complements 
the  EU's  security  of  supply  framework,  as  the  framework  for  security  of  electricity  and  gas 
supply underpins the stability of the EU energy system, while the CRMA secures the materials 
needed for the medium- and long-term development of clean energy infrastructure. Critical raw 
materials  will  be  increasingly  relevant  for  the  future  energy  system,  as  will  be  discussed  in 
section 4.3.2. 

4.2.  How did EU action make a difference and to whom?  

The  EU-level  actions  were  successful  in  achieving  EU-level  coordination,  increasing 
transparency among Member States and jointly addressing risks. This has been demonstrated 
in particular during the energy crisis of 2021-2023, where measures to address unilateral supply 

190 Directive (EU) 2022/2555 on measures for a high common level of cybersecurity across the Union. 
191 Commission delegated regulation (EU) 2024/1366. 

68 

 
 
 
cuts from Russia have been coordinated in a unified way. Coordination through EU-level fora 
such as the TTE Council, the ECG and GCG proved to be valuable tools and were praised as 
such in the public consultation answers. 

The 2016 Commission’s proposal for the Security of Gas Supply Regulation argued that the 
necessity of EU action was based on:  

i. 

ii. 

iii. 

iv. 

“The increasing interconnection of the EU gas markets and the ‘corridor’ approach for 
enabling the reverse flows on gas interconnectors call for interconnected measures”;  
“Without such coordination, national security of supply measures are likely to adversely 
affect other Member States or the security of supply at EU level”;  
“The risk of a major disruption of gas supplies to the EU is not restricted to national 
boundaries and could affect several Member States, whether directly or indirectly”; 
“National approaches both result in sub-optimal measures and aggravate the impact of 
a crisis”.  

Respondents  to  the  public  consultation  largely  agreed  that  the  2021-2023  energy  crisis  had 
confirmed these statements. Some respondents also highlighted that the emergency measures 
were  a  demonstration  of  the  need  for  EU-wide  measures  to  avoid  sub-optimal  national 
uncoordinated  measures.  Both  Regulations  clearly  improved  cross-border  cooperation.  Both 
Regulations  allowed,  for  example,  better  identification  of  regional  supply  risks  and  create  a 
shared understanding of security of supply across regions.  

In  electricity,  this  was  achieved  through  the  two  assessments  of  regional  crisis  scenarios 
performed by ENTSO-E, and on which national crisis scenarios had to be based. The exercise 
was  further  refined  throughout  the  implementation  period,  thanks  to  an  update  of  the 
methodology, which led to a closer involvement of RCCs for the identification cross-border 
risks and to more emphasis on simulations at regional level. The improvement of the second 
regional crisis scenario report was recognised by Member States. 

Thanks to  the Gas Security of Supply  Regulation,  Member States developed Common Risk 
Assessments in regional risk groups. In this framework, Member States jointly assessed relevant 
risk  factors  which  could  lead  to  the  materialisation  of  a  major  transnational  risk,  including 
disruption of gas supply from the single largest supplier.  

Nevertheless, some shortcomings still persist:  

•  The methodology used for regional electricity crisis scenarios assessment lacked early 

top-down consistency checks to ensure full consideration of regional aspects. 

•  The  governance  structure  of  regional  risk  groups  in  gas  is  weak.  No  Member  State 
volunteered to coordinate the North-Eastern risk group, while the Commission’s Joint 
Research Centre had to provide extensive support to multiple groups.  

The level of cross-border cooperation was spurred by the pivotal role played by the ECG and 
the GCG, especially during crises. This is embodied by the dramatic increase of the number of 

69 

 
 
ECG  and  GCG  meetings  during  the  last  years.  In  its  2022/2023  winter  outlook,  ENTSO-E 
asserted that “cross-border cooperation and close coordination at all levels [would] be key this 
winter to ensure that the European power system maintains its balance between supply and 
demand”, stressing the importance of the two coordination groups192. Both the GCG and the 
ECG proved valuable a in case of crisis situations, as the declaration of crisis levels and their 
reasons were immediately shared and discussed within the groups.  

However,  in  the  public  consultation,  some  participants  raised  the  over-reliance  of  the  Risk 
Preparedness Regulation on national measures. They argued that, by prioritising national plans, 
the  Regulation  may  inadvertently  encourage  Member  States  to  overly  rely  on  national 
measures, hampering regional cooperation. However, many Member States wanted to retain a 
degree  of  decision  on  what  severe  risks  are  and  whether  to  protect  certain  categories  of 
consumers (e.g. risk appetite). Nevertheless, promoting regional plans by Member States (in 
particular smaller ones) could be explored instead of national ones. 

The two Regulations provided a first framework to operationalise the energy solidarity principle 
in case of emergencies, but implementation did not meet expectations. In gas, only 9 solidarity 
agreements out of the 40 required have been signed at the time of writing, and when Russia 
launched  its  full-scale  invasion  of  Ukraine,  there  were  only  three  in  place.  Consequently, 
emergency cooperation was not operational until default solidarity agreements were introduced 
by  the  Solidarity  Regulation  and  later  by  the  Hydrogen  and  Gas  Market  Decarbonisation 
Package.  In  electricity, where it is  referred to  as cooperation and assistance, the situation is 
similar  though  the  Regulation  is  more  recent.  The  information  about  regional  and  bilateral 
measures to cooperate in the prevention or management of a crisis was deemed incomplete in 
RPPs:  only  9  Member  States  referred  to  existing  arrangements  and  had  identified  measures 
(even if not complete enough).  

However,  even  if  solidarity  and  assistance  provisions  were  never  triggered,  they  are  largely 
recognised as  necessary  and useful.  Participants of the two “dry run” exercises of 2022 and 
2024  concluded  that  having  an  operational  solidarity  framework  was  necessary  in  case  of  a 
crisis. However,  respondents  to  the public  consultation  pointed that  implementation barriers 
were  experienced,  due  to  e.g.  operational  complexity.  In  electricity,  there  has  not  been  any 
similar testing of the provisions at EU level (it was not mandatory). However, some areas for 
improvement of the regulatory framework have been identified during the workshops held at 
the ECG. In particular, there have been complaints about mandatory ‘financial agreements’, 
which was considered too restrictive, as some Member States would prefer non-financial ones. 
An approach based on wider “economic” agreements could offer more flexibility.  

The two “dry run” exercises of 2022 and 2024 represent an important and tangible example of 
EU added value, in terms of coordination and cooperation. It is instrumental to ensure that non-
market-based measures implemented by individual Member States do not have an undue effect 
on the functioning of the market and do not deteriorate the security of gas supply situation in 

192 See: Winter Outlook 2022-2023_Report.pdf 

70 

 
 
 
other Member States. Currently, there are no specific provisions in the Gas Security of Supply 
Regulation  for  organising  such  exercises,  but  Member  States  welcomed  both  exercises  and 
called for the Commission to organise such EU-wide security of gas supply “dry run” exercise 
every two years. 

The  framework  was  arguably  successful  in  preventing  cross-border  restrictions.  This  is  an 
important result from an EU perspective, as restrictive national measures can worsen security 
of supply tensions and are detrimental for building trust between Member States.  Continued 
cooperation,  especially  during  crises,  is  crucial  to  reduce  the  negative  impact  on  the  EU’s 
collective  welfare  and  citizens’  well-being.  Cooperation  can  help  to  share  the  burden  and 
thereby  avoid  curtailment  of  the  most  vulnerable  in  society.  An  example  of  a  cross-border 
restriction  occurred  in  January  2017,  before  the  adoption  of  the  two  evaluated  Regulations, 
when  Bulgaria  imposed  a  long-term  export  ban  on  electricity,  leading  to  substantial  price 
increases on power markets in Greece and Romania193. During the implementation period, and 
while  the  EU  faced  one  of  the  most  severe  energy  crises  in  its  history,  no  Member  States 
implemented  measures  restricting  cross-border  trade.  For  gas,  the  Solidarity  Regulation 
strengthened  the  role  of  the  Commission  to  lift  undue  cross-border  restrictions  imposed  by 
Member  States  on  cross-border  flows  during  a  crisis,  a  provision  that  was  praised  by 
participants during the dry run in 2022.  

However,  in  October  2022  Germany  introduced  a  gas  neutrality  charge  to  refinance  costs 
incurred when filling gas storages to meet the filling obligations. This levy was charged at all 
cross-border points and thus had a substantial impact on cross-border gas flows and was harmful 
for the internal market and the EU security of gas supply. It proved an obstacle to phasing out 
Russian  pipeline  gas,  as  alternative  routes  for  Member  States  from  the  Central  and  Eastern 
Europe region became more expensive. In this case, the framework proved to be insufficient in 
preventing and resolving the situation, even if the neutrality charge is not active anymore since 
1 January 2025.194 This may partly explain why, in the public consultation, the performance of 
the  Gas  Security  of  Supply  Regulation  was  deemed  the  least  effective  on  the  objective: 
“Enhance regional and EU-wide cooperation, even in times of crisis” (even if it should be noted 
that the feedback was still positive, overall). 

To combat the 2021-2023 energy crisis, the EU also adopted crisis measures which were more 
effective to address cross-border risks compared to individual actions from Member States. For 
example, a 15% gas demand reduction target at EU level, rather than at national level, ensured 
that  demand  could  be  reduced  where  it  was  most  efficient.  Consequently,  a  wide  variety  of 
results  between  Member  States  was  observed  (ranging  from  -42%  in  Denmark  to  +7%  in 
Malta), reflecting different consumption patterns between Member States while not hampering 
the achievement of the result at the EU-level (demand was cut by 18% between August 2022 

193 See: Managing Critical Grid Situations – a Market Analysis 
194 On 23 December 2024 Germany adopted the “Drittes Gesetz zur Änderung des Energiewirtschaftsgesetzes” 
amending §35e194 of the “Energiewirtschaftsgesetz”, as published on BGBl. 2024 I Nr. 448 vom 30.12.2024. 
It determines that from 1 Jan 2025 the gas neutrality charge will no longer be levied at cross-border exit points. 
Therefore, the addressed concern has been solved. 

71 

 
 
 
and December 2024, compared to the 5-year reference, saving ca. 176 bcm of gas).195 Besides, 
the  Storage  Regulation  included  a  burden  sharing  mechanism,  obliging  that  Member  States 
without  storage  facilities  contribute  to  filling  the  storages  of  Member  States  with  storage 
facilities. This contributed to make the EU response to the crisis more efficient, compared to 
national and uncoordinated measures.196 

The  two  Regulations  contributed  to  improve  transparency  and  information-sharing  among 
Member  States  and  market  actors.  This  was  confirmed  by  the  public  consultation,  with 
“Improving  transparency  and  information  sharing”  being  the  objective  where  respondents 
rated the Risk Preparedness Regulation highest. The Regulations established 27 PAPs and EPs 
(with the United Kingdom in 2019, and without Cyprus) and 28 RPPs (with Northern Ireland) 
that were consulted with domestic market participants and other Member States. For both gas 
and electricity, it is an obligation to share draft plans with other Member States, to provide them 
the opportunity to make comments. A three-day session of the ECG was organised to present 
and discuss the RPPs. The plans being publicly available is valuable for Member States and 
market participants, as they can now anticipate measures that could be implemented in a crisis. 
This is a significant contribution to meeting the policy objectives of improving transparency 
and information sharing.  

The Gas Security of Supply Regulation has provisions to foster transparency and avoid security 
of supply risks stemming from nationally concluded supply contracts at EU level. Article 14 
provides an obligation on Member States to notify to the Commission information related to 
gas supply contracts to assess the security of supply situation. It also allows the Commission to 
directly receive the gas supply contracts under specific and duly justified circumstances from 
gas undertakings. However, the enforcement provisions could be further specified to reinforce 
the EU added value of the measure. This is necessary to ensure effective implementation to 
strengthen security of supply and diversification while preserving confidentiality of commercial 
information, also to facilitate the proposed provisions of the REPowerEU roadmap.  

The two Regulations provided an adequate framework to share information between Member 
States  after  incidents,  e.g.  during  GCG  meetings  in  September  2022  and  October  2023 
following  the  Nord  Stream  and  Balticconnector  disruptions.  ECG  meetings  were  held  in 
January  2021  following  a  scale  2  incident  splitting  the  European  electricity  system  in  two 
regions197,  and  in  October  2024  following  an  incident  in  the  South-East  of  the  Continental 
Europe power system.198  

195 See COM reports on Regulation (EU) 2022/1369 COM(2023) 173, SWD(2023) 63 and COM(2024) 88 
196 See Commission reports reviewing the Storage Regulation COM(2023) 182, COM(2024) 89 and COM(2025) 

98 

197  See:  https://www.acer.europa.eu/news-and-events/news/continental-europe-electricity-system-separation-
incident-8-january-2021-next-steps 
198 The incident resulted in a partial black-out in Albania, Montenegro, Bosnia-Herzegovina and Croatia 

72 

 
 
 
4.3.  Is the EU action still relevant? 

This section looks at the relevance of the security of supply framework consisting of: 

•  Past  relevance:  the  relationship  between  the  needs  and  problems  at  the  time  of 

introducing the Regulations and during its implementation.  

•  Future relevance: the relationship between the current and future needs and problems 

in the EU and the objectives of the Regulations.  

4.3.1.  Past relevance 

The evaluation  period was marked by the COVID-19 pandemic, the energy crisis,  recurrent 
geopolitical turbulences and the rise of attacks on EU energy assets (e.g. Nord Stream pipelines, 
EstLink-2  electricity  cable).  During  these  challenging  times,  the  need  to  ensure  a  match 
between supply and demand and make the EU energy system resilient to (external) shocks and 
putting  in  place  appropriate  tools  to  prepare  for  and  manage  crises  has  remained  relevant. 
However, some needs have either emerged or  gained importance during the implementation 
period. These needs include:  

•  Diversification of gas suppliers  
•  Emerging cross-sectoral risks  
•  Cybersecurity threats  
•  Critical  infrastructure  needs,  such  as  cross-border,  environmental  as  well  as  climate 

risks  

These needs were only partially addressed by the framework, lowering its overall relevance for 
achieving the general and specific objectives that had been set when it was adopted. 

This  section  examines  the  relevance  of  the  specific  objectives  outlined  in  section  2,  in 
particular: 

• 
• 

Improving regional cooperation and transparency. 
Improving assessment of risks and preparedness. 

The  objective  of  improving  regional  cooperation  in  gas  responded  to  the  lack  of  solidarity 
actions between Member States that had been brought to light by the 2009 crisis. In electricity, 
the objective of spurring information-sharing responded to the lack of transparency of national 
plans for crisis situations, which hindered cooperation with neighbouring countries and caused 
uncertainty for businesses. All these objectives remained relevant across the evaluation period 
until  today:  information-sharing,  adequate  infrastructure  and  crisis  management  procedures, 
among others, remain valid principles to ensure the resilience of the EU’s energy system. The 
specific protection granted to households in times of crises became even more relevant, with 
the proclamation of the European Pillar of Social Rights in December 2017 which recognized 

73 

 
 
 
the  right  of  everyone  to  “access  essential  services  of  good  quality,  including  (…)  energy” 
(Principle 20)199.  

The current plans and risk assessments (or regional crisis scenarios in electricity) were useful 
in identifying relevant risks but only to a certain extent. For example, a full Russian supply 
disruption was simulated in most national gas risk assessments, which was crucial for Member 
States  to  prepare  for  supply  cuts  that  occurred  in  reality.  However,  ongoing  diversification 
efforts and phasing out Russian fossil fuels are not adequately covered in these assessments and 
plans. For electricity, relevant scenarios were identified but their depth was limited (as reflected 
in the Commission opinions on the Risk Preparedness Plans) and this was later confirmed by 
the fact that Member States had to re-run scenarios to decide on ad hoc measures during the 
energy crisis. 

Therefore, while the plans and risk assessments have largely responded to the needs they were 
supposed to address, several areas will require further adaptation to assess relevant security of 
supply risks. In particular, the plans and risk assessments should be adapted to better  reflect 
emerging risks, such as cybersecurity, physical and hybrid threats200 to critical infrastructure, 
climate change impacts and cross-sectoral risks between gas and electricity: 

•  Cross-sectoral  risks  were  considered  in  18  out  of  25  national  gas  risk  assessments, 
although they mostly concerned short-term failures, which due to their assumed short 
duration  were  not  considered  impactful.  Many  electricity  RPPs  submitted  during  the 
energy crisis did not sufficiently consider the relevance of a gas shortage affecting the 
electricity system. At the Commission’s request, ENTSO-E calculated in 2022 for the 
first  time “critical  gas  volumes” for electricity although this was not  required by the 
legal framework.  

•  Cybersecurity  risks  were  identified  in  14  out  of  25  national  gas  risk  assessments, 
although in most cases it remains unclear whether sufficient preventive measures are 
implemented. Similarly, as indicated in several Commission opinions on the electricity 
RPPs, cybersecurity risks to  the electricity  system  need to  be better accounted for201. 
The 2024 gas dry run also showed that in case of a cyber-attack, TSOs were able to 
switch  to  backup  systems  and  use  alternative  communication  channels,  although 
coordination  between  cyber  and  operational  experts  within  TSOs  must  be  better 
integrated in  response procedures. The  EU’s 2024  Cyber Posture Risk  Assessment202 

199 Interinstitutional Proclamation on the European Pillar of Social Rights (2017/C 428/09), 13 December 2017: 

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017C1213(01)&rid=2 

200 Hybrid threats combine conventional and unconventional, military and non-military activities that can be used 
in  a  coordinated  manner  by  state  or  non-state  actors  to  achieve  specific  political  objectives.  See: 
https://www.eeas.europa.eu/sites/default/files/hybrid_threats_en_final.pdf  

201 In its opinions the Commission suggested elements that should be included in the description of crisis scenarios.  
202  Council,  in  its  May  2022  Conclusions  on  the  EU’s  cyber  posture,  requested  the  Commission,  the  High 
Representative,  and  the  NIS  Cooperation  Group  (NIS  CG)  to  carry  out  a  risk  evaluation  and  develop 
cybersecurity  risk  scenarios  in  a  situation  of  threat  or  possible  attack  against  Member  States  or  partner 
countries. See Risk assessment report on cyber resilience on EU’s telecommunications and electricity sectors 
| Shaping Europe’s digital future 

74 

 
 
 
concluded  that  for  electricity,  the  highest  identified  risk  concerns  entities  directly 
connected to the electricity grid. The report concludes that the most salient threats come 
from insiders who infiltrate organisations or are manipulated, along with cyberattacks 
using ransomware and malware to disrupt operational technology relied on by gas or 
electricity producers.  

•  Physical  threats  to  critical  infrastructure  were  identified  in  12  out  of  25  gas  risk 
assessments,  usually  terrorist  attacks  or  sabotage.  The  focus  generally  lays  on  the 
assessment or mitigation of the impact of resulting security of supply disruptions, rather 
than  addressing  the  risk  to  infrastructure  itself,  which  affects  the  ability  to  define 
preventive actions and may lead to increased costs for consumers. In its opinions on 
electricity RPPs, the Commission  recommended  most  Member States to  take critical 
infrastructure better into account. Moreover, the 2024 gas dry run indicates that in case 
of a crisis, coordination procedures between critical infrastructure protection and energy 
security Competent Authorities could benefit from further clarification.  

•  Environmental threats, climate change and natural disasters were considered in 13 
out of 25 national gas risk assessments, e.g. floods or storms affecting LNG shipments 
or  damaging  critical  infrastructure.  However,  climate  change  aggravating  these  risks 
was  only  briefly  mentioned  by  1  national  risk  assessment  and  was  otherwise  not 
considered. The Risk Preparedness Regulation requires the methodology for identifying 
regional electricity crisis scenarios to consider ‘rare and extreme natural hazards’. The 
electricity  RPPs  refer  to  several  weather  events,  but  the  depth  of  the  assessment  is 
limited, and the Commission opinions recommended to several Member States to take 
climate change impacts better into account, as its relevance was demonstrated by e.g. 
the low hydro and nuclear availability during a drought in summer 2022. 

While these risks are included in a non-exhaustive list in the Regulations as the risk categories 
to assess, Member States are only obliged to assess these risks if they deem them relevant. In 
other words, there is no obligation for Member States to assess all these risks. Therefore, when 
Member States do not include such risks, it is not in all instances sufficiently clear whether 
these  risks  have  been  assessed  but  not  considered  relevant,  or  whether  they  have  not  been 
considered at all. The framework may benefit from further clarity about the risks that have been 
discarded.  

4.3.2.  Future relevance 

The objectives served by the EU’s security of electricity and gas supply framework will remain 
relevant  for future needs and problems,  but  an adaptation of the Regulations are  required to 
ensure  continued  relevance  in  the  future.  This  section  identifies  the  following  future 
developments that should be considered to keep the framework relevant: 

1.  The role of electricity and natural gas in a decarbonised, electrified and more integrated 

energy system 

75 

 
 
2.  The protection of consumers and critical energy needs considering electrification and 

the phase out of natural gas; 

3.  The role of new energy carriers, like biomethane and hydrogen, in energy security; 
4.  The  importance  of  diversification  due  to  geopolitical  changes  and  reliance  on 

homegrown clean energy sources; 

5.  The role of critical raw materials in securing resilient clean energy technology supply 

chains; 

6.  The impact of climate change on EU energy security. 

The  ongoing  energy  transition  will  have  a  profound  effect  on  future  security  of  gas  and 
electricity  supply.  Phasing  out  imported  fossil  fuels  and  instead  relying  on  homegrown 
renewable energy sources will have a substantial positive impact on the EU’s energy security, 
as it makes us more resilient to e.g. the supply shocks experienced during the energy crisis of 
2022. At the same time, a more electrified and decarbonised energy system requires a different 
management of the energy system, with more flexibility. 

Phasing out natural gas will affect the relevance of the Gas Security of Supply Regulation, as 
the phase out will likely occur at different speeds across consumer categories. The demand of 
protected customers will change, as household demand for gases may see the largest absolute 
decrease of all sectors by 2040, as indicated by the Impact Assessment of the 2040 Climate 
Targets. Residential gas demand could decrease by 2040 with -70% to -82% between 2020 and 
2040.203  It  would  mean  that  the  protected  customer  category  may  decrease  significantly, 
requiring reconsideration of this provision. A phase out of natural gas may also in the future 
impact critical gas undertakings financially.  

The current design of the gas supply standard, including its storage element, may lose relevance 
in the future, due to decarbonisation, sectoral integration and electrification. Ongoing sectoral 
integration and electrification of the energy system means that critical energy uses (e.g. heating, 
industry) are expected to increasingly change vector from gas to e.g. electric heating. Current 
gas  storage  and  supply  standard  policy  is  designed  to  have  sufficient  gas  available  to  cover 
these critical heating needs in winter, while such policy does not exist for electricity. If heating 
demand becomes more electrified, this may change the relevance of the supply standard for gas, 
and it puts in question the relevance of a split approach per vector. In a sectorally integrated 
energy  system,  focus  may  need  to  be  redirected  to  a  cross-vector  approach  for  the  supply 
standard and/or storage policy that considers heating demand irrespective of the carrier. During 
the  consultation  activities,  for  example,  suggestions  to  align  EU  gas  storage  policy  with 
decarbonisation goals  included the possibility to have dedicated  requirements for  renewable 
gases. 

The development of biomethane will become increasingly relevant for energy security. Through 
the Hydrogen and Decarbonised Gas Package, the definition of ‘natural gas’ now also means 

203 

See: 

SWD(2024) 

63 

https://eur-lex.europa.eu/resource.html?uri=cellar:6c154426-c5a6-11ee-95d9-

01aa75ed71a1.0001.02/DOC_3&format=PDF  

76 

 
 
 
biomethane that can be directly injected in the system. This means that provisions of the Gas 
Security of Supply Regulation from 2025 onwards directly apply to biomethane. However, the 
production of biomethane has different particularities compared to natural gas. For example, 
the  production  of  biomethane  is  seasonal,  mostly  distributed  due  to  the  high  costs  of 
transporting  biomass  resources,  and  dependent  on  availability  of  local  resources.  With  an 
expected increase of biomethane in the energy system, it will give a more prominent role to the 
distribution grid for security of gas supply, where biomethane is often injected into the system. 
An increased use of biomethane may lead to a strengthened energy-food nexus and means that 
the  sourcing  of  biomethane  will  be  relevant  for  e.g.  risk  assessments.  Biomethane  used  for 
thermal generation will likely still contribute to security of electricity supply by 2050, as it can 
provide flexibility for variable renewable energy.  

Hydrogen will also become important for the future energy security framework, as it will be 
used in hard-to-abate applications in industry and transport to replace fossil fuels, and provide 
flexibility to the power sector. For example, hydrogen can contribute to security of supply by 
providing  flexibility to  the electricity grid, through  long-term  storage, including  through the 
supply of e-gases and e-fuels.204 However, the role of hydrogen will be different than the current 
role  of  natural  gas.  Furthermore,  it  will  be  crucial  that  the  deployment  of  electrolysers  to 
produce electrolytic hydrogen is well integrated with other decarbonisation processes and grid 
capacities.205 

Figure 34: Commission projection on hydrogen consumption 

2
H
M

t

 70

 60

 50

 40

 30

 20

 10

 -

2020

2025

2030

2035

2040

2045

2050

Source: Climate Target Plan 2040 Impact Assessment  

204 European Commission, Artelys, Trinomics, Enerdata, Study on energy storage – Contribution to the security 
https://op.europa.eu/en/publication-detail/-

of 
/publication/a6eba083-932e-11ea-aac4-01aa75ed71a1/language-en 

Europe,  March 

electricity 

supply 

2020: 

in 

205 In a study of June 2022, ENTSO-E stated that, in 2050, the growth of low-carbon hydrogen “would require a 
power  input  of  1,951–  2,173 TWh;  this  alone  represents  70  –  78%  of  current  total  and more  than double 
current renewable EU power generation”. The Commission-funded platform ETIP-SNET recommended that 
the impact of electrolysers’ deployment “on electric grid will be an order of magnitude higher than on gas 
grid;  therefore  it  is  paramount  to  include  electrolysers  and  other  components  of  hydrogen  production  in 
planning process of power system, rather than only tackling them as a connection request” 

77 

 
 
 
 
It also seems useful to consider lessons learnt from the experience with gas security of supply 
in relation to third-country suppliers. This can help to avoid dependencies on imports from a 
single dominant supplying third country in the future. 

Repurposing  natural  gas  infrastructure  will  be  crucial  to  a  cost-efficient  transition.  An 
integrated network planning approach is essential to ensure that the objective of repurposing 
natural  gas  transmission,  import  or  storage  infrastructure  to  hydrogen  is  balanced  with  the 
objective  of  continuing  to  ensure  security  of  natural  gas  supply206.  The  Hydrogen  and  Gas 
Market Decarbonisation Package contains provisions to address the decommissioning of gas 
infrastructure and if necessary, repurposing it for the transport of hydrogen. This should take 
place in a sequenced manner keeping security of supply considerations in mind. The Package 
also introduces integrated network planning of electricity, hydrogen and gas infrastructure at 
national level and ensures the appropriate regulatory oversight.  

While  the  Gas  Security  of  Supply  Regulation  has  provisions  that  are  directly  relevant  for 
diversification, it will require adaptation to align it with the REPowerEU objective to phase out 
of the dependency on Russian gas supplies. Provisions that facilitate diversification include the 
infrastructure standard, which is designed to ensure that a disruption to the single largest piece 
of infrastructure can be withstood, which enabled a complete shift of flow patterns when Russia 
cut its gas supplies to the EU in 2022. Moreover, Article 14 of the Regulation also gives the 
option to Competent Authorities or the Commission, under certain conditions, to request supply 
contracts concluded with third country suppliers to assess whether it negatively impacts security 
of  supply.  Although  the  Regulation  provides  for  Competent  Authorities  or  undertakings  to 
notify contractual information to the Commission in some cases, more transparency regarding 
the origin of gas imported would be needed to achieve REPowerEU objectives. As announced 
in  the  Roadmap  towards  ending  Russian  energy  imports  adopted  on  6  May  2025207,  in  the 
legislative  proposal  of  June  2025208  new  rules  for  increased  transparency,  monitoring  and 
traceability  of  Russian  gas  were  proposed.  Following  Russia’s  invasion  of  Ukraine,  the 
Commission  and  Member  States  in  the  CEE  region  have  also  worked  diligently  to  identify 
diversification routes in light of the end of transit through Ukraine, notably through a regional 
spin-off working group of the GCG. 

However,  none  of  the  listed  measures  are  designed  to  require  a  pre-defined  level  of 
diversification, nor explicitly encourage phasing out Russian gas. To ensure future relevance 
and to incorporate the lessons learned from the past overreliance on Russian gas, this objective 
may need to be better incorporated. As the 2021-2023 crisis showed, a lack of diversified supply 

206 See Commission report on energy storage (2020), which states: “In 2050, gas-fired plants continue to have an 
important role in the provision of flexibility. Their fuel supply is however totally different than the one of 2030: 
while in 2030 gas-fired plants were mainly using natural gas32, in 2050 gas-fired plants are mainly using 
biogas, and to a lower extent e-gases coming from the power-to-gas-to-power loop.” 

207 COM(2025) 440 final. 
208 COM(2025) 828 final 

78 

 
 
 
sources can be a high security of supply risk that can put in jeopardy the security interests of 
the EU or its Member States, regardless of the supplier or the energy carrier.  

Besides diversification, a sound policy should also look at the reliability of trading partners. 
Public governance quality indicators209 is one of the proxies that can be used to evaluate the risk 
level. Figure 37 shows the changing geography and the improved governance indicator of EU 
gas suppliers during the evaluation period. Since 2021, the average governance quality of EU 
gas suppliers has significantly increased from -0.01 to 0.47. This reflects mainly the drop of 
Russia’s  share  in  EU  gas  imports,  largely  compensating  the  parallel  decrease  of  Russia’s 
governance quality grade. This improvement could however be substantially weakened in case 
other major EU gas suppliers were to see their WGI ratings fall in the coming years. 

Figure 35 – Evolution of EU gas imports portfolio (bcm, left axis) and of the related weighted 
governance average (right axis) 

Source: Commission, based on ENTSOG Transparency Platform, Refinitiv and World Bank  

The importance of diversification of gas supplies is increasingly underlined by the current tense 
geopolitical situation. The state of the current geopolitical situation is challenging to quantify 
but  Figure  36  illustrates  the  change  in  relevance  of  geopolitical  risks  compared  to  previous 
years. This trend is confirmed by other indicators, such as the Geopolitical Annual Trade Risk 
Index  (GATRI)  from  the  Hague  Centre  for  Strategic  Studies,  which  has  measured  a  steady 
increase  of  risk  between  2020  and  2024  driven  by  both  economic,  diplomatic  and  military 

209  World  Bank’s  Worldwide  Governance  Indicators  (WGI)  measure  the  perceptions  of  quality  of  governance 
across countries and over time. Each country is allocated with a grade between -2,5 and 2,5 for each of these 
indicators. The higher the grade, the better for governance quality. The EU average grade was computed by 
multiplying the countries’ average grades by their relative share in EU gas imports. Datasets are available at: 
https://www.worldbank.org/en/publication/worldwide-governance-indicators  

79 

 
 
 
 
aspects210. This tumultuous context is also embodied by the dramatic increase of the number of 
trade  restrictions  added  annually,  which  tripled  between  2019  and  2023211.  These  global 
tensions may require enhanced monitoring and early warning tools. This is exacerbated by the 
higher reliance of the EU on a global LNG market (cf. section 3.1) which make geopolitical 
risks more relevant. Given that LNG is a global market, risks materialising in other parts of the 
world will become increasingly relevant for EU security of supply. In recent years, events like 
strikes hindering Australian LNG exports in September 2023 or the Red Sea crisis between Q3 
2023 and Q1 2024 have had a tangible impacts on EU energy markets. However, depending on 
the  demand  scenario  chosen,  EU  gas  consumption  may  decrease  significantly  in  the  future, 
potentially impacting demand for LNG and gas through pipeline to different extents.212  

Figure 36: Geopolitical risk index 

Source: European Central Bank213 

The fact that additional measures were needed to combat the energy crisis reflects that the Gas 
Security  of  Supply  Regulation  was  not  sufficiently  relevant  in  tackling  the  crisis  the  EU 
faced. The Gas Security of Supply Regulation was designed to tackle time-limited supply crises 
and was not designed to tackle a prolonged supply disruption from the EU’s main supplier. For 
example, temporary storage solutions were necessary to ensure that storages were filled to 90% 
by  1  November  of  each  year,  after  Gazprom’s  manipulation  of  the  storage  market  left  EU 
storages filled at only 77% on 1 November 2021. As ENTSOG’s Winter Outlook 2021-2022214 
showed, this low storage level would lead to a risk of demand curtailment in Ukraine-route risk 
group  and  Baltic  States/Finland  risk  group,  in  case  of  cold  winter  conditions  and  supply 
disruptions  from  Russia  (the  latter  transpired  the  year  after).  However,  these  storage 
requirements  adopted  under  the  Storage  Regulation  are  temporary  in  nature.  Although  the 
storage market does not face the same risks as it did in 2021, with Gazprom no longer having 
access  to  EU  storage  sites,  after  the  expiration  of  the  Storage  Regulation  there  are  fewer 

210 GATRI 2025: https://gatri.app.hcss.nl/ 
211  International  Monetary  Fund,  2023:  https://www.imf.org/en/Blogs/Articles/2023/08/28/the-high-cost-of-

global-economic-fragmentation 

212 See for example ACER’s 2025 LNG Market Monitoring Report: ACER 2025 LNG Monitoring Report 
213  Caldara  and  Iacoviello  (2022),  included  in  ECB  report  on  ‘geopolitical  risk  and  its  implications  for 
https://www.ecb.europa.eu/press/financial-stability-

macroprudential 
publications/macroprudential-bulletin/html/ecb.mpbu202504_01~6aa0c34852.en.html  

policy. 

See: 

214 SO0032-21_Winter Supply Outlook_2021-22_Final .pdf 

80 

 
 
 
 
safeguards to ensure storage filling in order for the EU to be sufficiently prepared going into 
each winter season. At the same time, with the orderly phase out of fossil fuels expected to 
progress in the coming decades, the relevance of natural gas storage targets as a percentage of 
storage capacities may decrease in the mid- to long-term. In parallel, storage demand may rise 
for electricity, hydrogen and CO2. 

At the same time, the Regulation focuses mainly on the supply side, and did not sufficiently 
leverage the demand side of energy security. Reducing demand has been an effective tool to 
mitigate the energy crisis, as showcased under the ‘effectiveness’ criteria. However, this is in 
the  current  Gas  Security  of  Supply  Regulation  not  sufficiently  covered,  since  the  Demand 
Reduction Regulation expired in March 2024. The experience with the Gas Demand Reduction 
Regulation shows that to remain relevant, there may be potential to continue to leverage demand 
reduction and demand response during crises.  

Strategic foresight tools were mobilised215 for this fitness check, with key outcomes being the 
identification  of  ‘accelerating  technological  change  and  hyperconnectivity’,  ‘aggravating 
resource  scarcity’  and  ‘climate  change  and  environmental  degradation’  as  key  megatrends 
relevant  for  gas and  electricity security of supply. This  identification is  generally  consistent 
with the Megatrends that were identified by respondents to the public consultation, when asked 
for which of the Megatrends the EU security of electricity and gas supply architecture is least 
prepared (see Figure 53 in Annex VI). Particular risks identified during the workshop include 
the increased likelihood of cyber-attacks on the energy system in case of further geopolitical 
competition,  which  due  to  increased  system  complexity  may  be  increasingly  relevant. 
Furthermore, increased competition for  CRMs and scarcity of basic resources such as water 
may  have  an  impact  on  electrification  efforts.  Lastly,  climate  change  may  aggravate  water 
scarcity (impacting nuclear, thermal or hydro generation), energy demand (e.g. heatwaves), or 
affect weather patterns impacting wind generation in  certain  regions or affect  coastal  power 
plants due to rising sea levels.  

Currently, the EU faces a high dependency on imports of CRMs, often from a limited number 
of suppliers, which poses significant geopolitical and supply chain risks. For instance, the EU 
relies on China for approximately 98% of its rare earth elements, essential for manufacturing 
high-efficiency  magnets  used  in  wind  turbine  generators.  As  demand  for  clean  energy 
technologies grows, the EU’s need for these materials is expected to multiply fivefold by 2030. 
In the battery sector, EU demand for lithium, crucial for electric vehicle and energy storage 
batteries, is projected to surge up by 12 times by 2030. Currently, the EU imports around 79% 
of its lithium from  Chile, rendering it vulnerable to  supply disruptions. Similarly, the EU is 
reliant on imports for other key battery materials such as nickel, cobalt, and graphite, with China 
controlling a significant portion of the global supply chain. In 2024, it accounted for 70-75% 

215 As per tool #20 of the Better Regulation Toolbox, an analysis using the Megatrends method developed by the 
Commission’s Joint Research Centre, assessed how long-term driving forces may affect future relevance of 
the EU energy security architecture. This was achieved by the means of an internal workshop and of a question 
included in the public consultation. See Annex VI for more information. 

81 

 
 
 
of lithium and cobalt processing, and more than 90% of graphite refined battery-grade supply 
active materials and rare earth refining supply216. Therefore, the EU adopted in 2024 both the 
Critical  Raw  Materials  Act217  and  the  Net  Zero  Industry  Act218  in  order  to  reduce  the  risks 
associated with CRMs and critical energy transition technologies.  

Furthermore, there is a growing importance of CRMs for the energy security framework due to 
their central role in the deployment of renewable energy technologies and the expected rapid 
electrification  of  the  EU’s  energy  system.  The  current  security  of  supply  framework  is  not 
equipped to address these future problems. For instance, the IEA219 estimates that clean energy 
technologies will account for over 40% of total copper  and rare earth elements demand, 60-
70% of total demand for cobalt and nickel, and almost 90% for lithium by 2040. Electrification, 
particularly in sectors like transport, heating, and industry, is expected to drive a significant 
share  of  this  demand,  with  the  number  of  electric  vehicles  in  the  EU  projected  to  reach  30 
million by 2030. This rising demand coincides with ongoing geopolitical shifts, which expose 
vulnerabilities of highly concentrated supply chains, particularly for e.g. graphite, where more 
than  90%  of  the  EU’s  imports  currently  come  from  a  single  third  country.  These  dynamics 
underscore  the  need  to  integrate  CRMs  more  explicitly  into  the  EU’s  energy  security 
framework,  ensuring  that  the  availability  of  materials  keeps  pace  with  the  accelerated 
deployment of clean energy infrastructure. 

The number of extreme weather events had already dramatically increased, as shown in section 
3.1, and the energy sector is projected to be most impacted by climate-induced infrastructure 
damages in the years to come. Extreme weather hazards which may disrupt energy assets are 
becoming more frequent and more diverse. Climate change may impact not only the supply-
side of the energy system, but also demand patterns, in particular for the building sector. Future 
heating needs are expected to decrease, while cooling requirements are projected to rise, further 
stressing  the  energy  system  in  summer  periods220.  Improvements  will  be  needed  on  risk 
assessments to  support better  risk preparedness,  while some provisions may also  need  to  be 
updated to match the future reality of the energy system, e.g. the supply standard. 

216 IEA (2025) Global Critical Minerals Outlook 2025: https://iea.blob.core.windows.net/assets/ef5e9b70-3374-
4caa-ba9d-19c72253bfc4/GlobalCriticalMineralsOutlook2025.pd   
217 Regulation (EU) 2024/1252 
218 Regulation (EU) 2024/1735 
219 See: The Role of Critical Minerals in Clean Energy Transitions – Analysis - IEA 
220 Cf. e.g. Commission’s impact assessment report on Europe’s 2040 climate target, SWD(2024) 63 final. 

82 

 
 
 
Figure 37: Climate risk exposure of electricity generation, network and supply chains 

Source: IRENA 

Climate change may also lead to a deteriorating business case for certain companies operating 
in  the  energy  sector.  This  could  result  in  financial  risks  for  undertakings  that  are  critical  to 
security of energy supply.  These types of risks are currently not  addressed by the  evaluated 
regulations. 

In general, the results of the energy Eurobarometer221 of September 2024 confirm the continuous 
relevance  of  energy  security  of  supply  policies.  The  energy  Eurobarometer  showed  that 
reducing  energy  imports  and  increasing  energy  independence  was  considered  by  26%  of 
respondents the main future priority of energy policy (third highest). The second highest was 
‘decreasing energy consumption’ (27%), which supports the relevance of measures that were 
instrumental  to  address  the  energy  crisis,  such  as  the  Gas  Demand  Reduction  Regulation. 
Moreover, for 22% of respondents EU energy policy means preventing electricity black-outs 
and energy shortages, which jumped up from just 7% in 2019.222  

221 European’s attitudes towards energy policies - September 2024 - - Eurobarometer survey 
222 Other policy areas directly relevant to energy security also saw a big jump from 2019 to 2024, such as improving 

energy infrastructure (from 8% to 27%), decreasing energy consumption (from 2% to 30%). 

83 

 
 
 
 
Figure  38:  responses  to  the  question:  'in  your  opinion,  which  of  the  following  energy-
realated issues should the European Union tackle as a priority over the next five years' 

Source: Special Eurobarometer 555, September 2024 

84 

 
 
 
 
 
 
5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1.  Conclusions 

Since the beginning of the 21st century, the EU has progressively developed a comprehensive 
legislative  framework  on  security  of  gas  and  electricity  supplies.  This  fitness  check  has 
evaluated the latest legislation from 2017 until 2024. The evaluation period was marked by the 
Covid-19 pandemic and Russia’s full-scale invasion of Ukraine, resulting in one of the most 
severe energy crises in the history of the EU.  

The evaluated framework, including the emergency regulations established in the context of the 
energy  crisis,  has  ensured  a  stable,  secure  and  uninterrupted  energy  supply,  and  protected 
vulnerable and critical consumers, and has therefore been overall successful. The analysis has 
also shown that the evaluated regulations have delivered benefits compared to what could have 
been achieved without EU-level action, by ensuring a degree of coordination between Member 
States. This report also demonstrated the framework’s relevance, with persistent risks to EU’s 
security  of  electricity  and  gas  supply.  However,  this  real-life  stress-testing  and  the  fact  that 
additional emergency regulations were needed showed that there are areas for improvement and 
that  new  risks  should  be  covered  in  more  depth  as  they  are  increasingly  wide  reaching  and 
frequent.  

More specifically, the assessment has looked at the effectiveness, efficiency, EU added value, 
coherence, and relevance of the framework, in line with the Better Regulation guidelines. 

1.  With  regard  to  effectiveness,  this  fitness  check  found  that  the  Gas  Security  of  Supply 
Regulation and the Electricity Risk-Preparedness Regulation were effective in achieving their 
objectives to a certain extent, increasing the EU's overall preparedness and making the EU more 
resilient to gas supply disruptions and electricity blackouts.  

•  The  framework  achieved  its  specific  objective  of  enhancing  transparency  and 
coordination,  even  in  times  of  crisis.  This  was  achieved  through  the  Coordination 
Groups  and  by  sharing  plans  and  risk  assessments  among  Member  States,  based  on 
security of supply simulations and common methodologies set up by the Regulations. 
The specific objectives of the Gas Security of Supply Regulation to have adequate and 
flexible  infrastructure  and  to  ensure  supplies  to  protected  customers  in  case  of 
disruptions  was  met,  through  the  infrastructure  standard  and  supply  standard.  No 
curtailment of gas protected customers took place in the evaluation period.  

•  However,  the  fitness  check  also  highlighted  clear  weaknesses  of  the  framework 
regarding upfront preparedness for the 2021-2023 energy crisis. The fact that the EU 
required additional emergency regulations to combat the energy crisis, points to the need 
for more robust risk assessments and scenario planning, also considering emerging risks 
such as cybersecurity, hybrid threats, access to critical energy transition minerals and 
climate  change.  It  also  shows  that  the  specific  objective  of  ensuring  preparedness 
through a risk-based approach was not sufficiently met. Moreover, solidarity between 

85 

 
 
Member States was not operational during the energy crisis (only 9 out of 40 agreements 
are signed), until the default solidarity rules adopted in 2023 were introduced.  

2. On efficiency, the fitness check found that the framework's implementation costs consist of 
administrative and infrastructure costs. The case study results indicate that absolute costs are 
low (in the order of a few hundreds of millions over the assessment period) compared to the 
extraordinary costs of potential supply crises (which is in the order of billions).  

•  However, the data collection and public consultation shows that the burden on national 
administration  and  Competent  Authorities  can  be  high  in  terms  of  manpower.  The 
compliance costs for energy undertakings are on the other hand low.  

•  Furthermore,  the  analysis  shows  that  there  is  room  for  improvement  in  terms  of 
simplifying and streamlining the regulatory framework, especially regarding the various 
reporting  obligations  (e.g.  risk  assessments  and  plans)  on  Member  States  and 
administrative procedures. This needs to be balanced with the important role that these 
reporting requirements have in preserving a high level of security of supply. 

•  Further monitoring tools might be needed in the future, to fill the current data gaps to 
monitor  security  of  supply,  and  to  enable  an  accurate  assessment  of  the  costs  and 
benefits of the framework in the future. Key performance indicators could be developed, 
e.g. to assess the administrative burden caused by reporting obligations.  

3.  In  terms  of  coherence,  the  Gas  Security  of  Supply  Regulation  and  Electricity  Risk-
Preparedness  Regulation  were  mostly  consistent  with  each  other  and  other  EU  policies  and 
legislation  during  the  evaluation  period.  The  evaluated  Regulations  build  on  the  well-
functioning  internal  market  and  a  highly  interconnected  energy  system,  supported  by  EU 
Regulations and funding.  

•  There is nevertheless a need for a more coordinated approach to security of supply in 
the electricity and gas sectors, especially regarding spillover effects from one sector to 
the other. While the Regulations were generally coherent, more coordination regarding 
future  cross-sectoral  crises  is  fundamental.  In  particular,  the  concept  of  ‘protected 
customers’  is  not  aligned  between  gas  and  electricity,  leading  potentially  to  lower 
overall protection of critical or vulnerable consumers.  

•  The EU’s security of electricity and gas supply framework draws from and complements 
the  recently  adopted  horizontal  EU  legislation  on  cybersecurity  and  critical 
infrastructure protection. However, the increased electrification of end-use sectors and 
newly  emerging  geopolitical  risks  might  warrant  additional  sectoral  measures  to  be 
implemented to ensure the coherence in the future. At the same time, synergies between 
the security of supply framework and the framework for energy infrastructure  can be 
further strengthened.  

•  The Regulations are in line with wider EU policy objectives, such as ensuring European 
competitiveness  and  the  decarbonisation  objectives.  However,  due  to  accelerated 
decarbonisation, sectoral integration and electrification, there is room for improvement 

86 

 
 
to  enhance  the  synergies  within  the  framework,  and  specific  provisions  may  require 
further review to avoid the risk of carbon lock-in. 

4. The evaluated Regulations have generated significant EU added value.  

•  The  Regulations  provided  EU  added  value  by  starting  regional  and  EU-wide 
cooperation,  enhancing  security  of  electricity  and  gas  supply,  and  reducing  the  risks 
associated with supply disruptions. The framework's ability to facilitate the sharing of 
best practices and expertise among Member States was highlighted as a key benefit.  
•  However, there is room for improvement to enhance the framework's ability to address 
cross-border risks in much more depth and operationalise the energy solidarity principle. 

5. The Gas Security of Supply Regulation and the Electricity Risk-Preparedness Regulation has 
been and will remain relevant for the EU's current security of supply challenges. However, 
there are new realities that the current regulation does not address yet, and that will need to be 
considered in any upcoming revision. 

•  The Gas Security of Supply Regulation has been and will remain relevant for current 
EU  policy  objectives,  where  energy  security  is  a  prerequisite  for  EU  economic 
competitiveness in the current geopolitical context.  

•  The ongoing energy transition to a decarbonised and more electrified energy system will 
improve  security  of  supply  by  reducing  the  need  to  import  fossil  fuels  from  third 
countries.  At  the  same  time,  the  energy  system  of  the  future  requires  a  different 
management of the energy system, with a growing need for flexibility through storage, 
demand response and cross-border infrastructure.  

•  However, the framework requires adaptation to ensure future relevance in the context 
of  changing  energy  markets  and  a  changing  external  context.  For  example,  the  Gas 
Security of Supply Regulation was designed for short-term supply disruptions and not 
a  prolonged  disruption  of  the  EU’s  main  supplier.  At  the  same  time,  stakeholder 
feedback and a megatrend workshop indicate that there are emerging challenges that 
require  further  review,  adapting  to  the  transition  to  a  low-carbon  economy  which 
fundamentally  changes  energy  markets  and  the  sectoral  integration  of  the  gas  and 
electricity systems. Moreover, geopolitical challenges increase the relevance of having 
a  robust  long-term  diversification  policy  at  EU  level,  as  demonstrated  by  the  recent 
adoption  of  an  EU  roadmap  to  end  Russian  energy  imports.  A  robust  long-term 
diversification policy may require enhanced transparency and traceability  to ensure a 
diversified supply mix.  

•  Cybersecurity  risks,  physical  and  hybrid  threats  to  infrastructure  and  environmental 
threats due to climate change will be increasingly important for a future energy security 
framework. While horizontal regulation on cybersecurity and critical entities resilience 
have been put in place, the analysis shows that additional sectoral measures or a revision 
of existing provisions would be needed to support the implementation of the horizontal 
regulation. 

87 

 
 
•  Additionally, growing demand for CRMs, driven by the energy transition and increasing 
electrification, presents new vulnerabilities. The horizontal legislation is insufficient to 
address the specificities for the energy system, and additional measures are needed to 
ensure resilient and secure energy systems.  

5.2.  Lessons learned 

Without prejudice to future Commission action, the lessons learned from this fitness check point 
to the following areas for improvement  regarding the EU framework on security of gas and 
electricity supplies, which could be further analysed: 

•  Simplification: while the performance framework has been relatively cost-efficient in 
the  achievement  of  its  objectives,  there  is  room  for  simplification  and  for  reducing 
administrative burden, making the whole framework more operational and actionable. 
Simplification  can  be  achieved  through  streamlining  the  reporting  obligations  for 
national authorities, reducing the amount of regional risk groups and simplifying the 
procedure to request an exemption for the bidirectionality obligation. 

•  Adaptation:  the EU energy system  as a  whole has been stable during the  evaluation 
period, but the electricity sector is already experiencing a massive transformation. This 
notably  involves  the  decarbonisation,  digitalisation,  electrification  and  sectoral 
integration of our energy system.  It  can be anticipated that the EU energy system  in 
2030 and then 2040 will be radically different from the one of 2017 or even of today, 
with increased renewable energy penetration and a more marginal role for natural gas. 
The particularities of “energy security” and “security of supply” will evolve along with 
this transformation, requiring adaptation. Among others, flexibility will become more 
critical for security of energy supply in the future, by having sufficient energy storage, 
demand  response  and  interconnection  available.  It  also  calls  for  a  deeper  and 
consolidated cross-border assessment of existing and emerging risks, given the regional 
dimension of such risks and the interconnectedness of the electricity system. Moreover, 
emerging risks needs to be better incorporated in risk assessments at EU and national 
level, e.g. critical infrastructure protection, cybersecurity, extreme weather events. 
•  Integration: the gas and electricity sectors are very closely interlinked, and they may 
become even more integrated in the future. While some important differences persist 
between the two markets, there is room to significantly align the two Regulations. For 
example,  risk  scenarios  in  gas  and  electricity  are  not  always  consistent  (e.g.  a  gas 
shortage was initially not sufficiently considered as a risk in electricity plans in 2022) 
and the timing of the planning process is not aligned. The areas in which the synergies 
between  the  two  Regulations  could  be  enhanced  notably  include  crisis  management, 
risk assessments and plans. 

•  Transparency  and  supervision:  this  fitness  check  report  underlined  both  the  added 
value of transparency provisions which spur coordination, and the lack of data on certain 
areas of security of electricity and gas supply (e.g., transparency and traceability of gas 
imports, timely availability of key data). In particular, the REPowerEU Roadmap and 

88 

 
 
legislative proposal to end Russian energy imports adopted in May and June 2025 points 
at new rules for increased transparency, monitoring and traceability of Russian gas will 
inspire the future EU energy security architecture. 

In  this  perspective,  the  new  Commissioner  for  Energy  and  Housing  has  been  tasked  in  his 
mission  letter  to  "review  the  security  of  supply  framework”223.  This  review  provides  an 
opportunity for the EU to build on the findings and lessons learnt from the fitness check exercise 
and to ensure that the framework remains effective in ensuring a stable and secure energy supply 
for Europeans also in the future.  

223 

https://commission.europa.eu/document/download/1c203799-0137-482e-bd18-

4f6813535986_en?filename=Mission%20letter%20-%20JORGENSEN.pdf 

89 

 
 
 
 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

Lead DG 

The European Commission’s Directorate-General (DG) for Energy is the lead DG for this fitness 
check (PLAN/2024/1444). 

Organisation and timing 

The Commission published a call for evidence on the fitness check on 3 September 2024, together 
with a public consultation. They were open for feedback until 26 November 2024. 

An Inter-Service Steering Group (ISG) was set up in July 2024, involving representatives from the 
following Commission’s Directorate General: Secretariat General (SG), European External Action 
Service  (EEAS),  DG  Climate  Action  (CLIMA),  DG  Communications  Networks,  Content  and 
Technology (CNECT), DG Competition (COMP), DG Defence Industry and Space (DEFIS), DG 
European  Civil  Protection  and  Humanitarian  Aid  Operations  (ECHO),  DG  Environment  (DG 
ENV), DG Internal Market, Industry, Entrepreneurship and SMEs (GROW), DG Migration and 
Home  Affairs  (HOME)  DG  Mobility  and  Transport  (MOVE),  DG  Neighbourhood  and 
Enlargement Negotiations (NEAR), Joint Research Centre (JRC), Eurostat (ESTAT). The meetings 
were  held  on  10  July  2024,  20  November  2024  and  4  February  2025.  In  addition,  a  cross-DG 
strategic foresight workshop (to which all the ISG members were invited) was organized on 17 
October 2024. 

Consultation of the Regulatory Scrutiny Board 

The RSB was consulted in an upstream meeting on 6 January 2025. The draft Fitness Check report 
and all supporting documents were submitted to the RSB on 19 February 2025 and a hearing was 
held on 19 April 2024. In the hearing, the RSB made the following recommendations: 

RSB recommendations 
The scope of the fitness check  should be clarified 
upfront  and  its  purpose  of  feeding  into  the  wider 
impact assessment for the revision of the EU energy 
security  of  supply  legislation  should  be  clearly 
stated. While the fitness check focuses on gas and 
electricity  security  of  supply,  the  general  EU 
framework  on  energy  security  of  supply  is  much 
wider. The report thus needs to clearly justify which 
elements  are  in  the  scope  of  the  exercise  (in 
particular as regards the emergency measures) and 
which  have  been  excluded  from  the  analysis  and 
why. Once the scope is clarified, the analysis should 
stay within those limits and other elements of the 
energy  security  framework  should be  consistently 
covered in the analysis of coherence. 
The analysis of effectiveness should be performed 
in line with the defined scope of the fitness check. 
It should be more unambiguous in its conclusions 

Modifications to the fitness check report 
In the introduction, the scope of the fitness check has 
been  clarified.  It  notably  clarifies  that  the  report 
primarily  focuses  on  the  Gas  Security  of  Supply 
Regulation  and  Electricity  Risk  Preparedness 
Regulation, but that the emergency measures whose 
objective was to remedy the security of supply issues 
in  2022-2023  are  also  within  scope.  Horizontal 
elements  that  are  relevant  for  wider  energy  security 
have been assessed in terms of coherence and future 
relevance.  However,  the  Gas  Security  of  Supply 
Regulation and Electricity Risk-Preparedness contain 
(limited) measures on e.g. cybersecurity and critical 
energy  infrastructure  protection,  which  have  been 
assessed  against  all  five  criteria.  A  visual  has  been 
added to further aid the understanding of the scope. 
The analysis of effectiveness follows the clarification 
of  the  scope,  reflecting  effectiveness  of  the  Gas 
Security  of  Supply  Regulation,  Electricity  Risk 

EN 

90 
EN 

 
 
agreements.  The 

on the achievement of specific objectives and on the 
various elements of the two regulations, including 
on the emergency measures. It should also cover all 
the  key  elements  of  the  toolkit,  including  for 
example  the  N-1  rule,  the  simulations,  or  the 
conclusions  on 
solidarity 
effectiveness  should  not  only  be  limited  to  the 
process / procedural part of the framework but also 
relate 
framework  had  any 
the 
attributable impact on the energy markets / reality. 
The  conclusions  about  efficiency  should  be  more 
nuanced  in  particular  reflecting  the  limitations  of 
the  information  on  the  costs  and  benefits.  As  the 
provided  evidence  on  the  costs  and  benefits  is 
limited,  the  claim  made  in  the  report  about 
‘reasonable costs’ is not well substantiated. 

to  whether 

The  report  could  usefully  provide  additional 
information  on  the  functioning  of  the  energy 
markets  in  relation  to  the  security  of  supply 
framework to provide further insights into the real 
benefits  and  total  costs  for  different  stakeholders, 
including  the  costs  of  infrastructure.  Since  the 
report acknowledges difficulties with evidence/data 
availability  to  assess  the  performance  of  the 
framework,  the  conclusions  should  point  to  the 
need to develop appropriate monitoring system for 
the future, including key performance indicators. 

The analysis of relevance should be revisited in the 
report and provide for both backward- and forward-
looking  parts.  The  backward-looking  analysis 
should  focus  on  the  needs  the  interventions  were 
supposed to address, i.e. ensuring a constant match 
between  energy  demand  and  energy  supply  in  a 
stable  and  secure  manner,  while  protecting 
vulnerable and critical consumers. It should reflect 
whether the achievement of the specific objectives 
of the evaluated regulations could contribute to the 
matching  of  supply  and  demand  on  the  relevant 
energy  markets.  The  forward-looking  part  should 
further  analyse  the  evolution  of  the  needs  and 
changing  context,  considering  for  instance  the 

the 

and 

lack 

Preparedness  Regulation 
emergency 
measures.  The  conclusions  on  effectiveness  have 
been  qualified,  taking  more  explicitly  stock  of  the 
achievement  (or 
the  specific 
objectives,  not  just  the  general  objectives.  More 
specific  conclusion  have  been  provided,  notably 
regarding  the  emergency  measures,  as  well  as  the 
solidarity  agreement  and  infrastructure  standard  (N-
1).  

thereof)  of 

The  conclusions  on  efficiency  have  been  nuanced, 
reflecting the uncertainty of the findings on costs and 
benefits given the lack of key performance indicators 
(c.f. next point). The comparison has been made more 
explicitly with the costs of potential supply crises, by 
assessing  the  potential  costs  of  such  incidents. 
Additional information on the costs of the Regulation 
has  been  added,  both  in  Annex  IV  and  in  the 
efficiency section, on e.g. the costs of infrastructure 
development  (c.f.  next  point),  the  cost  of  the 
organization  of  mandatory  exercises  and  reporting 
requirements.  
The  report  has  been  strengthened  by  adding  a 
paragraph  in  the  efficiency  section  on  the  price  and 
market  developments  after  a  supply  crisis.  In 
particular,  the  market  effects  of  the  various  cuts  in 
Russian  gas  supplies  in  2022  has  been  included. 
Additional information on the costs of infrastructure 
development  that  is  directly  attributable  to  the  Gas 
Security  of  Supply  Regulation,  notably 
the 
bidirectionality  requirement,  has  been  added  in  the 
efficiency  section.  The  need  for  further  key 
the 
performance  indicators  has  been  added  in 
conclusions, 
the  future 
in  particular  to  assess 
administrative costs of the Regulations.  
The  backward-looking  part  has  been  redrafted,  to 
analyse whether the needs that the Regulations set out 
to  address  have  in  reality  been  tackled, focusing  on 
among  others  the  adequacy  of  the  relevant  risks  to 
security of supply that are to be addressed in the risk 
assessments.  The  forward-looking  part  has  been 
reinforced  with  further  elements  substantiating  the 
state of the geopolitical context, e.g. through reports 
from reports of the European Central Bank, the World 
Bank and the International Monetary Fund. 

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two  distinct, 

ongoing  transformation  of  EU  energy  system  and 
the geopolitical situation. 
The  conclusions  from  the  analysis  on  each  of  the 
specific objectives and different evaluation criteria 
should  be  systematically  brought  forward  to  the 
concluding section. As the fitness check covers the 
security  of  supply 
though 
in 
interrelated  markets  for  gas  and  electricity,  the 
conclusions  and  lessons  learned  should  be  more 
nuanced. Both the conclusions and lessons learned 
should be more specific to be useful for the future 
revision  of  the  EU  energy  security  of  supply 
framework,  for  instance  on  the  alignment  of  how 
vulnerable  consumers  should  be  treated  or  the 
issues  related  to  the  transformation  of  the  EU 
energy landscape 

the  evaluated  Regulations 

The  specific  objectives  have  been  more  explicitly 
covered in the conclusions, in particular as regards the 
effectiveness  of 
in 
achieving  their  specific  objectives.  The  lessons 
learned  for  a  future  revision  have  been  further 
highlighted, addressing the importance of reacting to 
the  geopolitical  situation  through  e.g.  a  sound 
diversification  policy,  adapting  to  the  increasing 
importance 
and 
‘dunkelflaute’ 
improving  the  cross-border  assessments  of  key 
emerging 
(e.g. 
infrastructure  protection, 
cybersecurity,  critical 
extreme weather events). It highlights where the two 
Regulations  can  be  further  aligned  (e.g.  risk 
assessments,  plans)  and  where  it  can  be  further 
for 
simplified 
bidirectional capacity). 

for  exemptions 

cross-sectoral 

situations 

and  or 

request 

risks 

(e.g. 

of 

Evidence, sources and quality 

The Fitness Check was supported by an evidence base developed in line with the Better Regulation 
Guidelines,  through  a  methodology  encompassing  a  broad  range  of  different  qualitative  and 
quantitative data. DG ENER benefitted from the support of JRC by the means of an administrative 
arrangement, notably for the design and the analysis of the public consultation, but also for the 
identification of key indicators. 

Use of external expertise 

This fitness check report was not supported by an external study. 

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ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

Methodology, sources of information and data analysis  

This  fitness  check  has  been  carried  out  based  on  a  number  of  wide-ranging  activities  and  data 
sources. The primary activities that this fitness check is based on include: 

• 

• 

• 

• 

• 

• 

In-house expertise derived from  e.g. the experience gained  from  implementing 
the Regulations. 

A 12-week call for evidence and public consultation, as well as other consultation 
activities.  

Two table-top exercises (“dry runs”) to stress-test the EU framework against crisis 
situations. 

Extensive  desk  research,  with  the  support  of the  Commission’s  Joint Research 
Centre. 

Exchanges with Member States and other key actors. 

A strategic foresight workshop, based on the Megatrends tool developed by the 
Joint Research Centre. 

In-house expertise based on implementation of the Regulations 

DG ENER has gained experience from implementing the Gas Security of Supply Regulation in its 
current form since 2017 and the Risk-Preparedness Regulation in its current form since 2019.  

This  experience  includes  two  cycles  of  common  risk  assessments,  national  risk  assessments, 
preventive action plans and emergency plans developed by Member States and three Union-wide 
security of supply simulations done by ENTSOG for gas. The risk assessments and plans contained 
a large amount of information and data on the specific security of supply situations in the Member 
States,  such  as  the  main  national  and  transboundary  risk  factors  (political,  technological, 
commercial/financial/market,  social,  or  natural  risks),  detailed  descriptions  of  the  national  and 
regional gas systems, compliance with the infrastructure and supply standards, measures imposed 
at national level to prevent and mitigate crises (both market-based and non-market based), tests of 
the emergency plans that were carried out, as well as roles and responsibilities during different 
crisis levels and information on regional crisis cooperation and solidarity. The Commission has 
assessed these deliverables and provided opinions on the preventive action plans and emergency 
plans, which are published online224. These were indispensable sources of information for writing 
this fitness check report. However, the quality of some of the risk assessments and plans was not 
in  all  cases  sufficient  to  allow  for  meaningful  comparisons  or  to  get  an  adequate  view  of  the 
preparedness  to  such  risks.  In  addition,  some  late  submissions  also  made  a  comparison  more 
challenging, as the plans were in that case not done in the same moment in time. The Commission’s 

224 

 See: Commission's opinions on the preventive action plans and emergency plans 

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Joint Research Centre also had to step in to provide modelling support to several of the Common 
Risk Assessments.  

Experience was also gained from one full cycle of regional electricity crisis scenarios, national 
electricity crisis scenarios and Risk Preparedness Plans (including Commission’s opinions). The 
second cycle is still ongoing: the first step, with the identification of regional electricity scenarios 
was performed by ENTSO-E in September 2024. Like for gas, these documents were a rich source 
of very useful information on the security of electricity supply situation of the EU as a whole and 
of Member States specifically. The publicly available Commission’s opinions225, stemming from 
the internal  assessment  performed  by  DG  ENER  with  the  support  of  JRC,  were also  used as a 
source of information on the quality of those reports and plans.   

A total of 41 of ECG meetings (since July 2019) and 27 GCG meetings (since October 2017) were 
held in full format and several meetings in the restricted Member State only format. Here, issues 
as well as best practice measures for implementing the Electricity Risk-Preparedness Regulation 
and Gas Security of Supply Regulation have been discussed respectively. In addition, two joint 
Electricity and Gas Coordination Group meetings have been organised in 2022, in case of cross-
cutting  issues  such  as  the  critical  gas  volumes  for  electricity  which  were  computed  as  part  of 
ENTSO-E’s  Winter  Outlook.  These  meetings  are  organised  and  chaired  by  the  Commission’s 
Directorate-General for Energy. Members of the GCG include the Competent Authorities of all 27 
Member  States  (usually  ministries  for  energy,  or  National  Regulatory  Authorities),  ENTSOG, 
ACER,  the  Energy  Community  Secretariat  and  the  representatives  of  industry  and  consumer 
associations (BEUC, Eurelectric, Eurogas, Euroheat & Power, Energy Traders Europe, GIE, IOGP 
and IFIEC). Apart from meetings organised, there is regular correspondence through the functional 
mailbox and the mailing list in case of security of supply incidents, the activation or deactivation 
of crisis levels, or in case of the notification of legally required deliverables (e.g. risk assessments, 
plans).  

Two Commission reports were issued on the implementation of the evaluated Regulations. This 
includes  Commission  report  COM(2023)  572  and  the  accompanying  Staff  Working  Document 
SWD(2023) 323, which reviewed the application of the Gas Security of Supply Regulation (EU) 
2017/1938. This report was based on a dedicated questionnaire circulated to members of the Gas 
Coordination Group via EUSurvey, implementation of the Regulation (among others during the 
energy crisis) and the assessment of Member States’ risk assessments, preventive action plans and 
emergency plans. In addition, the report reviewing the Electricity Risk-Preparedness Regulation is 
legally due by September 2025 (which was therefore elaborated in parallel to this fitness check 
report) was essential to feed the gained experience of implementing this Regulation into this fitness 
check226.  Both  the  reports  on  the  Gas  Security  of  Supply  Regulation  and  Electricity  Risk-
Preparedness Regulation were key inputs for this fitness check report.  

The experience gained from addressing the energy crisis informed this report, as the energy crisis 
served  as  a  real-life  test  of  the  adequacy  of  the  legislative  framework.  This  includes  the  daily 

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

sector-national-competent-authorities-and-commissions-opinions_en 

226  COM(2025) 539 final. 

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management,  coordination  and  communication  during  crisis  situations,  such  as  the  unilateral 
suspensions of supplies by Gazprom during 2022, as well as the Nord Stream and Balticconnector 
sabotage.  In  addition,  this  includes  the  drafting  of  the  annual  reports  on  the  Gas  Storage 
Regulation227  and  the  adoption  of  the  annual  implementing  acts  to  set  the  intermediary  filling 
targets228, the reports on the Gas Demand Reduction Regulation229 and the report on the Solidarity 
Regulation230. The reports on the Gas Storage Regulation, the Gas Demand Reduction Regulation 
and the Solidarity Regulation were key inputs and data sources for this fitness check report. The 
development of an Interactive Gas Monitoring Dashboard to Boost EU Security of Gas Supply231 
has helped following the Security of Gas Supply situation and provided also input to the fitness 
check report. 

Consultation activities 

As is further detailed in Annex V containing the synopsis report, a 12-week Call for Evidence and 
Public Consultation were carried out to gather views of citizens and stakeholders. A total of 86 
respondents provided feedback to the Call for Evidence and 114 respondents replied to the public 
consultation.  

The call for evidence and public consultation were part of the consultation strategy, which was 
approved  by  the  ISG  on  10  July  2024.  All  goals  and  consultation  activities  set  out  in  the 
consultation strategy were carried out and/or used for this fitness check (call for evidence, public 
consultation, Commission expert group meetings, regulatory roundtable, Eurobarometer).  

The public consultation was designed to consist of five sections, of which the last three respondents 
had to actively chose to answer, as they contained questions targeted to a more expert audience. 

A generic energy security section with mostly open question for a wide audience (including non-
expert audience) to give their views on their perception of the EU’s energy security framework. 

Optional: a specific section on the wider energy security framework, that contained more detailed 
questions  on  matters  related  to  energy  security  at  large,  or  issues  that  matter  to  both  gas  and 
electricity.  

Optional: a specific section on the functioning  of the gas security of supply framework, mostly 
targeting the provisions on the Gas Security of Supply Regulation, and to a lesser extent also the 
provisions  of  the  Gas  Storage  Regulation  and  the  emergency  Regulations  adopted  during  the 
energy crisis. 

227 

228 

229 

230 

231 

EN 

 COM(2023) 182, COM(2024) 89, COM(2025) 98 

 Regulation (EU) 2022/2301, Regulation (EU) 2023/2633 and REGULATION (EU) 2024/2995 

 COM(2023) 173, SWD(2023) 63 and COM(2024) 88 

 COM(2023) 547 

 See: Interactive gas monitoring dashboard to boost EU energy security - European Commission 

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Optional:  a  specific  section  on  the  functioning  of  the  electricity  security  of  supply  framework, 
mostly covering the provisions of the Electricity Risk-Preparedness Regulation. 

The specific sections on gas and electricity security of supply each contained questions aimed to 
assess  the  respondents’  perception  of  the  five  criteria  used  to  evaluate  the  Regulations 
(effectiveness, efficiency, coherence, EU added value and relevance). A mix of closed questions 
(to  evaluate  a  set  of  pre-defined  existing  provisions)  and  open  questions  (to  try  to  eliminate 
potential biases or information gaps) were used. A particular effort was made to raise awareness of 
this consultation among stakeholders and in the general public, beyond the sole publication on the 
Europa  website.  The  Commission  advertised  it  by  the  means  of  several  publications  on  social 
networks232 and of multiple presentations to various audiences. 

In  addition,  several  forward-looking  questions  were  included  in  order  to  gauge  respondents’ 
perception of which areas of improvement there could be for the Regulations within the scope of 
this fitness check. These forward-looking questions also helped to evaluate the future relevance of 
the Regulations.  

The public consultation contributions were analysed by the Commission’s Joint Research Centre, 
using a mixed-methods approach. Statistical tools were applied to closed questions, with results 
presented both at the overall level and by stakeholder category. Open questions were categorised 
by stakeholder group and evaluated qualitatively, allowing for a more in-depth understanding of 
the responses and detailed insights into respondents' views. 

The call for evidence and public consultation were useful exercises to inform the Commission of 
views from stakeholders and citizens alike, but the sample is by no means representative of the EU 
population at large. While a significant number of stakeholders that are directly affected by the 
Regulation  responded,  the  views  of  citizens  on  EU  energy  security  are  still  comparatively 
undetected.  In  addition,  the  public  consultation  in  particular  was  a  rather  long  and  complex 
questionnaire,  which  may  have  discouraged  participants  from  filling  in  the  questionnaire, 
especially the less directly concerned stakeholders and citizens. To combat respondents’ fatigue, 
at the beginning of the questionnaire the option was given to only answer the first section, which 
drastically shortened the questionnaire.   

More information on the details of the call for evidence and the public consultation can be found 
in Annex V. 

Table-top exercises (“dry runs”) 

Two table-top exercises (“dry runs”) to stress-test the EU framework against crisis situations were 
organised in December 2022 and November 2024 by the Commission. These simulation exercises 
made it possible to test: (i) the emergency procedures and system resilience of the EU’s gas system; 
and (ii) the interlinkages between the EU’s gas system and its electricity system. The vast majority 
of Member States participated in both exercises, as well as the European Network of Transmission 
System Operators for Gas (ENTSOG) and relevant national transmission system operators (TSOs). 

232 

 E.g.  on  Twitter  on  17  October  (https://x.com/Energy4Europe/status/1846809954205708611)  and  9  November 
(https://x.com/Energy4Europe/status/1855251496578757106). 

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For  the  2024  exercise,  Ukraine,  Moldova,  the  Energy  Community  Secretariat,  the  European 
Network  of  Transmission  System  Operators  for  Electricity  (ENTSO-E),  and  certain  national 
electricity TSOs also participated. 

These  dry  runs  were  designed  as  a  discussion-based  exercise  in  which  participants  met  in  a 
“classroom”  setting  to  address  the  actions  they  would  take  in  response  to  a  series  of  events. 
Participants received information about a scenario affecting the gas supply in Central and Eastern 
Europe where a series of events trigger emergency declaration. A facilitator helped guiding the 
discussion  by  asking  questions  designed  to  address  the  exercise’s  objectives.  In  addition, 
participants were invited to fill in templates for answering the specific questions. 

Participants came to the exercise ready to discuss the national and regional measures foreseen under 
emergency level as well as the actions to take in case of solidarity need or solidarity request. The 
rules of the exercise were: 

• 

• 

• 

• 

• 

• 

• 

Work within the framework of the Gas Security of Supply Regulation (Regulation 
(EU) 2017/1938) and Regulation (EU) 2022/2576 on enhancing solidarity; 

Participants  needed  to  bring  with  them  all  material  deemed  necessary  for 
addressing a crisis situation (mobile phone, laptop, moderate quantity of printed 
material, e.g., emergency plan of the country they represented); 

Participants  were  to  adhere  to  the  scenarios  and  work  with  the  information 
provided and available in their organizations; 

Participants  should  interact  with  other  colleagues  and  discuss  actions  as  they 
would do in a real emergency situation; 

Participants  were  required  to  act  assuming  that  they  had  all  the  necessary 
information.  Only  if  this  information  does  not  exist  in  their  organization,  they 
must report this fact; 

There are no "wrong" answers, everyone's opinion is valid; 

Time slots allocated were to be respected and instructions of the facilitator were 
to be followed. 

In the meeting, the Chatham House Rule applied (participants were free to use the information 
received,  but  neither  the  identity  nor  the  affiliation  of  the  speaker(s),  nor  that  of  any  other 
participant, might be revealed).  

The  overall  goal  of  the  exercise  was  to  draw  a  number  of  lessons  learnt  and  to  formulate 
suggestions for improving the capacity of national authorities, gas (and electricity) Transmission 
System Operators (TSOs) of the Member States, and the Commission in reacting adequately to gas 
emergencies  and  mitigating  as  much  as  possible  their  effects  through  the  application  of  their 
Emergency Plans and solidarity cooperation mechanisms.  

For  the  2022  exercise,  all  Member  States  and  the  European  Network  of  Transmission  System 
Operators for gas (ENTSOG) were invited to participate in the exercise. Eleven Member States 
(Austria,  Bulgaria,  Czech  Republic,  Greece,  Germany,  Hungary,  Italy,  Romania,  Slovenia, 

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Slovakia, and Spain), the Commission and ENTSOG had an active role, while most other Member 
States attended as observers. 

The specific objectives for the 2022 exercise were as follows:  

• 

• 

• 

• 

Assess the EU preparedness in case of a gas emergency and the functioning of the 
solidarity mechanism; 

Test the regional coordination among Member States; 

Enhance regional decision making and response capacity; 

Share experience and exchange lessons learnt. 

The exercise was conducted by means of a scenario that develops in two phases. During 
the first phase, a series of events affect the gas supply in Central Eastern Europe triggering 
the emergency declaration of several Member States. The scenario sets the framework to 
assess  the  response  to  the  emergency  declaration  under  the  Gas  SoS  Regulation.  The 
scenario progressed towards a succession of events that unchained the need of solidarity 
by some Member States. The solidarity mechanism is assessed in the second phase of the 
scenario. 

Participants were divided in two groups (A & B) during the session dedicated to emergency 
to promote discussion and benefit from the interaction of a smaller group. As for the second 
phase, due to the need of assessing the solidarity mechanisms at EU level, the participants 
met in a common group during the session dedicated to solidarity. 

For the 2024 exercise, all Member States, as well as Ukraine and Moldova, the Energy Community 
Secretariat, ENTSOG and ENTSO-E were invited to participate in the exercise. Twelve Member 
States  (Austria,  Bulgaria,  Croatia,  Czech  Republic,  Greece,  Germany,  Hungary,  Italy,  Poland, 
Romania, Slovenia, and Slovakia), Ukraine and Moldova, the Commission and ENTSOG had an 
active role, while the other 13 Member States and participants attended as contributors. 

The 2024 exercise was similar in format to the 2022 exercise. The key difference was the emphasis 
on  testing  the  joint  preparedness  with  Ukraine  and  Moldova  for  the  expiry  of  the  gas  transit 
agreement through Ukraine. In addition, the interaction between the gas and electricity systems in 
case of a cross-sectoral crisis was tested, as well as the preparedness in case of a cybersecurity 
incident in the gas sector.  

While the dry run exercises were crucial to test the emergency procedures in case of a crisis, they 
cannot cover all types of crises. This means that despite their comprehensive nature and the positive 
feedback received from participants, more exercises are needed to adequately test all the various 
procedures and provisions relevant to different crisis situations. In addition, they are simulation 
exercises,  meaning  that  there  may  be  a  discrepancy  between  how  participants  react  during  the 
simulation and how participants would react during a real crisis. It also means that assumptions 
had to be made regarding the nature and severity of the crisis, which in real life of course may 
differ. 

Desk research 

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Extensive  desk  research  was  carried  out,  with  the  support  of  the  Commission’s  Joint  Research 
Centre, to give scientific and analytical backing to this fitness check. This desk research was based 
on a set of indicators that predominantly featured in the chapter 3 “how has the situation evolved 
over the evaluation period” and chapter 4 “evaluation findings”.  

Indicators used to assess the Regulations as well as the overall security of gas and electricity supply 
situations in the EU include: 

Overarching energy indicators, such as the EU energy mix (gross inland consumption), electricity 
power  generation  per  technology  (see  graph  below),  EU  annual  gas  consumption  and  the 
electrification  rate  of  final  consumption  in  the  EU.  These  indicators  were  chosen  to  provide  a 
comprehensive  picture  of  the  energy  landscape,  which  serve  as  the  foundation  for  evaluating 
security of electricity and gas supply as they shed light on how diverse and resilient the energy 
sources are, influencing the stability and sustainability of energy supply. The bulk of data for these 
indicators is publicly available on Eurostat, the ENTSOG, ENTSO-E and GIE AGSI+ and ALSI+ 
transparency platforms. 

Figure 42: Electricity power generation per technology 

Source: ENER Chief Economist Unit, based on Fraunhofer and ENTSO-E data 

EU natural gas imports, the share of natural gas imports (LNG vs pipeline) and the  Herfindahl-
Hirschmann index (HHI) were used to evaluate the risk landscape related to natural gas imports. 
The EU natural gas imports give an overview of how the EU’s gas imports have changed over the 
years and show on which third countries there may be a potential dependency and the order of 
magnitude of such a potential dependency. The share of pipeline vs LNG of natural gas imports 
was chosen in order to assess the change in reliance on the global LNG market vs the reliance on 
suppliers on the other side of pipeline import routes. This is important because since the Russian 
invasion of Ukraine, the EU has moved towards importing more natural gas via LNG, which brings 
risks (geopolitical or otherwise) and for which there are different infrastructure needs. The HHI 
index  was  used  to  provide  a  measure  of  diversification  of  EU  natural  gas  supplies,  which  is 
imperative for assessing the security of gas supply in the EU. Energy import origin concentration 
index shows in  one figure,  how  varied  import  origins  of  energy  sources  are.  It is  based  on  the 
Herfindahl-Hirschman index (HHI) principle, i.e. adding the square of the shares of every origin 

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in the total import. This indicator lies in the interval [0, 1]. Lower values of this index mean more 
diversified  origins,  higher  values  mean  more  concentrated  origins.  Calculations  are  based  on 
EUROSTAT data nrg_ti_gas and nrg_te_gas. An unspecified origin is also included for the HHI 
indicators. 

To paint the picture of the degree of interconnectedness between the gas and electricity systems, 
the  percentage  of  electricity  produced  with  gas  and  the  percentage  of  gas  used  for  producing 
electricity  have  been  calculated.  This  has  been  done  based  on  Eurostat  data,  by  dividing  gross 
electricity  production  with  natural  gas in  TWh  (PE_NG)  by  final  consumption  of  electricity  in 
TWh (FCE), and transformation input of NG for electricity and combined heat and power in TWh 
(TI_EHG) by inland consumption of natural gas in TWh (IC_NG). This is an oversimplification of 
the situation and is merely indicative. In reality, the interconnectedness also depends on e.g. how 
critical the gas volumes are to the adequacy of the electricity system, not just the volumes of gas 
used  for  electricity.  The  latter  also  depends  on  the  role  that  gas-fired  power  plants  have  in  an 
electricity system (e.g. whether it is used as back-up generation).  

For electricity, the Loss of Load Expectation (LOLE) and Expected Energy Not Served (EENS) 
are  key  indicators.  LOLE  in  a  given  geographical  zone  and  for  a  given  period  is  the  expected 
number of hours during which a lack of market-based resources is expected to cover the demand 
needs with sufficient transmission grid operational security limits. This indicator is very useful to 
give an overview of adequacy over longer periods and is commonly used in adequacy assessments 
such as the European Resource Adequacy Assessment. It is expressed in hours per year. EENS in 
a given geographical zone and for a given period is the energy (MWh) which is expected not to be 
supplied due to a lack of market-based resources retaining sufficient transmission grid operational 
security limits. This indicator describes the magnitude of adequacy issues expressed in energy for 
an analysed season. It is expressed in GWh(MWh)/year. 
The share of centralised and decentralised electricity generation is an important indicator, as a more 
decentralised  system  is  more  resilient  to  market  volatility  and  disruptions  on  the  transmission 
system.  The  figures  used  in  this  fitness  (see  table  below)  are  estimations  based  on  ENTSO-E 
statistical  factsheet  2023  and  CETO  2024.  It  should  be  noted  however  that  there  are  some 
uncertainties regarding the exactitude of the below figures, because of high discrepancies across 
databases. 

Table 2: Installed centralized and decentralized electricity generation capacities in 
2024 (nominal) 

Centralised 
Nuclear 
Fossil fuels 
Waste 
Other non-renewable 
Hydro pumped storage 
Hydro ror and reservoir 
Wind  
Solar Thermal 

GW 
94 
307 
6 
13 
39 
108 
285 
2 

EN 

100 
EN 

 
 
Solar PV 
TOTAL 

Decentralised 
Hydro run-of-river  
Solar PV 
Biogas 
TOTAL 

146 
1000 

GW 
3 
201 
12(*) 
216 

Source:  JRC  estimations,  ENTSO-E  statistical  Factsheet  2024  and  CETO  2025  data233.  Biogas 
data refers to 2023. 

Assessing the vulnerability of the EU’s energy system to cyberattacks is challenging due to a lack 
of official statistics at EU level. However, the number of successful cyberattacks per year against 
European energy and utility companies has been used, in order to provide an indication of the threat 
level face by European energy undertakings. Data stems from a Energicert report of September 
2022, from the Danish critical sectors’ cybersecurity centre, which monitors the cyber threat to 
Danish critical sectors. The report is based on public sources only, for security reasons, meaning 
that the accuracy of the data may not always be guaranteed by Energicert as they rely on third 
sources, as indicated in their 2022 report.  

Extreme weather events are affecting the EU’s energy system (electricity system in particular), and 
protection  of  critical  energy  infrastructure  against  extreme  weather  events  is  of  paramount 
importance to EU security of electricity and gas supply. Therefore, the number of extreme weather 
events in Europe (including a split per type of extreme weather events for 2019-2022) has been 
included.  The  graph  and  data  come  from the  European  Environment  Agency, Climate  Change, 
impacts  and  vulnerability  in  Europe  2022,  European  Severe  Weather  Database  (ESWD), 
Copernicus  Emergency  Management  Service  (CEMS)  2022  Annual  report  and  International 
Disaster Database (EM-DAT). (2022). EM-DAT Data.   

Governance quality was assessed by using the World Bank’s Worldwide Governance Indicators 
(WGI). WGI reports on six broad dimensions of governance for over 200 countries and territories 
over the period 1996-2023: 1) voice and accountability, 2) regulatory quality, 3) political stability 
and  absence  of  violence/terrorism,  4)  rule  of  law,  5)  government  effectiveness,  6)  control  of 
corruption. It is based on over 30 underlying data sources, and six aggregate indicators are created 
by using a statistical methodology known as an Unobserved Components Model (UCM).234 For 
this report, the eleven top supplying third countries were selected, using the allocated WGI grade 
between -2,5 and 2,5 for each of six indicators. The higher the grade, the better for governance 
quality. The EU average grade was computed by multiplying the countries’ average grades by their 

233  JRC  Clean  Energy  Technology  Observatory 

(CETO)  Technology  Reports,  available  at: 

234 

EN 

https://setis.ec.europa.eu/publications-and-documents/clean-energy-technology-observatory/ceto-
reports-2025_en  
 The 
https://documents.worldbank.org/en/publication/documents-
reports/documentdetail/099005210162424110 

methodology 

available 

fully 

is 

online: 

101 
EN 

 
 
 
 
 
relative 
are 
gas 
https://www.worldbank.org/en/publication/worldwide-governance-indicators 

Datasets 

imports. 

share 

EU 

in 

available 

at: 

To  assess  the  state  of  play  of  the  implementation  of  the  evaluated  Regulations,  the  amount  of 
submissions of deliverables due under the evaluated Regulations (and their timeliness), the amount 
of  Gas  and  Electricity  Coordination  Group  meetings,  the  amount  of  crisis  levels  declared,  the 
amount of storage certifications adopted and pending, the amount of solidarity agreements and the 
amount  of  infringement  procedures  have  been  included  as  indicators.  This  paints  a  picture  of 
whether there are any issues with implementation for Member States, which could either indicate 
a  high  administrative  burden,  or  a  lacklustre  implementation.  Data  comes  from  the  European 
Commission’s  Directorate-General  for  Energy,  based  on  Member  States’  submissions  of  the 
various  deliverables  (risk  assessments,  plans  and/or  methodologies)  or  Gas  and  Electricity 
Coordination Group meetings. However, evaluating the exact state-of-play of implementation goes 
beyond assessing these indicators and can at times be more intangible. For example, the level of 
preparedness to a gas or electricity crisis does not merely depend on having adequate plans or risk 
assessments, but also on human factors and behaviour during an actual crisis.  

For  the  infrastructure  standard  indicator  data  has  been  provided  by  Member  States’  preventive 
action plans and the Commission’s Joint Research Centre has collected them. The N-1 indicator is 
calculated according to the formula set out in Annex II in Regulation (EU) 2017/1938, which is:  

The exact definitions of the parameters are provided in Annex II of Regulation (EU) 2017/1938. 
This indicator measures the technical capacity of a national gas network to satisfy an exceptional 
daily  gas  demand  when  losing  its  largest  infrastructure.  The  parameters  in  the  formula  are  the 
addition of the technical capacity of entry points in mcm/d (EPm) maximal technical production 
capability in mcm/d (Pm), the maximal technical storage deliverability in mcm/d (Sm), the maximal 
technical send-out capacity of all LNG regasification facilities in  mcm/d (LNGm), the technical 
capacity of the single largest gas infrastructure in mcm/d (Im) and the total daily gas demand during 
a day of exceptionally high gas demand occurring with a statistical probability of once in 20 years 
(Dmax).  Some  Member  States  have  provided  two values  for  storage  deliverability  either  at 30% 
filling or 100% storage filling levels which affects the withdrawal capacity of underground gas 
storages (affecting parameters Sm and potentially Im). In this case, 100% storage filling has been 
chosen, as this value was provided by all Member States and for comparison purposes with years 
before 2017 (in the old Regulation (EU) 994/2010 the indicator was requested only at 100% storage 
filling level). Additionally, a box plot of the bi-directionality indicator of all borders inside the EU 
from  2017  to  2023  has  been  included,  with  1  being  full  bi-directionality  of  all  pipeline 
interconnection points and 0 meaning all pipeline interconnection points being unidirectional. For 
each border, the smallest capacity is divided by the largest (values between 0 and 1). The maximum 
number  of  possible  values  is  the  number  of  borders.  Capacities  are  taken  from  ENTSOG’s 
transparency platform. While both indicators are indispensable to assess the EU’s security of gas 
supply  and  while  it  is  certainly  likely  that  the  Gas  Security  of  Supply  Regulation  provided 
incentives to comply with the Regulation, the causal relationship between the two is difficult to 
establish.  

EN 

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Figure 43: Infrastructure standard (N-1) per Member State 

Source: Commission’s Joint Research Centre, based on Member States’ plans235 

For the  energy  crisis,  several  indicators  were included  in  this  report.  The  storage  filling  during 
2021-2022 of underground gas storages that were owned by Gazprom (or where Gazprom had user 
rights  to  the  storage  facility)  and  the  non-Gazprom  storages  was  included,  produced  by  the 
Commission’s Joint Research Centre based on GIE AGSI data. This indicator is useful to highlight 
the market behaviour of Gazprom that was one of the main causes of the energy crisis. In addition, 
the wholesale electricity prices (in €/MWh) across the EU, as well as the average lowest (Sweden) 
and highest (Italy) during the crisis were shown. This shows the impact of the energy crisis, since 
the main impact of the supply cuts were an increase in prices. One of the main ways the energy 
crisis was tackled, was by reducing gas demand to re-establish the supply-demand balance after 
the gas supply cuts from Russia. Therefore, the monthly natural gas demand reduction compared 
to the 5-year reference period included in the Gas Demand Reduction Regulation (EU) 2022/1369 
has  been  used  as  an  indicator,  to  track  the  progress  of  this  response  to  the  energy  crisis.  The 
reference period is defined as the average of the previous 5 years for the period August 2022 to 
May 2023 (as laid out in the demand reduction regulation). Therefore, for August-December it 
refers to 2017-2021, but for January-May to 2018-2022. Data comes from Eurostat’s nrg_cb_gasm.  

It is difficult to find reliable data on blackouts as many authors have reported236. Most data comes 
from the US that is more used to extreme weather events. An exception is the Nordic and Baltic 
regions  which  publish  a  detailed  annual  report  on  faults,  disturbances  and  energy  not  supplied 
(ENS) in their transmission alternating current (ac) power grids, including a detailed analysis on 
individual components of the grid.   

235 

236 

EN 

 Three Member States with small and isolated gas markets (SE, LU, SI) are exempted from the N-1 rule, due to 
Article 5(9) of the Gas Security of Supply Regulation. 

 See  for  example,  Sanja  Duvnjak  Žarković,  Xavier  Weiss,  and  Patrik  Hilber,  ‘Addressing  Data  Deficiencies  in 
Outage  Reports:  A  Qualitative  and  Machine  Learning  Approach’,  Electric  Power  Systems  Research  236  (1 
November 2024): 110901, https://doi.org/10.1016/j.epsr.2024.110901. 

103 
EN 

 
 
 
 
The estimation of cost incurred due to a blackout is typically built considering the following two 
indicators: 

Energy not supplied (ENS): an estimation of the amount of energy which would have been supplied 
to  end-users  if  no  interruption  of  electricity  had  occurred.  Each  operator  estimates  its  value 
following different procedures237.  

Value of Lost Load (VoLL). It is a measure used to quantify the damage caused by interruptions 
of  electricity  supply  (€/MWh).  There  are  several  methods  for  determining  its  value  based  on 
surveys,  macro-economic  data,  or  revealed  preferences.  The  use  of  surveys  is  a  very  common 
approach, in particular when the focus is on households. There are three different survey-based 
approaches for estimating the VoLL: willingness-to-pay (WTP), willingness-to-accept (WTA) and 
direct  worth.  Several  factors  influence  the  estimation  of  VoLL  by  end-users:  specific  power 
interruption  scenario,  specific  sector,  outage  duration  (few  hours  are  acceptable  for  many 
consumers, but unit cost increases exponentially with the duration of the disruption of electricity), 
period  of  occurrence  (day/night,  season),  societal  cost,  if  there  is  a  pre-notification  or  not,  etc. 
Figure  35  represents  the  discrepancy  of  VoLL  values  depending  on  the  method  used  for  its 
estimation. It should be noted that ACER has adopted in 2020 a methodology for calculating the 
VoLL, the cost of new entry and the reliability standard238. 

237  ENTSOE, 

‘HVAC  Nordic  and  Baltic  Grid  Distrubance  Statistics  2023’,  11  December  2024, 

https://eepublicdownloads.entsoe.eu/clean-
documents/SOC%20documents/Nordic/2024/HVAC_NORDIC_AND_BALTIC_GRID_DISTURBANCE_STAT
ISTICS_2023.pdf.  

238  https://acer.europa.eu/sites/default/files/documents/Decisions_annex/ACER%20Decision%2023-

2020%20on%20VOLL%20CONE%20RS%20-%20Annex%20I.pdf 

EN 

104 
EN 

 
 
 
 
 
Figure 44: VoLL value estimation based on macro data (blue bar) or survey-based (red 
point). 

Source:  ACER  webinar  on  the  implementation  of  the  EU  methodology  for  electricity 
adequacy metrics. 5 June 2024 

The  cost  of  short-term,  limited  geographic-scale  power  disruptions  has  been  studied  for  many 
years, but there is a lack of studies and methods to estimate the cost of long duration disruptions 
(typically  more  than  one  day)  and  large  geographical  scope239.  One  of  the  main  barriers  is  the 
difficulty of assessing the social impacts of large outages. 

To the best of our knowledge there are currently three tools to assess the cost of outages: two tools 
focus on the US: i) the interruption cost estimate calculator240, ii) the power outage economic tool  
(POET), not yet published. The third tool is the blackout-simulator241, which focuses on Europe. It 
is worth mentioning that as the main input data of these tools is based on surveys (at least for the 
households’ segment), it is not adequate to use the tools developed in the US due to the significant 
differences in electricity prices between the US and Europe. A summary of the main characteristics 
of the blackout simulator tool is provided, cofounded by the Commission under FP7 with grant 
number 261696, including its main limitations242: 

Blackout simulator considers the economic costs for companies, institutions and establishments, 
and households’ willingness to pay (WTP) to avoid power cuts.  

The  tool  was  developed  to  estimate  power  outage  costs  for  the  period  from  2000  to  2017.  In 
particular, the data for the estimation of household sector costs is based on a survey conducted in 
2012 considering information from 8300 households. 

239  ‘Frontiers  in  the  Economics  of  Widespread,  Long-Duration  Power  Interruptions.  Proceedings  from  an  Expert 

Workshop’ (Lawrence Berkeley National Laboratory, January 2019). 

240 https://www.icecalculator.com  
241 http://blackout-simulator.com/ 
242 

 http://blackout-simulator.com/methodology/  

EN 

105 
EN 

 
 
 
 
The economic cost estimation does not consider long-term costs of macroeconomic relevance as 
this cannot be assigned to individual events.  

The cost due to damage to, or destruction of the electricity infrastructure is not considered. 

The tool cannot be used to estimate outages lasting longer than 48 hours. 

For  this report, the socio-economic impacts  of  a  second  historical  black-out  were  simulated.  A 
dataset on power blackouts in Europe was analysed, and a blackout that occurred in the Balearic 
Islands  on  13  November  2008  was  selected  as  a  second  case  study.  This  choice  was  based  on 
availability of information, modelling convenience and the difference with the first example. GDP 
data for 2008 for the Balearic Island case study was taken from Instituto Nacional de Estadística.243 

Regarding data on interrupted energy (ENS), the following databases have been considered:  
Nordic and Baltic region annual outage reporting244  

Power blackouts in Europe245 

Nordic and Baltic region annual outage reporting system 

This annual report provides an overview of faults, disturbances and ENS in the Nordic and Baltic 
100-420 kV power grids. Out of scope are faults in generation units, faults in grids below 100 kV 
(most of the distribution grids and local grids), faults during testing or maintenance, or faults in 
HVDC power lines. Faults are classified according to the criteria shown in the table below. 

243  See:  

https://ine.es/dyngs/INEbase/en/operacion.htm?c=Estadistica_C&cid=1254736167628&menu=resultados&idp=1
254735576581 

244  https://www.entsoe.eu/publications/system-operations-reports/#nordic 
245  Andrej  Stankovski  et  al.,  ‘Power  Blackouts  in  Europe:  Analyses,  Key  Insights,  and  Recommendations  from 
Empirical Evidence’, Joule 7, no. 11 (15 November 2023): 2468–84, https://doi.org/10.1016/j.joule.2023.09.005. 

EN 

106 
EN 

 
 
 
Figure 45: Causes of grid faults 

Source: HVAC Nordic and Baltic grid disturbance statistics 2023. 11 December 2024 

Power blackouts in Europe 

The authors of this work have compiled 478 severe events from the European transmission system, 
between 1972 and 2021. The main sources of information are publicly available data, so there is 
information missing in the database. To summarize, the most common initiator of the failures are 
weather events, in 32% of all events. Cascading occurrences are the biggest threat due to the highly 
interconnected European power system. The impact of cascading failures contributes to more than 
91% of the total ENS. Seasonality affects the recovery time which is significantly longer in winter 
due to the high number of physically damaged components. Recovery times are shorter for events 
with a high impact, which can be explained by the available resources that TSO commit during 
these extreme events. 

While the utmost effort has been made to be comprehensive and to have meaningful and robust 
results, there are several shortcomings. In particular, there are exogenous factors that influence EU 
energy security. Energy security is a complex interplay of global dynamics, including geopolitical 
shifts,  international market  fluctuations,  and the  actions  of  external  suppliers. While this report 
acknowledges  these  factors,  it  proved  challenging  to  quantify  their  actual  impacts  on  both  EU 
security of electricity and gas supply and the results of the evaluated interventions. Establishing 
causality between provisions of the two Regulations and the subsequent outcomes is therefore in 
most cases not possible. 

In addition, data and streamlined key performance indicators (KPIs) were not always sufficiently 
available  to  monitor  and  evaluate  the  Regulations,  in  particular  given  the  large  number  of 
hypothetical scenarios for which the Regulation prepares. This may need to be addressed in the 
future, by adding clear monitoring parameters to assess the performance of the Regulations. Due 

EN 

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to  the  ‘preparedness-paradox’,  a  counterfactual  is  absent,  meaning  that  it  is  not  possible  to 
determine which crises have been prevented and what their impact would have been. 

Other activities 

In  addition  to  the  aforementioned  activities,  informal  exchanges  have  been  held  with  Member 
States  and  stakeholders  that  have  tasks  assigned  to  them  by  the  Regulations.  In  particular,  the 
Commission’s Directorate-General for Energy inquired about costs incurred directly attributable 
to the provisions of the Regulations, which were used for the costs and benefits overview in Annex 
IV and the efficiency criteria. Most Member States and/or stakeholders indicated the costs in FTE 
or hours worked. When the costs reflected administrative costs, they have been kept in units of 
time and have not been monetised (unless the monetary value was not already provided directly) 
by using the hourly rate (+25% overhead) of the OIOO tariffs standard cost model. This approach 
was chosen because the OIOO tariffs at our disposal were outdated (2018) meaning that they likely 
do not reflect the current rates and because the time spent was not reported for management level 
or non-management level. All of this means that time spent is a more accurate proxy. Nevertheless, 
the numbers provided in the Annex are clearly an oversimplification and most likely do not actually 
reflect the cost incurred for a number of reasons. Firstly, several Member States and/or stakeholders 
indicated that they found it difficult to estimate the hours or FTE attributable to the Regulations. 
Secondly,  not  all  Member  States  and/or  stakeholders  provided  the  data  needed  to  give  a 
comprehensive overview. Lastly, due to a lack of data availability, it was not possible to triangulate 
the data received from Member States and stakeholders, meaning that the numbers may not be 
robust. The absolute values of the costs therefore should not be taken as absolute truths but are 
only indicative and should only be used to compare the order of magnitude of costs of the different 
provisions with one another. For this reason, the approach was taken to provide ranges of reported 
costs, rather than provide a specific number, which reflects the uncertainty associated with the costs 
of the Regulations.  

In addition, there is a general difficulty of putting a monetary value on (and even quantifying in 
other ways) the benefits associated with security of supply, due in particular to the absence of an 
accurate counterfactual. Security of supply policy functions in many cases as insurance for severe 
but unlikely events. Several of the provisions in the two Regulations will hopefully never have to 
be  used,  making  their  related  benefits  difficult  to  assess.  Due  to  the  ‘preparedness-paradox’,  a 
counterfactual  is  absent,  meaning  that  it  is  not  possible  to  determine  which  crises  have  been 
prevented and what their impact would have been. Aforementioned simulation exercises such as 
the blackout simulator, or dry run exercises can give an indicative picture for hypothetical crises 
but  cannot  say  which  events  have  in  fact  been  prevented  (which  is  the  ultimate  benefit  of  the 
Regulations). 

Another  activity  carried  out  to  inform  this  fitness  check  was  a  strategic  foresight  workshop, 
organised  by  three  junior  professionals  of  the  Commission’s  Junior  Professional  Program, 
sponsored  by  Directorate-General for  Energy’s  Unit F4.  This  workshop  was  mostly relevant to 
inform the evaluation  based  on  the ‘relevance’  criteria,  in  particular  to see  whether  the  current 
framework is fit for future challenges. While the strategic foresight workshop based on the JRC’s 
Megatrends  tool  was  in  informative  exercise,  the  exercise  has  its  limitations.  In  particular,  the 
Megatrends tool is useful to understand general direction of broader developments that are relevant 
for  EU  energy  security.  However,  to  translate  this  into  specific  policy-relevant  insights  or 

EN 

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recommendations proved challenging. In addition, the participants consisted of both members from 
the ISG, representatives from other DGs or agencies that indirectly are affected by energy policy, 
as well as energy experts from DG ENER. While this provided an appropriate balance between 
experts  and  non-experts,  discussions  often remained  at macro-level  and  recommendations  were 
therefore mostly generic in nature. In order to provide more meaningful strategic foresight, more 
follow-up workshops would need to be organised. However, given resource constraints, this was 
out of the scope for this fitness check. More details on the strategic foresight workshop can be 
found in Annex VI.  

EN 

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ANNEX III. EVALUATION MATRIX  

EFFECTIVENESS 
To what extent were the Regulations successful in achieving their key objectives? 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators  and 
requirements 

information 

Data sources 

• 

EQ1 – To what extent have the Gas 
the  Electricity  Risk 
SoS  and 
Regulations 
Preparedness 
contributed 
in 
increase 
to  an 
security  of  supply,  preparedness 
and  resilience  of  the  EU  energy 
system? 

• 

• 

• 

EQ1.1  -  How  well  have  the  Gas 
SoS  and 
the  Electricity  Risk 
Regulations 
Preparedness 
protected  vulnerable  consumers 
from possible supply disruptions? 
EQ1.2 – Have the assessments of 
risks improved, in particular with 
the  protection  of 
regard 
infrastructure  to  cyber,  physical 
and ownership risks? 
EQ1.3 - Have the preventive and 
improved 
emergency  measures 
and  did  they  increase  the  EU’s 
preparedness for supply shocks? 

to 

•  EQ1.4  –  Have 

infrastructure 
needs  been  adequately  assessed 
and  addressed  to  ensure  security 
of  supply  even  during  disruption 
scenarios? 

•  Continuity  of  the  balance  between 
supply  and  demand,  meaning  no 
shortages,  disruptions  or  blackouts 
in the face of the risk covered by the 
Regulations. (EQ1). 

•  Sufficiency of the measures together 
to  protect  vulnerable  customers 
against supply disruptions (EQ1.1). 
•  Quality,  realism,  completeness  and 
the  update 
risk 
assessments and of electricity crisis 
scenarios (EQ1.2).  

frequency  of 

•  Robustness  of  national assessments 
of  physical,  cyber  and  ownership 
risks related to the pieces of energy 
infrastructure critical for security of 
energy supply. (E.Q1.2) 

•  Compliance  with 

the 

SSOs 

certification obligation. (E.Q1.2) 
•  Adequacy of the measures contained 
in  the  plans  to  mitigate  the  risks 
identified 
assessments 
(EQ1.3). 

the 

in 

Quantitative indicators 
• 

Number  of  declarations  of  crisis 
levels (EQ1) 
LOLE/EENS (EQ1) 
Amount  of  supply  disruptions/ 
blackouts (EQ1) 
Diversification  of  gas  supplies 
(HHI)) (EQ1) 
Storage  filling  -  percentage  of 
capacity  &  percentage  of  protected 
customer demand (EQ1) 
Amount 
procedures/EU  pilots 
questions) 
Number of SSOs certified (EQ1.2) 
N-1 (EQ1.4) 
Bi-directional 
(EQ1.4) 
Gas supply disruption simulations – 
(EQ1, EQ1.2, EQ1.3, EQ1.4) 

infringement 
sub-

capacity 

increase 

(all 

of 

• 
• 

• 

• 

• 

• 
• 
• 

• 

Qualitative indicators 
• 

Extent to which supply standard has 
been implemented by MSs (EQ1.1). 

Desk research: 

• 
• 

• 

• 
• 

national 

PAPs/EPs/RPPs 
Common 
risk 
and 
assessments,  cyber  posture  risk 
assessment 
Commission  opinions  on  the  Plans 
(all) 
GCG / ECG meetings 
Reports  reviewing  the  Regulations, 
ACER reports, JRC studies. 

Data sources: 

• 
• 
• 
• 

Eurostat (e.g., nrg_cb_gas(m)) 
ENTSO-E transparency platform 
ENTSOG transparency platform 
GIE AGSI transparency platform 

Other sources: 

• 
• 
• 
• 

ENTSOG simulations and outlooks 
ENTSO-E simulations and outlooks 
Dry runs, table-top exercises. 
Public consultation 

EN 

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•  Compliance  with  the  infrastructure 
bi-
requirements 

including 

standards, 
directionality 
(EQ1.4).  

•  Sufficiency,  availability  and  actual 
use  of  infrastructure  to  deal  with 
supply  cut  scenarios,  infrastructure 
disruption  scenarios  or  periods  of 
exceptionally 
demand 
(EQ1.4). 

high 

• 

• 

• 

Timeliness and completeness of risk 
assessments  and  plans 
(EQ1.2, 
EQ1.3). 
Extent  to  which  the  Commission’s 
opinions  were  followed  by  MS 
(EQ1.3) 
Preventive and mitigative measures 
included 
in  PAPs/EPs/RPPs  are 
consistent  with  the  identified  risks 
(EQ1.3). 

Answers: 
• 
▪ 
▪ 

EQ1.1 
No instances of mandatory curtailment occurred during the implementation period, neither in gas nor in electricity, which makes the effectiveness of the measures difficult to assess. 
Electricity SoS: there is no protection of vulnerable customers as such. Member States can establish users entitled to receive special protection against disconnection, with regard to public safety and personal 
security. Usually they include health facilities, essential social services, critical processes in industries: the approaches taken by Member States were quite varied, and the Commission had to request clarifications 
in several instances. One of the positive outcomes of this measure is that MSs were forced to review their manual load shedding plan; it is questionable whether the fairness criteria is sufficiently taken into account 
in those plans even if it is not a mandatory requirement). 

▪  Gas SoS: protected customers have not been curtailed during the implementation period. In addition, no major issues reported by respondents in implementing or enforcing the supply standard, which is specifically 
designed to protect the protected customers from supply disruptions. However, in the public consultation, some respondents highlighted the vagueness and the difficult monitoring the supply standard as potential 
issues. The report reviewing the Gas SoS Regulation pointed towards difficulties estimating protected customers’ demand, in particular when it is not on annual basis. Particularly, estimating demand in the two 
first cases of the supply standard is a challenge when daily metering is not available, as is the case in many countries for small consumers like households. 

• 
▪ 
▪ 

EQ1.2 
Overall, the assessment of risks has significantly improved during the implementation period. 
Electricity SoS:  

▪ 

▪ 

Compared to a no-intervention scenario (the 2016 Impact assessment considered that, without an EU-intervention, “risks would still be assessed and addressed on the basis of very different methods, and 
from a national perspective only”), there is a huge improvement: 1) two regional crisis scenarios report were elaborated ii)  there is a common methodology for the identification of scenarios that was 
developed and approved. This was an important step to improve collective risk assessment. At the same time, the policy objective of improving and harmonising risk assessments and preparedness were 
not completely met. 
According to Commission’s assessment of the plans, most of them did not provide a sufficient description of the scenarios: scenarios in the first iteration of the RPPs were very shallow, in particular 
those about gas crisis spillover. When the energy crisis started, some MS had to elaborate ad-hoc scenarios while others had to perform stress test to complement their preparedness. 
Not all concerned Member States adequately considered outermost regions in the definition of their national electricity crisis scenarios in their RPPs, while recital 20 of the Regulation requires to do so.  
Overall, the first cycle of regional crisis scenarios was not completely satisfactory (cf. EQ2.1): this led to a recommendation from the ECG and to an update of the methodology.  

▪ 
▪ 
▪  Ownership risks: Member States assessed the risks related to the ownership relevant to electricity security of supply and notified the Commission in January 2021. No major risks were identified, and 
most MS have preventive and preparedness measures in place. But assessment focused on grids (transmission/distribution assets): not much on generation, and no consideration of risks related to the 
ownership of relevant infrastructure in the gas sector, despite their importance for security of electricity supply, without any clarification on whether that would be relevant for the MS in question or not, 
which is not always evident. 

EN 

111 

EN 

 
 
 
▪ 

▪ 

Cybersecurity risks: For several of the RPPs received, the Commission made recommendations specifically for scenarios on cyber-risks. These scenarios were not addressed in much detail in the plans. 
The Commission recommended to include a reference to a framework with minimum and advanced cybersecurity requirements, procedures to follow in case of an incident, a description of the roles and 
interactions between the competent authority and the cyber-specific actors, such as CSIRT, CERT and cyber-specific authorities (considering the link between sectorial response and national level and 
EU cyber response), including during a crisis, and the links with cyber specific legislation. 
Physical risks: RPR requires Member States to assess risks to the security of supply arising from man-made events and to consider appropriate preventive and mitigating measures in their RPPs. 
However, when it comes to national electricity crisis scenarios, most plans lack a detailed and concrete assessment of threats related to physical attacks, despite their potential to significantly disrupt 
electricity supply. Strengthening these scenarios is essential to ensure a more robust response framework, particularly in light of the increasing targeting of critical energy infrastructure. Enhanced cross-
border coordination and information sharing among Member States are also crucial to effectively anticipate and mitigate such risks. This information is however considered as very sensitive by MSs. 

▪  Gas SoS:  

▪ 
▪ 

ENTSOG carried out three EU-wide simulation (2017, 2021, 2025) on which CRAs had to be based. 
CRAs have been developed in regional risk groups, which did not exist prior to the implementation of the Gas SoS Regulation. National risk assessments were not reported to the Commission prior to 
an EU intervention being in place.  

▪  Without the Gas SoS Regulation, the situation would most likely be similar to the one described in the 2016 IA’s baseline scenario, i.e. e risk assessments and plans will continue to be national and 
uncoordinated. The implementation pre-2016 has shown that they had very different focuses and paid little attention to common or coordinated scenarios and actions in the case of a supply disruption 
and the cross-border impact of national measures were not taken into account to the necessary extent. At the same time, the policy objective of enhancing preparedness through assessing risks has mostly 
been met, although there are still areas that do not fully meet this objective. 

▪  Ownership risks: Member States are required (if relevant) to take risks relating to the control of infrastructure in the national risk assessment (e.g. due to third country ownership of infrastructure), as 
well as cybersecurity risks and threats to critical infrastructure, especially if it can become an N-1 situation. Yet in only 5 out of 25 national risk assessments that were submitted to the Commission, the 
risk related to control of critical infrastructure was assessed. No significant impacts resulting from control of infrastructure were identified. While a number of certifications of storage system operators 
are still pending, there is currently no available evidence that storage ownership or storage operators could put the security of gas supply of the EU at immediate risk. 
▪ 

Cybersecurity risks: were identified in 14 out of 25 national risk assessments, usually in the form of a cyberattack on infrastructure.  

▪ 

Physical risks: physical threats to infrastructure were identified in 12 out of 25 risk assessments, usually due to terrorist attacks or sabotage of critical infrastructure.  

• 
▪ 

EQ1.3 
Electricity SoS: 

▪ 

▪ 

▪ 
▪ 

The RPPs exercise obliged Member States to establish procedures and mechanisms to inform the public in case of an electricity crisis (the European Commission requested additional information in only 
2 cases) as well as to review their manual load shedding plans, thereby reinforcing preparedness throughout the EU. 
However, the overall level of RPPs could be improved, and in 16 cases the Commission considered that the plans have to be amended to include further information on some national measures, including 
on procedures and corresponding information flows, triggers, and conditions or their application (especially for non-market-based measures). 
However, the quality of national measures in the plans was satisfactory (e.g., double fuel obligation for gas-fired power plants) and the link with national crisis scenarios was well-established. 
On emergency tests, most of the plans lacked concrete information to actually carry out the tests. During the RPPs exercise,  the Commission requested additional information about those tests in 18 
cases. In most cases, the calendar was missing; 3 plans were not referring at all to the mandatory tests. 

▪  Gas SoS:  

▪ 

▪ 

The Commission opinions recognised the overall quality and completeness of the Member States’ plans, in particular as regards the description of the specificities of the national gas systems. Thanks to 
this provision, Member States are obliged to make the necessary crisis arrangements, take into account their neighbouring Member States when designing them and ultimately also consult them on the 
measures they are intending to take in case of a crisis. Having plans in place brings a predictable and transparent framework for action.  
All  Member  States  now  have  preventive  and  crisis  measures  in  place,  which  is  a  positive  outcome  of  the  Regulation.  Usually  the  process,  the  appointed  crisis  managers,  as  well  as  the  roles  and 
responsibilities during a crisis are well described, which brings added value as it helps to identify the relevant actors during a crisis, for stakeholders and for neighbouring Member States.  

EN 

112 

EN 

 
 
 
▪ 

▪ 

▪ 
▪ 

▪ 

▪ 

▪ 

▪ 

In addition, the description of the national gas system that is required by the templates, is usually of high quality and brings a better understanding of the national system, as well as their interlinkages 
with neighbouring systems. 
As indicated in the Commission opinions, both in the plans of 2019 and 2023, the preventive measures described in the PAP and the crisis mitigation measures described in the EP are generally measures 
that are adequate to tackle or prevent crisis. However, the weakness is that they are often not tied to the risks identified in the risk assessments. There is a logical sequence in deliverables in the Regulation, 
with first providing risk assessments and then producing the plans. While it is a requirement of the Regulation, in practice this has not sufficiently been applied by Member States, making this sequence 
of deliverables less effective and less coherent.  
Areas of improvement identified in the Commission’s opinions were: 
PAPs  in  the 2023:  (1) insufficient  regional dimension,  (2)  inadequate identification of critical gas-fired power  plants,  (3)  lack of clear definition and  estimation  of  volumes of  (solidarity) protected 
customers, (4) inadequate preventive measures that are not associated with identified risks and (5) lack of distinction between market-based and non-market-based measures.  
EPs in the 2023: (1) lack of clear definition of parameters used to declare crisis levels, (2) unclarity regarding the measures to be adopted per crisis level, (3) insufficient consideration of measures to 
protect electricity generation and district heating and (4) a lack of an adequate regional dimension with insufficient description of cooperation mechanisms.  
PAPs in 2019: (1) details on stakeholder consultation, (2) information on the (enforcement of) the supply standard and lack of information on the infrastructure standard, (3) inaccurate information on 
(solidarity) protected customers, (4) details on the regional and national gas systems, (5) insufficient assessments of the impact of preventive measures on the economy, the internal market, consumers and 
the environment. 
EPs in 2019: (1) lack of regional chapters due to lack of solidarity agreements, (2) plans don’t mention the quantitative impacts of measures and often no explicit priority orders are defined, (3) interruptible 
contracts and fuel switching are often mentioned but not clear when it would be activated and what their expected impact would be. 

All in all, it means that the policy objectives to have (1) adequate levels of regional and EU-wide cooperation and information sharing, (2) establish clear roles and responsibilities for crisis situations, 
and (3) enhance preparedness and transparency of measures have largely been met. However, there is room for improvement to adequately enhance preparedness through a risk-based approach through 
the risk assessments and plans.  

EQ1.4 

▪ 

Electricity SoS:  

▪ 

▪ 

No infrastructure standard as such. Article 5 only requires ENTSO-E to consider “accidental hazards going beyond the N-1 security criterion and exceptional contingencies” in the identification of 
regional crisis scenarios. 
Article 11(1)(k) requires Member States to include in their RPPs “information on related and necessary plans for developing the future grid that will help to cope with the consequences of identified 
electricity crisis scenarios”. But most of the Member States did not include such information. As part of the RPPs exercise, the Commission requested more information on this point in 14 cases. 

▪  Gas SoS:  

▪ 

▪ 

N-1 has significantly improved over the years, with only Greece and Ireland not meeting the N-1 standard (apart from those exempted). In 2023, Finland also temporarily did not meet the N-1 requirement 
due to the Balticconnector disruption, which is now back in operation. The Finnish example demonstrated the relevance of such criteria, as without a situation where it complied with the N-1 standard, 
it would have had severe difficulties to cope with such a disruption. 
Reverse flows due to bi-directional capacity, helped shifting flows from West to East after RU supply cuts in 2022. Bi-directional capacities have significantly increased over the evaluated period. 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators and information requirements 

Data sources 

• 

EQ2  –  To  what  extent  have 
the  Gas  Security  of  Supply 
the  Electricity  Risk 
and 
Regulations 
Preparedness 

• 

EQ2.1  –  To  what  extent 
have  the  Electricity  Risk 
Preparedness  and  the  Gas 
Regulations 
SoS 

•  Embedding of cross-
border  risks  within 
risk 
common 
and 
assessments 

EN 

• 

113 

Quantitative indicators 
• 

Amount of ECG, GCG, regional risk group and Crisis Management Group meetings 
(EQ2, EQ2.1, EQ2.3, EQ2.4, EQ2.5) 
Amount of infringement procedures/EU pilots (all) 

Desk research: 

• 

PAPs/EPs/RPPs 

EN 

 
 
 
enhanced 
to 
contributed 
coordination among Member 
States,  as  well  as  EU-wide 
and 
regional  cooperation, 
especially during crises? 

• 

• 

• 

• 

to 

contributed  to  improving 
regional  risk  assessments, 
cross-border 
reducing 
reducing 
risks,  or 
to 
that 
national  measures 
affect 
negatively 
neighbouring countries? 
EQ2.2  –  To  what  extent 
have  the  Electricity  Risk 
Preparedness  and  the  Gas 
Regulations 
SoS 
the 
contributed 
adoption 
regional 
of 
measures  by  Member 
States? 
EQ2.3  –  To  what  extent 
have  the  Electricity  Risk 
Preparedness  and  the  Gas 
SoS Regulations increased 
and 
transparency 
information 
sharing 
among  Member  States, 
and  between  Member 
States 
the 
Commission? 
EQ2.4 – Has regional and 
EU-wide 
cooperation 
been  effective  over  the 
implementation period? 
EQ2.5  –  To  what  extent 
emergency 
have 
cooperation 
joint 
and 
crisis  management  been 
effectively implemented? 

and 

regional 
scenarios (EQ2.1) 

crisis 

•  Absence 

of 
restrictive  measures 
with  adverse  effects 
neighbouring 
on 
countries 
in 
PAPs/EPs/RPPs 
(EQ2.1) 

•  Non-implementation 
restrictive 
of 
measures 
with 
adverse  impacts  on 
neighbouring 
countries  during  a 
crisis  (EQ2.1  &  EQ 
2.5). 

•  Joint  elaboration  of 
risk  assessments  in 
risk  groups  (EQ2.1 
& EQ2.3). 

•  Consultation of plans 
neighbouring 
(EQ2.1  & 

with 
MSs 
EQ2.3).  
•  Functional 
information 
exchange, 
and 
coordination 
cooperation  through 
ECG, 
GCG, 
Regional risk groups, 
RCCs 
(EQ2.3  & 
EQ2.4).  

•  Operationality 
and 
effectiveness 
of 
ECG,  GCG  and  the 
Crisis  Management 

• 
• 
• 

• 

• 

• 

Amount of solidarity agreements (EQ2.5) 
Gas supply disruption simulations – ( EQ2.1) 
Amount of times EU/MSs tested crisis management procedures and provisions in 
their plans, e.g. via TTXs (EQ2.4, EQ2.5). 
Number  of  measures 
RPPs/PAPs/EPs. (EQ2.1)  
Number of measures to restrict cross-border energy trade implemented during crisis 
situations. (EQ2.1)  
Number of regional measures includes in RPPs/PAPs/EPs (EQ2.2) 

to  restrict  cross-border  energy 

included 

trade 

in 

Qualitative indicators 
• 

Timeliness and completeness of risk assessments and plans (EQ2, EQ2.1, EQ2.2, 
EQ2.3, EQ2.4). 

•  MSs were sufficiently consulted on each other’s plans and risk assessments (EQ2.1, 

EQ2.3).  

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

and 
risk 

Common 
national 
assessments 
Commission 
opinions  on  the 
Plans (all) 
GCG 
meetings 
Reports 
reviewing 
Regulations, 
ACER 
JRC studies. 

/  ECG 

reports, 

the 

(e.g., 

Data sources: 
Eurostat 
nrg_cb_gas(m)) 
ENTSO-E 
transparency 
platform 
ENTSOG 
transparency 
platform 
GIE 
transparency 
platform 

AGSI 

and 

Other sources: 
ENTSOG 
simulations 
outlooks 
ENTSO-E 
simulations 
outlooks 
Dry  runs,  table-
top exercises. 
Public 
consultation 

and 

EN 

114 

EN 

 
 
 
 
 
Group  to  coordinate 
during crises (EQ 2.3 
& EQ2.5).  
• Operationality 

of 
solidarity  to  ensure 
that  MSs  can  offer 
assistance  to  another 
MS 
in  emergency 
(EQ 2.3 & EQ2.5). 

• 
▪ 

EQ2.1 
Electricity SoS: 

▪ 

▪ 

In 2017 Bulgaria had put in place an export ban on electricity; the Commission commissioned a study to assess the impacts of  the ban, which concluded that it had resulted in a loss of approximately 
EUR 27 million for Bulgarian generators. The Commission imposed a fine of EUR 77 million on Bulgaria in 2019 and Bulgaria had to pay compensation to neighbouring countries due to the electricity 
export ban. This type of measure was not implemented since the entry into force of the regulation. 
On risk assessment: 

• 

• 
• 

ENTSO-E was tasked to develop regional crisis scenarios. However, these regional scenarios were, in reality, assessed at pan-European level. Sufficient details on certain scenarios and on 
their particular relevance for certain regions were not provided. Overall, the first cycle provided a good baseline for improvement, but also showed that the methodology had some limitations. 
The methodology was thus updated, and ENTSO-E presented a new regional scenarios assessment in 2024. For the first time, two scenaFor the first time, two scenarios (out of 23) were 
simulated to better assess the cross-border affects in the evaluation of the scenarios. ENTSO-E concluded in their report that ‘the first effort to simulate impact of regional crisis scenarios 
show promising potential to improve the risk preparedness in the electricity sector’.iiAccording to the regulation, only ENTSO-E can trigger an update of the regional scenarios (not the ECG 
nor the Commission). In addition, while the regulation requires ENTSO-E to update the regional scenarios at least every four years, it does not define the exact scope of an update. Lastly, 
while the regulation allows the ECG to suggest some amendments to the scenarios, these are not binding. However, following the recommendation issued by the ECG following the first 
identification of regional scenarios, ENTSO-E decided to carry out a revision of the methodology to address the shortcomings identified and best practices. Such revision of the methodology 
can be also requested by ACER and the Commission.  
According to the regulation, national crisis scenarios have to be consistent with regional crisis scenarios: however, in a limited number of cases there was a divergence between both.  
The instruments envisaged by the Regulation have helped improve cross-border coordination, and consequently reduce risks by being better prepared in real cases. For example, following 
the full-scale invasion of Ukraine by Russia, work was enhanced and accelerated to have the Winter supply Outlook earlier. In its 2022/2023 winter outlook, ENTSO-E stressed the importance 
of coordination tools to ensure the continued balance between supply and demand in the European power system. 

▪  Gas SoS:  

▪ 

▪ 

Before the Regulation, there was no framework to identify (let alone address) cross-border risks. The Regulation created the obligation for MSs to create common risk assessments in regional risk groups. 
In the latest CRAs, a series of risks were identified often taking a full Russian supply disruption as the baseline scenario. On top of a full Russian supply disruption among others individual pipeline 
disruptions, liquefaction trains being out of service, or cold-spells were simulated. This means that the common risk assessments have mostly met the policy objective of enhancing preparedness and 
transparency of measures through a risk-based approach, although there are areas that require further work to ensure that this objective is completely met.   
6 MSs have included measures in their emergency plans of 2023 that restrict cross-border flows, which is the same as in the 2019 version of the EPs. This does not necessarily mean that these restrictions 
are undue during a crisis, as the justification of activating such measures will depend on the situation at hand. No cross-border restriction has been implemented thus far during a crisis. The regulation 
also provides for the Commission to act as a safeguard in case restrictive measures are implemented (this role was recognised and appreciated during the dry run).  

EN 

115 

EN 

 
 
▪ 

A gas neutrality charge was introduced by Germany, which was seen as a hindrance to cross-border trade, was implemented during the crisis to refinance the costs incurred to fill storages. It proved an 
obstacle to phasing out Russian pipeline gas, as alternative routes for Member States from the Central and Eastern Europe region became more expensive. In this particular case, the framework proved 
to be not successful in preventing and resolving the situation, even if the measure is not active anymore since 1 January 20251 

• 

EQ2.2  
▪ 

▪ 
▪ 

▪  Gas SoS:  

Electricity SoS: In RPR, the regional measures are aimed at implementing the so-called cooperation mechanism that consists of the provision of assistance among MS in a spirit of solidarity to prevent or 
manage a crisis within a particular region (as defined in the Regulation), 
▪ 

On regional measures, work remains in progress and has not been completed. Some MS are more advanced, especially Penta which was the first to sign a MoU. Czechia, Austria, Germany, Hungary, 
Poland and Slovakia also signed a MoU in 2022. 
Consequently, most of the RPPs lacked information about the measures necessary to implement and enforce regional and bilateral measures to comply with the cooperation and assistance mechanism. 
As part of the RPPs exercise, clarifications regarding the definition of region were requested in 6 cases. 

▪ 

▪ 

Regional risk groups have developed common risk assessments but no measures to address such regional risks are required by the Gas SoS Regulation and the Plans and associated measures are consulted 
within the group. In addition, the regional chapters of the PAPs and EPs where e.g. cooperation mechanisms between Member States within a region are required to be described by the Regulation, are 
often incomplete, as flagged in the Commission’s opinions of the plans. Description of regional measures are often missing.   
However, cooperation has actually gone beyond the regional dimension. The most recent developments and exchanges with MS concluded to the need for a single European risk group for LNG, reflecting 
the importance of wider regional cooperation and efficient integration of the market all over the EU. 

• 
▪ 

EQ2.3 
Electricity SoS:  

▪  Member  States had to  consult  relevant  regional Member  States, other  relevant directly  connected  Member  States  and  the ECG on  draft versions of  their  national plans  to ensure  consistency.  The 

Commission provided for a platform to exchange and consult draft Plans, moreover, a dedicated 3-day meeting of the ECG was convened to present and discuss each plan.  
A number of draft plans were not exchanged by the end of the deadline, but the Commission took swift enforcement actions to ensure all plans would be available ahead of the ECG expert meeting.  

▪ 
▪  While the ECG and MS can make comments following the consultation, only one Member State (Sweden) officially provided comments to its neighbours.  
▪ 
▪ 

All the plans are now available on Europa website, making it much more transparent than it used to be (in the old electricity SoS directive, plans were not even notified).  
ECG acted as monitoring and cooperation platform, that was enhanced by the Regulation. 

▪  Gas SoS:  

▪  Member States have to consult their national plans within the regional risk groups and had to jointly develop a Common Risk Assessment for  which they share relevant national data. National risk 

▪ 

▪ 

assessments do not have to be consulted with neighbouring Member States.  
According to MSs’ updated PAPs of 2023, 23 out of 26 plans were consulted with (domestic) stakeholders and 13 out of 24 (not  relevant for MT and IE) were consulted with neighbouring Member 
States and the Commission, according to MSs’ PAPs. All plans are available to stakeholders and neighbouring Member States, given that they are required to be published on the Europa webpage by the 
Regulation. 
GCG is adaptable and flexible. Best practice measures were exchanged in particular during the crisis and next steps for EU-wide measures to enhance preparedness during the energy crisis were discussed, 
which played a key role in informing the Commission in order to propose new legislative proposals. 

• 
▪ 

EQ2.4 
Electricity SoS: 

▪ 

▪ 

On regional cooperation, RCCs perform several SoS-related tasks. ENTSO-E has to identify the regional crisis scenarios in close cooperation with RCCs. In the first RPPs cycle their involvement was 
very limited due to their recent set up (5 July 2020). The  revised methodology explicitly defines RCCs’ role. RCCs have been fully involved in the second assessment. Nevertheless, the  Regulation 
establishes that ENTSO-E may delegate the identification of regional electricity crisis scenarios to the RCCs.  
Some regions have a very high level of cooperation (e.g., PENTA), but it is very unequal across regions. On EU-wide cooperation, ECG has proved to be a very useful platform for monitoring and 
cooperation.  

EN 

116 

EN 

 
 
▪  Gas SoS: Regional cooperation process was established via the 13 regional risk groups, albeit with varying degrees of activity. Overall, regional cooperation through the regional risk groups was not 
always satisfactory. In addition, 2 risk groups were not active (Mediterranean) or did not have a coordinator (North-Eastern). This means that the policy objective of ensuring adequate levels of regional 
cooperation has not been completely achieved. 

▪ 

▪ 

In 2022/2023 Commission’s Joint Research Centre had to step in to provide modelling support to 7 out of 13 risk groups (Caspian, Ukraine, Libya, Belarus, Baltic Sea, Denmark and Trans Balkan) 
because of which the remaining risk assessments could be delivered. The current regional approach to the risk groups is no longer fit for purpose, given the changed geopolitical landscape, the risen 
prominence of LNG in the EU’s supply mix and the reduced role of some of the pipeline supply corridors. Less infrastructure bottlenecks exist than in the past, reducing in most cases the regional effects. 
A delegated act is therefore in preparation for the update of the risk groups.   
However, a regional spin-off of the GCG was created specifically to discuss the end of transit through Ukraine specifically for the CEE region, which  proved effective to exchange on the possible 
consequences of the end of transit, which left the region well-prepared for this development. EU wide cooperation on the other hand is effective and active. In particular, the GCG is adaptable and 
flexible and can guarantee all voices are heard when members engage equally. The GCG proved a useful platform to coordinate during the crisis, but also to exchange information and best practices. 
This cooperation includes Member States, stakeholders and the Energy Community, with chairmanship of the Commission. 

• 

EQ2.5  
▪ 

Electricity SoS:  

▪ 

▪ 
▪ 

▪ 

▪ 

Definition of electricity crisis quite diverse between MS. As part of the RPPs exercise, the Commission requested additional information on this definition in 16 cases.c4 Early warnings declared (Cyprus 
in May 2020, Greece in August 2021, France in December 2021, Ireland in October 2022). No electricity crisis declared. cIt should be noted that it may be politically difficult for Member States to 
actually declare an electricity crisis. 
All the RPPs lacked information about the technical, legal and financial arrangements for the implementation of the regional or bilateral measures before assistance is offered. 
Assistance can be provided only if an electricity crisis is declared, which remains very difficult politically (never happened). Also, according to Article 15(2), assistance should be offered only with the 
purpose of “protecting public safety and personal security”, which is very restrictive. This may hamper the operationality of the provision.  
There have been some complaints about mandatory ‘financial agreements’ as some MSs would have preferred to have non-financial agreements. An approach based on “economic” agreements could 
offer more flexibility.  
Article 15 of the Regulation limits assistance to the delivery of electricity, leaving out the delivery of equipment or technical staff. 

▪  Gas SoS:  

▪ 

▪ 

13 Early Warnings, 2 Alerts and 1 emergency declared since 2017. Majority of crisis levels were declared during the energy crisis in 2022. The emergency was declared by IT in 2017 due to the 
Baumgarten explosion. 
Unclarity on the criteria and coordination of de-activating national crisis levels, as well as unclarity of transitioning from market to non-market-based measures 

• 

During the energy crisis and during the ‘dry run’ of 2022, it was considered by participants that the EU emergency level is insufficiently defined, in particular the difference between EU and regional emergency 
and the role of the Commission in an emergency. During the dry run, participants indicated that an EU-wide emergency would be more effective, as it would include those Member States that may still be in a 
position to help those in need. However, Member States indicated that the declaration of an EU emergency would not necessarily result in the declaration of a national emergency level, which in some Member 
States would allow for introducing non-market measures. The EU emergency level was confirmed by the dry-run 2024, where the solidarity extended to non-directly connected MS, including with LNG, was tested. 
The role of the Commission in an EU emergency is ambiguous beyond its coordinating tasks. This contrasts with the role of the Commission in the recently expired EU alert, where the role of the Commission in 
monitoring, coordinating and enforcing demand reduction is clearer. This related to the lack of EU emergency plan in contrast to national emergency plans. The expired EU alert was considered a useful provision 
for the longer term by respondents to the questionnaire, as were the additional safeguards for cross-border flows. In case a Member State receives two solidarity requests, the procedure was considered unclear. If 
the market does not allow to satisfy both requests, there are several options: using a pro-rata allocation, based on the order of reception of the requests (first-served) or depending on the amount received as 
compensation (lowest cost). Several Member States foresaw complications with the changed solidarity request submission time to at least 72 hours before indicated delivery time. Participants expressed the wish 
that a 24-hour period would be applicable for solidarity through pipelines. 

Evaluation questions 
•  EQ3  –  Have  the  regulatory 
interventions  been  effective  in 

Sub-questions 

Judgement criteria 

• 

EQ3.1  –  To  what  extent 
did  the  Electricity  Risk 

Indicators and information requirements 
Quantitative indicators 

Data sources 

Desk research: 

• 

PAPs/EPs/RPPs 

EN 

117 

EN 

 
 
 
 
addressing the energy crisis in the 
EU in 2022/2023?  

crisis 

Preparedness  and  the  Gas 
SoS  Regulations  help  to 
prepare  the  EU  for  the 
energy 
of 
2022/2023? 
EQ3.2  –  To  what  extent 
did  the  crisis  measures 
help  mitigate  the  energy 
crisis in 2022/2023? 
the 
-  Were 
EQ3.3 
cooperation 
emergency 
provisions  adequate 
to 
respond to possible supply 
shocks?  

• 

• 

•  Sufficiency  of 

the 
evaluated framework 
to  offer  adequate 
preparedness  in  case 
of  protracted  supply 
crises (EQ3.1). 

•  Effective  restoration 
of storage filling and 
supply-demand 
balance  to  mitigate 
the imminent risks of 
gas 
shortages 
(EQ3.2). 

•  Operationalisation of 
and 
solidarity 
effectiveness 
of 
crisis  cooperation  in 
case of an emergency 
(EQ3.3). 

•  Degree 

to  which 
there  has  been  a 
united  response  of 
the  EU 
to  supply 
crises (EQ3, EQ3.2) 

• 

EQ3.1 
o 

Electricity SoS: 

EN 

• 

• 
• 

• 
• 
• 
• 

Storage filling - percentage of capacity & percentage of protected customer demand 
(EQ3.2) 
Demand reduction (EQ3.2) 
Amount of ECG, GCG, regional risk group and Crisis Management Group meetings 
(EQ3, EQ3.2) 
Amount of infringement procedures/EU pilots (all) 
Amount of solidarity agreements (.3) 
Gas supply disruption simulations – (EQ3, EQ3.1 & EQ3.2) 
Amount of times EU/MSs tested crisis management procedures and provisions in 
their plans, e.g. via TTXs (EQ3.1, EQ3.2, EQ3.3). 

• 

• 

• 

• 

and 
risk 

Common 
national 
assessments 
Commission 
opinions  on  the 
Plans (all) 
GCG 
meetings 
Reports 
reviewing 
Regulations, 
ACER 
JRC studies. 

/  ECG 

reports, 

the 

Qualitative indicators 
• 
• 

Extent to which the Commission’s opinions were followed by MS (EQ3.1). 
Preventive and mitigative measures included in PAPs/EPs/RPPs are consistent with 
the identified risks (EQ3.1). 
Speed of adoption of EU measures to combat the energy crisis (EQ3, EQ3.2).  
National measures implemented to ensure storage filling (EQ3, EQ3.2) 
National measures implemented to ensure demand reduction (EQ3, EQ3.2). 

• 
• 
• 

118 

(e.g., 

Data sources: 

• 

• 

• 

Eurostat 
nrg_cb_gas(m)) 
ENTSO-E 
transparency 
platform 
ENTSOG 
transparency 
platform 
GIE 
transparency 
platform 
Other sources: 

• 

AGSI 

• 

• 

• 

• 

and 

ENTSOG 
simulations 
outlooks 
ENTSO-E 
simulations 
outlooks 
Dry  runs,  table-
top exercises. 
Public 
consultation 

and 

EN 

 
 
 
 
▪ 
▪ 
▪ 

ECG proved very useful to ensure regular and up to date information on MS perspectives ahead of winter (supply sources, stocks, outages, alternative measures, etc) and coordination on measures. 
RPPs’ Scenarios proved to be too shallow, in particular with regard to gas crisis spillover risk: some MS had to do ad hoc assessments in the midst of the crisis.  
The nuclear corrosion crisis demonstrated the importance of transparent information for neighbouring Member States. 

o  Gas SoS: the 2022/2023 energy crisis was largely a crisis caused by a geopolitical factor, namely Russian supply disruptions. The national risk assessments and common risk assessments did require Member States 

(where relevant) to consider geopolitical risks, ranging from commercial disputes with supplying companies, political unrest in supplying countries or total supply disruptions from third countries.  

▪ 

▪ 

In the latest update of the national risk assessments, 24 out of 25 national risk assessments considered geopolitical risks, mostly related to a Russian supply disruption. It should be noted that the timing 
of this update coincided with the energy crisis, which may explain the high number of MSs that considered a Russian supply disruption.  
This is similar to the first iteration of the national risk assessments (due 1 October 2018), as 23 out of 26 considered (geo)political risks  – majority of which were RU supply disruption or end to UA 
transit. It should be noted that the timing of the risk assessment was just before the expected expiry of the transit contract between RU and UA on 31 December 2019. While the risk was considered by 
most Member States, the likelihood of the risk occurring was not considered likely by all Member States. 

o  However, despite the risk of Russian supply disruptions being recognised in most risk assessments, the Gas SoS Regulation was not designed to mitigate protracted supply disruptions from the EU’s main 

supplier. Therefore, the regulatory framework had to be complemented with a series of emergency measures to fill storages, reduce demand and improve our solidarity mechanism. 

• 

But the regulation failed to prevent market manipulation with historically low storage levels in October 2021, which led to SoS concerns and price increase. Hence the introduction of SSOs’ certification.  

o  Available bidirectional capacities supported the redirection of flows when Russia cut supplies in 2022. 
o 
EQ3.2 
o 
o  Gas SoS:  

Electricity SoS: not relevant. 

▪ 

▪ 
▪ 

▪ 

The significant reduction in demand for natural gas (-18% between August 2022 and December 2023) has been essential to preserving the delicate gas balance in the EU. A continuous gas demand 
reduction throughout the injection season of 2023 was a primary driver of achieving record high storage filling by 1 November 2023 (99%) which together helped keep prices to lower levels and contain 
volatility. This demand reduction has also contributed significantly to sensible storage management throughout the first part of the winter season 2023/2024, still 70% full by 1 February. 
The 2024 dry run exercise confirmed that demand reduction measures play a key role in the early stage of a potential future crisis.  
Concept of default rules and LNG solidarity completed EU’s crisis management architecture. Critical gas volumes for electricity were useful but alternative ways could be explored. Limiting non-
essential consumption of protected customers and additional safeguards for cross-border flows were useful additions.  
Achieving the objectives set by storage regulation helped strengthen the security of supply in winter 2023/24, which in turn reduced the risk premium in the gas market at the end of the year. The 
certification process is well advanced for a substantial share of the storage operators and sites. While a number of certifications are still pending, there is currently no available evidence that storage 
ownership or storage operators could put the security of gas supply of the EU at immediate risk. 

• 

EQ3.3 
o 

Electricity SoS:  

▪ 

▪ 

Not really tested at EU-level, as there has not been an  electricity crisis. MSs had to describe in their RPPs the measures to implement the regional/bilateral measures to provide assistance: but the 
Commission’s assessment of the plans showed that these were largely missing. To better understand the barriers, the Commission organized technical workshops with MSs experts. Another workshop 
was organized to propose solutions based on best practices and academic literature. 
In the future it could be useful to have mandatory regular tests coordinated by ENTSO-E, to assess the validity of assistance provisions (once they will be fully implemented). Yet, RPR requires Member 
States to carry out biennial regional crisis exercises 

o  Gas SoS: the Commission organised two table-top exercises (‘dry runs’) to test the emergency provisions, one in 2022 and one in 2024.  

▪ 

The 2022 exercise showed that in particular questions remained regarding the implementation of the solidarity mechanism. due to: 

• 
• 
• 

A lack of bilateral solidarity agreements. 
Complexity of establishing fair compensation for solidarity.  
Timing of solidarity (24h for pipeline and 72 hours for LNG). 

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• 
• 

LNG solidarity could provide additional flexibility but there may be contractual issues for diverting cargoes. 
The lack of legal framework for indirectly connected Member States to provide solidarity. 

▪ 

The 2022 exercise concluded on the non-solidarity parts that: 

•  Mutual consultation of MSs on their national plans and the Commission’s monitoring thereof is crucial to avoid undue restrictions. 
• 
Quality and accessibility of data on protected customers is not sufficient to have proper transparency during an emergency. 
• 
GCG and the crisis management group might overlap. 
• 
The criteria for when to declare EU or regional emergency is not always clear, as well as the role of the Commission during an EU emergency.  

▪ 

The 2024 exercise concluded that: 

• 

• 

The solidarity provisions extending the mechanisms to indirectly connected Member States, allow access to larger and supposedly cheaper market-based solidarity when the directly connected 
neighbours are in emergency. However, the effectiveness of the mechanism would benefit from a clearer identification of procedure and from the existence of an entity responsible for collecting 
and transferring gas to another Member State. It would also benefit from clearer guidelines on monitoring all actions taken before requesting solidarity.  
LNG can play a key role in case of a solidarity request. It was acknowledged that Member States don’t have legal tools to force LNG companies to participate in the solidarity mechanism. 
However, Member States can facilitate LNG solidarity with ad hoc communication channels and outreach to relevant involved parties. The effectiveness of LNG solidarity eventually depends 
on contractual arrangements between concerned parties.  

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Efficiency 
To what extent were the Regulations cost-efficient in achieving their key objectives? 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators  and 
requirements 

information 

Data sources 

▪ 

▪ 

▪ 

•  EQ4 – Is the net financial cost of the 
implementation 
evaluated 
of 
interventions justified? 

the 

of 

estimated 

estimated 

EQ4.1  -  What  have  been 
the 
financial 
costs,  if  any,  tied  with  the 
implementation 
the 
evaluated  interventions  (if 
possible,  broken  down  by 
type of actors)? 
EQ4.2  -  What  have  been 
the 
financial 
benefits,  if  any,  tied  with 
the  implementation  of  the 
evaluated  interventions  (if 
possible,  broken  down  by 
type of actors)? 
these 
EQ4.3  –  Were 
benefits  and  costs  in  line 
with  the  projections  when 
the 
interventions  were 
adopted? 

▪  EQ4.4 

–  Was 

the 
distribution  of  costs  fair 
among actors? 

of 

the 

• Reasonableness 

net 
implementation costs, in view of the 
initial 
the 
distribution between actors and of the 
results achieved (EQ4) 

expectations, 

of 

• Cost of the 2021-2023  energy  crisis 
the 

vs  expected  cost  without 
measures (EQ4.2, EQ4.3) 

• Difference  between 

the  expected 
implementation  costs/benefits  at  the 
time  of  the  adoption,  and  the  actual 
implementation 
costs/benefits 
(EQ4.3) 
• Fairness  of 

the  distribution  of 
implementation costs between actors 
(between  Member  States,  between 
private  and  public,  big  and  small 
actors) (EQ4.4) 

Quantitative indicators 

• Investments  realized  to  make  cross-
bi-

interconnections 

border 
directional (EQ4). 

• Estimated 

costs 

(in 
financial 
particular  human  resources)  needed 
for  the  drafting,  the  assessment  and 
the  update  of  the  various  plans  and 
risk assessments (EQ4). 

• Estimated costs (in particular human 
resources)  for  ACER,  ENTSO-E, 
ENTSOG and RCCs to perform their 
regulated tasks (EQ4) 

• Estimated  costs  associated  with 

storage filling obligations (EQ4) 

• Estimated  costs  associated  with  gas 
demand reduction measures (EQ4) 
• Estimated costs for gas undertakings 
to meet the supply standard (EQ4) 

• 
• 
• 
• 
• 

• 

• 
• 
• 

• 
• 
• 

• 
• 

Desk Research 
Old impact assessments 
Public consultation 
Call for evidence 
Commission Reports reviewing 
the Regulations 
Commission’s evaluation of the 
Governance Regulation 
ACER reports (storage) 
GCG / ECG 
Exchanges  with  MS  and  other 
key stakeholders 
CEF applications 
Blackout simulator 
Nordic and Baltic region annual 
outage reporting system 
Power blackouts in Europe 
Feedback  from  MSs  and  key 
actors on administrative costs 

Answers: 
• 

EQ4: Security of supply is by definition is an insurance. This implies that there are always costs involved while the benefits are hopefully never truly quantifiable, since that would mean that there is an actual supply 
disruption.  

• 

EQ4.1 
o 

Electricity SoS: 

▪  ACER: Human resources for the approval of the methodologies for the identification of regional crisis scenarios and for the short-term and seasonal adequacy assessments; for the monitoring of SoS 

measures; 

▪  Commission: Human resources for providing ECG secretariat and for the organization of ECG meetings; for the drafting of Commission’s opinions on RPPs; for the drafting of the report on the 

implementation of the Regulation. 

▪  ENTSO-E: Human resources for the drafting of the methodologies for the identification of regional crisis scenarios and for the short-term and seasonal adequacy assessments; for the drafting of the 

regional crisis scenarios reports; for the drafting of the seasonal adequacy outlooks; 

▪  MSs: Human resources for the drafting of RPPs; for the negotiations on regional and bilateral measures to provide assistance; for the organization of emergency tests. 

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▪  RCCs: for the drafting of the short-term adequacy outlooks; 

o  Gas SoS: 

▪  ACER: Human resources for the drafting of opinions on reverse flows exemptions 
▪  Commission: Human resources needed for the drafting of opinions on PAPs and EPs; for the drafting of the opinions on the SSOs certification decisions; the support provided for the drafting of CRAs; 
the drafting of the reports on the implementation of Gas SoS regulation and on the emergency regulations; the monitoring of SoS measures; for providing GCG secretariat and organizing GCG meetings. 

▪  ENTSOG: Human resources needed for the drafting EU-wide SoS simulation reports; 
▪  Gas  undertakings:  Financial  cost  of  meeting  the  supply  standard  and  the  storage  obligations;  of  developing  new  infrastructure  to  meet  N-1  and  reverse  flow  requirements  and  of  keeping  non-

commercially viable infrastructure operating (only for TSOs) 

▪  MSs: Human resources for the drafting of coordinated decisions to grant exemptions to the reverse flow requirements; for the certification of SSOs; for the drafting of national risk assessments and 

common risk assessments; for the drafting of PAPs and EPs; for the negotiation of solidarity agreements; 

EQ4.2 
o 

o 

EQ4.3 
o 

The benefits are not truly quantifiable, as the regulations are designed with the hope that they will never be used. Also, it is not possible to assess the potential costs of crises that were avoided, and how much the 
framework contributed to avoid those crises. 
Thus, the assessment of the benefits requires to use proxies (e.g., past crises), but only in a qualitative way. 

There were no projections of costs and benefits at the time of the adoption (in the respective impact assessments). 

EQ4.4 
o 
o  Among energy undertakings, the costs are mainly born by TSOs. 

The costs linked to the implementation of the regulation are mainly administrative, tied with reporting obligations. They are mainly born by Member States’ administrations. 

• 

• 

• 

Evaluation questions 

Sub-questions 

Judgement criteria 

the 
EQ5  –  To  what  extent  have 
Regulations  contributed  to  streamlined 
planning, 
and  monitoring 
including  through  further  digitalisation  or 
consolidation? 

reporting 

▪ 

▪ 

to 

avoid 

EQ5.1 – To what extent are 
the  timing  and  periodicity 
of  the  different  planning 
and  reporting  obligations, 
both within the Regulations 
consistent 
and  outside, 
(e.g., 
peak 
reporting  periods,  deliver 
up-to-date information)? 
EQ5.2  –  Is  there  evidence 
of  unnecessary  procedural 
and  administrative  burden 
due  to  overlaps  with  other 
EU  or  national  planning 
and reporting procedures?  

▪ 

▪ 

▪ 

Consistency  of  the  planning 
reporting  obligations 
and 
the 
stemming 
from 
interventions 
among 
themselves as well as with the 
obligations  stemming  from 
other  EU  interventions  (e.g., 
Governance 
Regulation) 
(EQ5.1, EQ5.2). 
Identified 
caused 
redundant 
(EQ5.2) 
Helpfulness  of  the  common 
templates  for  the  plans  and 
the risk assessments provided 

inefficiencies 
obsolete 
or 
requirements 

by 

Indicators 
requirements 

and 

Quantitative indicators 

information 

Data sources 

• Amount of overlapping planning and 
reporting  obligations,  under  EU 
legislation (EQ5.1, EQ5.2) 

• Amount  of  digital  tools  used  by 
Member  States  and  Commission  to 
draft  and  evaluate  the  plans  and  the 
risk  assessments,  compared  to  the 
amount  of  digital  tools  that  are 
available for this kind of tasks, as of 
today (EQ5.4) 

Qualitative indicators 

• Percentage  of  MS  compliant  with 

reporting obligations (EQ5) 

• 
• 
• 
• 
• 

• 

• 
• 
• 

Desk Research 
Old impact assessments 
Public consultation 
Call for evidence 
Commission Reports reviewing 
the Regulations 
Commission’s evaluation of the 
Governance Regulation 
ACER reports (storage) 
GCG / ECG 
Feedback  from  MSs  and  key 
actors on administrative costs 

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• Indicative  schedule  of  the  various 
reporting  obligations  for  Member 
States,  during  the  implementation 
period (EQ5.1, EQ5.2) 

• Typology  of  digital  tools  used  by 
Member  States  and  Commission  to 
draft  and  evaluate  the  plans  and  the 
risk  assessments,  compared  to  the 
typology  of  digital  tools  that  are 
available for this kind of tasks, as of 
today (EQ5.4) 

regulations 
States 

for 
the 
by 
Member 
when 
performing their planning and 
reporting obligations, and for 
the 
when 
Commission 
evaluating  those  documents 
(EQ5.3). 
Extent 
to  which  Member 
States  and  the  Commission 
use available digital tools in a 
the 
way 
administrative burden, for the 
design and for the assessment 
of  the  plans  and  of  the  risk 
assessments (EQ5.4). 

reduces 

that 

▪ 

▪ 

▪ 

– 

Regarding 
EQ5.3 
progress reporting, to what 
extent does the availability 
of  common  templates  (for 
EPs, 
RPPs, 
PAPs, 
Risk 
Common 
Assessments, 
National 
Risk 
Assessments) 
decrease the administrative 
of 
burden 
and/or 
Member  States 
make 
the 
Commission 
to  evaluate 
and use the information and 
data provided? 

it  easier  for 

costs 

and 

States' 

▪  EQ5.4  –  Are  the  current 
and 
Member 
Commission's 
planning 
and  reporting  obligations 
designed in such a way that 
they  make  efficient  use  of 
developments  in  the  fields 
of digital technologies? 

Answers 
• 

EQ5.1  

o  DDLs gas SoS and electricity RP: 

ENTSOG - Union-wide SoS simulation: 1 November 2017 (and every four years thereafter – unless more frequent updates are warranted) 

▪ 
▪  MSs - National risk assessment & common risk assessment: 1 October 2018 (and every four years thereafter – unless more frequent updates are warranted) 
▪  MSs - PAP & EP: 1 March 2019 (and every four years thereafter – unless more frequent updates are warranted) 
▪ 
COM - Commission assessment and opinion: 1 July 2019 (assessment within 4 months after the PAP/EP). 
▪  MSs - Updated PAPs/EPs taking account of Commission’s recommendation: 1 October 2019 (3 months after the receipt of the Commission’s opinion). 
▪ 
▪ 
▪ 
▪  MSs - national electricity crisis scenarios: 5 November 2020 (and every four years thereafter – unless more frequent updates are warranted) 
▪  MSs - draft RPPs: 5 April 2021 (implicit deadline, as the Regulation foresees a minimum 9-month consultation period for other MSs). 
▪  MSs - risk-preparedness plans: 5 January 2022 (and every four years thereafter – unless more frequent updates are warranted). 
▪ 
▪  MSs - Updated RPPs taking account of Commission’s recommendation: 3 months after the receipt of the Commission’s opinion. 

ENTSO-E – methodology for regional electricity crisis scenarios & methodology seasonal/short-term adequacy: 5 January 2020 
ENTSO-E – regional electricity crisis scenarios 5 July 2020 (and every four years thereafter – unless more frequent updates are warranted) 
ENTSO-E – seasonal adequacy outlooks assessments: every 1 December and 1 June. 

COM - Opinions on RPPs: 4 months after the submission of the final RPPs. 

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COM - opinion on draft NECPs: 30 December 2023. 

▪  MSs - draft NECPs: 30 June 2023. 
▪ 
▪  MSs - draft certifications for gas SSOs: 2 January 2024. 
▪ 
▪  MSs - final NECPs: 30 June 2024. 
▪ 

TSOs/MS/NRAs/ACER/EC: gas reverse flows exemptions every 4 years. 

COM - opinions on the draft certifications for gas SSOs: 25 working days after the submission. 

o 

o 

o 

o 

The deadlines stemming from the Gas SoS Regulation and Risk Preparedness Regulation lead to a logical sequence in deliverables (first simulations, assessments and risk assessments, based on which plans 
are developed). The deadlines largely do not overlap, unless this is necessary to ensure consistency between the deliverables (e.g. national and common risk assessments being delivered at the same time). 
The lack of timely submissions of these deliverables by Member States may indicate that these deadlines are too short, especially given the size of the reporting obligations. This is particularly relevant for the 
certification of storage system operators, where in some instances the deadlines are notably short ( 
There is no distinct overlap in timing of reporting requirements between the Gas SoS Regulation and electricity Risk-Preparedness Regulation. However, the updates of the PAPs/EPs come shortly before the 
draft NECPs have to be issued. Both the Plans and the NECPs, even if the topics are different, are extensive reporting requirements for MSs and while the required deliverables are not exactly the same, there 
may be room for simplification. 
The Gas Demand Reduction Regulation required Member States to issue a one-off update of its emergency plan to reflect voluntary demand-reduction measures by 31 October 2022, which should have been 
repeated in case a Union alert would have been declared (quid non). This update was shortly before the regular 4-year update of the plans by 1 March 2023, which led to duplication and therefore unnecessary 
administrative burden. 

• 

EQ5.2  

o 

Electricity SoS: 

▪  Member States have to submit 3 versions of their plans (1: draft; 2: final; 3: updated following Commission’s recommendation) – the process could probably be lightened. 

o  Gas SoS: the fact that two separate plans (PAP and EP) and two separate types of risk assessments (national and common risk assessments) have to be developed, leads to high administrative burden among 

o 

Competent Authorities. Whether the number of deliverables that require not only time and resources to elaborate, but also to require lengthy internal validation, can be reduced could be explored. 
The number of risk groups (12), corresponding to each supply disruption scenario leads to some duplication. The risk assessment of the Belarus risk group has even been merged with the North-Eastern risk 
group due to a lack of coordinator. 

o  Gas SoS report: Leading the risk groups and developing the Common Risk Assessment was considered a large administrative burden by Member States, especially in times of crises with competing priorities. 

Some MSs argue for reducing the number of regional risk groups. 

• 

EQ5.3  

o  Cross-sectoral: 

▪ 

▪ 

Overall, the use of templates makes it easier for Member States to understand exactly what is required and in which section. However, the templates are extensive and in some cases there is an overlap 
in the requirements included in the templates, between the various deliverables. 
For example, the infrastructure standard calculation has to be provided in the PAP, while it has already been calculated in the common and national risk assessments as well. This is also the case for the 
description of the regional gas systems. While it is important that Member States take both elements into account both when drafting the risk assessments and the plans, it is a duplication of efforts.  

• 

EQ5.4  

EN 

o  Cross-sectoral: while some digital technologies are used for reporting obligations (e.g. CIRCABC, EUSurvey), their use could be further leveraged. Certain data requirements that are currently in the national 
risk assessments and PAPs could be reported on through less burdensome ways (e.g. by filling in an online template). This may include the factual data requirements, such as protected customers demand, gas 
consumption figures, domestic production, gas import sources per country of origin. This may alleviate the burden of lengthy internal approval processes in Member States. E-reporting platform managed by 
DG ENER could be a source of inspiration. Some reporting (flows, demand, storage levels) is undertaken by ENTSO-E, ENTSOG and GIE via their transparency platforms. This reporting could be further 
enhanced since data reporting from MS generally comes from electricity and gas TSOs. 

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RELEVANCE 
How have the scope and objectives of the regulations remained relevant in addressing the past and current problems across the implementation period from 2017 and 2019 
until now? 

Evaluation questions 

Sub-questions 

Judgement criteria 

action 

(preventive 

EQ6  -  To  what  extent  are  the  various 
plans 
plans, 
emergency  plans, 
risk  preparedness 
plans) relevant in addressing actual risks 
and preventing, preparing, managing and 
mitigating  actual  energy  supply  crises? 
What could be improved?  

• 

N/a 

•  Timeliness  and  responsiveness  of 
provisions to crisis events (COVID-
19, energy crisis)  and  the  ability of 
these  measures 
to  mitigate 
disruptions in energy supply (EQ6). 

Data sources 

• 
• 

• 

• 
• 

research:  assessment  of 
risk 
requirements, 

Strategic foresight workshop 
Desk 
regulatory 
assessments and plans. 
GIE  AGSI  transparency  platform 
(storage) 
Eurostat (e.g. nrg_cb_gasm) 
Commission’s 2040 climate target 
plan (and its impact assessment). 

information 

Indicators  and 
requirements 
•  Quantitative indicators 
•  Frequency, duration and volumes of 
supply disruptions during crises and 
extreme  weather  events  (storms, 
heatwaves,  cold  snaps,  droughts, 
etc.) (EQ6) 

•  Supply-demand  balance  in  2021-

2024 (EQ6). 

•  Storage filling in 2021-2024 (EQ6). 
•  Demand  reduction 
in  2021-2024 

(EQ6). 

• 
•  Qualitative indicators 
•  Degree  to  which  the  type  of  crisis 
events  that  actually  occurred  since 
2017  had  been  identified  as  risk  in 
risk assessments (EQ6) 

•  Areas  that  current  energy  security 
standards (infrastructure standard, supply 
standard) do not address (EQ6). 

Answer: 

• 

EQ6  

o  Gas SoS: 

▪ 

▪ 

▪ 

The Commission opinions recognised the overall quality and completeness of the Member States’ plans, and relevant risks that actually materialised, such as a full Russian supply disruption were 
actually assessed in the risk assessments. The risk of a full Russian supply disruption has in fact been assessed in 24 out of 25 national risk assessments, while in the latest CRAs, a series of risks were 
identified often taking a full Russian supply disruption as the baseline scenario. 
As indicated in the Commission opinions, both in the plans of 2019 and 2023, the preventive measures described in the PAP are often not tied to the risks identified in the risk assessments. There is a 
logical sequence in deliverables, with first providing risk assessments and then producing the plans. While it is a requirement of the Regulation, in practice this has not sufficiently been applied by 
Member States, which has a negative effect on the relevance of the risk assessments.  
A breakdown of gas import sources per country of origin is already required by Annex VI. However, this may not reflect an accurate picture, in case a Member State is undertaking efforts to diversify 
away from a certain supplier, or if certain long-term contracts are expiring. Therefore, a description or projections of ongoing diversification efforts may be needed. 

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▪ 

▪ 

If a Member State knows that in the period before the next update of the PAP natural gas will be phased out, and it knows this may affect the composition of the breakdown of gas demand (e.g. certain 
sectors may phase out gas quicker than others), no quantitative estimate of this development is currently provided. This may also include the impact of ongoing electrification efforts and the role that 
gas would play in the adequacy of the electricity system. 
Apart from the role that domestic production, including biomethane, plays in the national gas system, there is no requirement on whether national hydrogen strategies should be included in the plans. 
This is of particular importance if it impacts security of gas supply or the replacement of gas demand in specific sectors. 

o 

Electricity SoS: the Commission’s assessment based on the opinions is that the RPPs are shallow in this department. While the RPPs have had a role in preventing, preparing for, managing and mitigating crises, 
when a crisis hit more had to be done. This may not be a shortcoming of the Regulation even given that it was explicitly envisaged in the Regulation though left at MS discretion.  

Evaluation questions 

Sub-questions 

Judgement criteria 

of 

•  Appropriateness 

plans 

in 
responding  to  and  preventing  real 
crises.  Flexibility of  plans to  adjust 
to emerging risks (EQ7). 

EQ7 - How well adapted are the evaluated 
regulations  to  technologic  or  scientific 
progress, 
the 
environmental/climatic challenges the EU 
will face? 

and 

to 

EQ7 – To what extent and how each of 
the 14 Megatrends246 identified by the 
Commission’s  JRC  may  impact  the 
evaluated regulatory framework in the 
future? 

•  Incorporation  of 

the 

impact  of 
expected  decline  of  natural  gas 
in 
and 
consumption 
biomethane  consumption 
the 
various  risk  assessments  and  plans 
(EQ7)  

increase 
in 

•  Degree  to  which  financial  risks  are 
included  in  risk  assessments  and 
plans (EQ7). 

•  Fitness of the current energy security 
framework  for  long-term  driving 
forces that may have a global impact 
in the future (EQ7). 

Data sources 

• 
• 

• 

• 
• 

• 

research:  assessment  of 
risk 
requirements, 

Strategic foresight workshop 
Desk 
regulatory 
assessments and plans. 
GIE  AGSI  transparency  platform 
(storage) 
Eurostat (e.g. nrg_cb_gasm) 
Commission’s 2040 climate target 
plan (and its impact assessment). 
Commission  study  on  energy 
storage’s contribution to electricity 
SoS 

information 

and 

Indicators 
requirements 
•  Quantitative indicators 
•  Amount  of  cross-sectoral 

risks 
identified in risk assessments (EQ7). 
•  Amount of emerging risks identified 

in risk assessments (EQ7).  

•  Qualitative indicators 
•  Degree  to  which  the  type  of  crisis 
events  that  actually  occurred  since 
2017  had  been  identified  as  risk  in 
risk assessments (EQ7) 

•  Areas  that  current  energy  security 
standards  (infrastructure  standard, 
supply  standard)  do  not  address 
(EQ7). 

•  Degree  to  which  realistic  cross-
sectoral  risks  are  identified  in  risk 
assessments  and  addressed  via 
measures in the plans (EQ7).   

•  Degree  to  which  emerging  risks  are 
identified  in  risk  assessments  and 
addressed via  measures  in  the plans 
(EQ7)  

• 

• 

EQ7  

o  Gas SoS: 

246  https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en 

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▪ 

▪ 

▪ 

▪ 

Natural disasters or environmental threats were considered in 13 out of 25 national risk assessments. Most common risks include floods or extreme weather conditions such as storms affecting e.g. LNG 
shipments either in the producing country or at the regasification terminal in the EU. However, the risk of climate change aggravating these risks was only briefly mentioned by 1 national risk assessment 
and was otherwise not taken into account.   
Given that household gas demand may in some Member States be phased out sooner than in other sectors, a reconsideration of the protected customers definition may in the future be required. This way, 
an adjustment can be made to a changing demand profile, while ensuring that residential needs are met, in particular as regards the gas consumption of vulnerable consumers. 
The  expected phase out  of natural gas  may  lead to a deteriorating  business  case  for certain companies operating  in the gas  sector.  This  could  result  in  financial  risks throughout  the  transition  for 
undertakings that are critical to security of gas supply.   
Infrastructure standard and gas storage targets need to be balanced with the need to avoid creating stranded assets and avoiding carbon lock-in to support decarbonisation objectives. Infrastructure 
standard incentivises development of fossil infrastructure, which is necessary for security of supply and system flexibility, but in the future may require adaptation. 

o 

Electricity SoS: 

▪ 
▪ 

Decarbonisation will be achieved mainly through electrification, thus power consumption patterns will change a lot, which may require some adaptation of the architecture.  
Similarly, the current architecture does not fully factor in climate change adaptation, and the European Commission recommended in its RPPs opinions to include climate change considerations, such as 
climate  vulnerability  and  risks.  And  an  estimation  of  GHG  emissions  in  cases  some  emergency  measures  appeared  to  have  a  potential  input.  These  were  however  recommendations  made  by  the 
Commission and not related to obligations in the Regulation.  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 
requirements 

and 

information 

Data sources 

EQ8  -  Are  the  Member  States’  and 
Commission’s  planning,  reporting  and 
under 
monitoring 
the 
obligations 
in  view  of 
Regulation  still  relevant 
legislative developments? 

EQ8.1  -  Are  there  planning, 
monitoring 
reporting 
and 
the 
obligations  missing  from 
evaluated Regulations in view of 
recent legislative developments? 
EQ8.2  -  Are  there  planning, 
reporting 
monitoring 
and 
obligations  under  the  evaluated 
Regulations  that  have  become 
obsolete,  e.g.  because  digital 
solutions  make  the  reporting  by 
MS no longer necessary? 

• 

• 

• 

•  Incorporation  of 

the 

impact  of 
expected  decline  of  natural  gas 
in 
and 
consumption 
biomethane  consumption 
the 
various  risk  assessments  and  plans 
(EQ8.1,)  

increase 
in 

•  Degree  to  which  financial  risks  are 
included  in  risk  assessments  and 
plans (EQ8.1). 

•  Assessment of redundant or outdated 
monitoring 
and/or 

reporting 
obligations. (EQ8, EQ8.2).  

to 

•  Assessment  of  missing  reporting 
and/or monitoring obligations (EQ8, 
EQ8.1). 
•  Adaptation 

and 
complex  risks  (e.g.  cybersecurity, 
hybrid threats) and the flexibility of 
the  Regulations 
incorporate 
emerging  risks  such  as  climate 
change (EQ8) 

emerging 

to 

•  Quantitative indicators 
•  Amount  of  cross-sectoral 

risks 
identified in risk assessments (EQ8). 
•  Amount of emerging risks identified 

in risk assessments (EQ8).  

•  Qualitative indicators 
•  Degree  to  which  realistic  cross-
sectoral  and  emerging  risks  are 
addressed  via  regulatory  provisions 
(EQ8). 

•  Degree  to  which  supply  standard 
integrates  a  changing  climate  reality 
(EQ8). 

• 
• 

• 

• 
• 

• 

research: 

requirements, 

assessment  of 
risk 

Strategic foresight workshop 
Desk 
regulatory 
assessments and plans. 
GIE  AGSI  transparency  platform 
(storage) 
Eurostat (e.g. nrg_cb_gasm) 
Commission’s  2040  climate  target 
plan (and its impact assessment). 
Commission 
energy 
storage’s  contribution  to  electricity 
SoS 

study  on 

EN 

127 

EN 

 
 
 
 
• 

EQ8 
o 

EQ8.1 
▪ 

Electricity SoS: on the RPPs opinions, the Commission’s asked several times MSs to quantify impacts on climate change of the envisaged measures (e.g., estimated GHG emissions) and to strengthen 
security dimension. 

▪  Gas SoS: financial risks (e.g. bankruptcies) of critical gas undertakings are not considered, which may become more relevant if the expected phase out of natural gas leads to a less solid business case 

for these undertakings. This could impact electricity as well, if it affects gas-fired power plants. 

o 

EQ8.2  
▪ 

Electricity SoS: 

• 

Reporting of plans has been digitalised because of the use of CIRCABC.  

▪  Gas SoS: the fact that two separate plans (PAP and EP) and two separate types of risk assessments (national and common risk assessments) have to be developed, leads to high administrative burden 

among Competent Authorities.  

▪  Gas SoS: There is room for simplification between the national risk assessments and the plans. Both the risk assessments and the PAP require a description of the regional gas system of each risk 
group the Member State participates in. Same goes for the compliance with the infrastructure standard, which is both required in the national risk assessments and the PAPs. The risk assessments again 
have to be summarised in the PAPs. 

▪  Gas SoS: crisis levels and corresponding measures have to be developed in the EP on national level and then have to be repeated at regional level (despite the fact that some of these regional crisis 

levels don’t exist). The regional dimension of this obligation is not clear and could be simplified.  

Evaluation questions 

Sub-questions 

Judgement criteria 

EQ9  -  To  what  extent  is  the  current 
framework relevant in addressing 
cross-sectoral  or  cascading  risks 
between  the  gas  and  electricity 
sectors? 

N/a 

• 

EQ9 

EN 

•  Effectiveness 

in 

addressing 
interdependencies  between  gas  and 
electricity.  Relevance  to  real-world 
cross-sectoral  disruptions,  such  as 
gas  shortages  impacting  electricity 
generation (EQ9). 

information 

and 

Indicators 
requirements 
•  Quantitative indicators 
•  Timing  and  amount  of  updates 
required  under  current  Regulations 
(EQ9, EQ9.2). 

•  Percentage  of  MS  compliant  with 
reporting obligations (EQ9, EQ9.2) 

• 
•  Qualitative indicators 
•  Duplications  and 

in 
reporting and monitoring obligations 
(EQ9, EQ9.2). 

redundancy 

•  Missing information requirements in 
plans  and  risk  assessments  (EQ9, 
EQ9.1). 

•  Degree  to  which  the  type  of  crisis 
events  that  actually  occurred  since 
2017  had  been  identified  as  risk  in 
risk assessments (EQ9.1) 

Data sources 

• 
• 

• 

• 
• 

• 

research:  assessment  of 
risk 
requirements, 

Strategic foresight workshop 
Desk 
regulatory 
assessments and plans. 
GIE  AGSI  transparency  platform 
(storage) 
Eurostat (e.g. nrg_cb_gasm) 
Commission’s 2040 climate target 
plan (and its impact assessment). 
Commission  study  on  energy 
storage’s contribution to electricity 
SoS 

128 

EN 

 
 
 
 
 
o  Gas SoS: MSs are required (if relevant) to assess the risk of a lack of electricity or other energy source as a risk for gas security of supply. Critical gas-fired power plants also have to be identified, along with the 

potential volumes needed for these power plants.  

▪ 

▪ 

A total of 18/25 national risk assessments consider such ‘cross-sectoral risks’ but most MSs only considered short-term failures and therefore did not consider it impactful. One MSs considered the 
risk of a gas shortage for electricity security of supply, although that risk was not considered impactful.  
As part of PAPs, the critical gas-fired power plants are to be clearly identified, along with their necessary volumes. However, as indicated in the Commission’s opinions, these power plants have often 
not been identified by Member States. In addition, the plans often do not adequately consider the impact of a gas supply disruption on electricity generation, or district heating, which is a requirement 
of the Regulation. This is likely due to the fact that this is a requirement stemming from Article 11 (dictating the crisis levels and procedures) but is not included in the templates in the annex, nor in 
the Articles stipulating the content of the plans.  

o 

Electricity SoS: Article 5 requires ENTSO-E to identify regional electricity crisis scenarios in relation to system adequacy, system security and fuel security, and “fuel shortages” is mentioned as one of three 
risks which must be considered. 

▪ 

However, many of the Commission’s opinions on the RPPs asked MS to at least clarify why there would not be a spillover impact of a gas crisis in the electricity sector as this was neither addressed 
in the plans nor explained. The Commission opinions asked many MS specifically to add further details to this x-sector assessment as the details in their plans were very limited.  
At Commission’s request, in summer outlook 2022, ENTSO-E calculated for the first time the so-called “critical gas volumes”, which contributed to a shared understanding of the impact of gas shortages on electricity 
generation. 

Evaluation questions 

Sub-questions 

Judgement criteria 

information 

and 

Indicators 
requirements 
Quantitative indicators 
•  Amount  of  cross-sectoral 
in 

risk 

risks 
assessments 

identified 
(EQ10). 

Data sources 

EQ10  -  How  well  adapted  are  the 
current  Regulations 
tackle 
geopolitical  and  emerging  risks, 
like cybersecurity, hybrid threats, 
or critical infrastructure risks? 

to 

N/a 

•  Effectiveness 

in 

addressing 
interdependencies  between  gas  and 
electricity.  Relevance  to  real-world 
cross-sectoral  disruptions,  such  as 
gas  shortages  impacting  electricity 
generation (EQ10). 

•  Adaptation 

to 

emerging 

and 
complex  risks  (e.g.  cybersecurity, 
hybrid threats) and the flexibility of 
the  Regulations 
incorporate 
emerging  risks  such  as  climate 
change (EQ10) 

to 

• 
• 

• 

• 
• 

Qualitative indicators 
•  Degree  to  which  the  type  of  crisis 
events  that  actually  occurred  since 
2017  had  been  identified  as  risk  in 
risk assessments (EQ10) 

•  Degree  to  which  realistic  cross-
sectoral  and  emerging  risks  are 
addressed  via  regulatory  provisions 
(EQ10). 

•  Degree to which protected customers 
definition is aligned in electricity and 
gas  and  degree 
it  is 
compatible  with  changing  demand 
structure (EQ10).  

to  which 

•  Degree  to  which  realistic  cross-
sectoral  risks  are  identified  in  risk 

research: 

requirements, 

assessment  of 
risk 

Strategic foresight workshop 
Desk 
regulatory 
assessments and plans. 
GIE  AGSI  transparency  platform 
(storage) 
Eurostat (e.g. nrg_cb_gasm) 
Commission’s  2040  climate  target 
plan (and its impact assessment). 

EN 

129 

EN 

 
 
 
 
 
assessments  and  addressed  via 
measures in the plans (EQ10).   

• 

EQ10 

o  Gas SoS: Member States are required (if relevant) to take risks related to cybersecurity risks and threats to critical infrastructure  (physical but also natural disaster or environmental risks), especially if it can 

become an N-1 situation.  

▪ 

▪ 

▪ 

▪ 

The recently adopted horizontal cybersecurity legislation (NIS2, CRA) aims to address these issues. However, at this early stage of the transposition process, it is too early to assess these provisions. 
Moreover, cybersecurity risks were identified in 14 out of 25 national risk assessments, usually in the form of a cyberattack on infrastructure. However, in most cases it is unclear whether preventive 
measures are sufficient to address the risks.  
The 2024 dry run exercise showed that in case of a cyber-attack, most Transmission System Operators (TSOs) had the possibility to switch to backup systems and use alternative communications 
channels to overcome the impact. It was identified that in case of a cyber-attack on the energy system, coordination between cyber and operational experts within the TSOs must be integrated in the 
response procedures.  
Physical threats to infrastructure were identified in 12 out of 25 risk assessments, usually due to terrorist attacks or sabotage of critical infrastructure. However, usually the focus lays on the assessing 
or mitigating the impact of the resulting disruption for security of supply, rather than addressing the risk to critical infrastructure itself. The dry run of 2024 showed that in case of a crisis, some 
coordination procedures between critical infrastructure protection and energy security Competent Authorities could also benefit from further clarification.   
Diversification is not adequately covered by the Regulation.  

o 

Electricity SoS:  

▪ 
▪ 
▪ 

Electricity Risk-Preparedness does not cover diversification, similar to the Gas Security of Supply Regulation.  
The consequences of malicious attacks do need to be considered as they are a requirement of the Electricity Risk-Preparedness Regulation 
The Commission recommended to several Member States in its RPP opinions, to take better and more into account cybersecurity, critical infrastructure risks and climate change impacts in their risk 
scenarios. Overall, the architecture could better factor in these dimensions.   

Evaluation questions 

Sub-questions 

Judgement criteria 

EQ11  -  To  what  extent  can  the  current 
storage  policy  (incl.  liquid  fuels)  in 
the  EU  from  a  security  of  supply 
perspective be expected to continue to 
satisfy  critical  end-use  of  energy, 
independently  of  the  energy  vector? 
(e.g. heating when electrified) 

N/a 

•  Adaptation 

to 

emerging 

and 
complex  risks  (e.g.  cybersecurity, 
hybrid threats) and the flexibility of 
the  Regulations 
incorporate 
emerging  risks  such  as  climate 
change (EQ11) 

to 

information 

Indicators 

and 
requirements 
•  Qualitative indicators 
•  Degree  to  which  realistic  cross-
sectoral  and  emerging  risks  are 
addressed  via  regulatory  provisions 
(EQ11). 

•  Degree  to  which  supply  standard 
integrates a changing climate reality 
(EQ11). 

•  Degree  to  which  emerging  risks  are 
identified  in  risk  assessments  and 
addressed via  measures  in  the plans 
(EQ11).  

Data sources 

• 
• 

• 

• 
• 

• 

research:  assessment  of 
risk 
requirements, 

Strategic foresight workshop 
Desk 
regulatory 
assessments and plans. 
GIE  AGSI  transparency  platform 
(storage) 
Eurostat (e.g. nrg_cb_gasm) 
Commission’s 2040 climate target 
plan (and its impact assessment). 
Commission  study  on  energy 
storage’s contribution to electricity 
SoS 

EQ11 

EN 

o 

The ongoing sectoral integration and electrification of the energy system means that critical energy consumption needs are expected to increasingly change vector (from natural gas/liquid fuels to electric heating). 
Current gas storage/supply standard policy is to a large extent designed to store gas to cover these critical needs in winter.  

130 

EN 

 
 
 
 
o 

If heating demand becomes more electrified, this may change the relevance of such storage policy for gas, and it puts in question the relevance of supply standard/storage policy split per vector. In the past, the 
objective of satisfying critical demand in winter was met via gas supply/storage requirements. In a sectorally integrated energy system, the focus may need to be redirected to a cross-vector supply standard/storage 
policy that covers heating demand irrespective of the carrier. 

Evaluation questions 

Sub-questions 

Judgement criteria 

EQ12  -  To  what  extent  is  the  Gas  SoS 
framework  fit  for  the  development  of 
renewable  gases 
(biomethane,  biogas, 
hydrogen)? 

• 

• 

EQ12.1  –  To  what  extent  and 
the  ramp-up  of 
which  ways 
biomethane production in the EU 
will  affect  the  security  of  gas 
supply framework? 
EQ12.2 – To what extent and in 
which ways will the ramp-up of 
renewable 
low-carbon 
and 
hydrogen impact the EU security 
of gas and supply frameworks? 

•  Sufficiency  of  the  safeguards  of 
current  storage  policy  (electricity, 
gas  and  possibly  liquid  storage)  to 
satisfy 
future  heating  demand 
(irrespective  of  the  energy  carrier 
used 
for  heating),  considering 
ongoing  electrification  and  climate 
change (EQ12). 
•  Incorporation  of 

impact  of 
expected  decline  of  natural  gas 
in 
consumption 
and 
biomethane  consumption 
the 
various  risk  assessments  and  plans 
(EQ12.1)  

increase 
in 

the 

information 

and 

Indicators 
requirements 
•  Quantitative indicators: 
•  Expected  evolution  of  natural  gas 
demand  for  the  period  2025-2040 
(EQ12) 

•  Expected  evolution  of  domestic 
biogas  and  biomethane  production 
for the period 2025-2040 (EQ12).  
•  Expected  evolution  of  hydrogen 
consumption  for  the  period  2025-
2040 (EQ12). 

•  Qualitative indicators: 
•  Areas  that  current  energy  security 
standards  (infrastructure  standard, 
supply  standard)  do  not  address 
(EQ12). 

•  Degree to which protected customers 
definition is aligned in electricity and 
is 
gas  and  degree 
compatible  with  changing  demand 
structure (EQ12).  

to  which 

it 

Data sources 

• 
• 

• 

• 
• 

• 

research:  assessment  of 
risk 
requirements, 

Strategic foresight workshop 
Desk 
regulatory 
assessments and plans. 
GIE  AGSI  transparency  platform 
(storage) 
Eurostat (e.g. nrg_cb_gasm) 
Commission’s 2040 climate target 
plan (and its impact assessment). 
Commission  study  on  energy 
storage’s contribution to electricity 
SoS 

• 

EQ12: 
o 

EQ12.1 
▪ 

Electricity SoS: Biomethane (like other renewable gases) used for thermal generation will likely still contribute to security of electricity supply by 2050, as it can provide necessary flexibility for 
variable renewable energy sources. 

▪  Gas SoS:  

• 

• 

Through the Hydrogen and Decarbonised Gas Package the definition of ‘natural gas’ also means biomethane that can be directly injected through the natural gas system (i.e. no biogas that 
has not been upgraded to biomethane). This means that the provisions of the Gas SoS Regulation also directly apply to biomethane.  
However, the production of biomethane has different particularities compared to fossil natural gas. With an expected increase of biomethane, it will give a more prominent role to the 
distribution grid for security of supply, where biomethane is often injected into the system. This will also increase the share of off-grid usages (outside the transmission system). 

•  Degree  to  which  supply  standard 
integrates a changing climate reality 
(EQ12). 

EN 

131 

EN 

 
 
 
 
• 

The increase in the use of biomethane may lead to a strengthened energy-food nexus. This might mean that the sourcing of biomethane (i.e. agricultural particularities) may need to be 
considered in e.g. risk assessments for security of gas supply. 

o 

EQ12.2 
▪ 

Electricity SoS: 

• 

• 

It is important that the pace of deployment of electrolysers to produce green hydrogen does not result in a cannibalisation of other decarbonisation processes or in a destabilization of the 
electricity grid, by exceeding the renewable generation capacities additions. 
However, there is also a role to play for hydrogen as seasonal storage or to help stabilise the grid, as indicated in the study on the SoS contribution of energy storage.247  

▪  Gas SoS:  

• 

• 

Future import of hydrogen will create new supply routes from different third country suppliers. The lessons learned of avoiding dependencies on single third country natural gas suppliers 
should be incorporated in the future hydrogen supply structure.  
Repurposing of natural gas transmission, import or storage infrastructure will be crucial to a cost-efficient facilitation of the energy transition. However, this may have negative impacts on 
security of natural gas supply. An integrated approach is needed to ensure that the objective of repurposing infrastructure for hydrogen is balanced with the objective of ensuring security 
of gas supply.  

Evaluation questions 

Sub-questions 

Judgement criteria 

EQ  13  -  To  what  extent  is  the  Gas  SoS 
framework fit for ending EU’s dependency 
on  Russian  gas  as  laid  down  in  the 
REPowerEU and interlinked end of RU gas 
transit via Ukraine? 
EQ13 

• 

N/a 

•  Sufficiency of the provisions aimed 
at  promoting  diversification  in  the 
gas SoS Regulation (EQ13) 

information 

Data sources 

Indicators 

and 
requirements 
Quantitative indicators: 

•  HHI indicator 

Number of reporting requirements related 
to diversification in the RAs, PAPs, 
and EPs. 

•  Eurostat 
•  Commission’s opinions 
•  Public consultation 

o  Gas SoS Regulation has provisions that are directly relevant for the phase out of Russian gas supplies. However, the Regulation was designed to answer to short-term disruptions and not designed for prolonged 

supply disruptions from the EU’s main supplier, nor were its objectives to diversify away from Russian gas, which is the objective of REPowerEU adopted in 2022.  
The possibility to adopt measures fostering diversification or ending a particular contract lies primarily with Member States.  
There are very few provisions that have an indirect impact on diversification: 

o 
o 

▪ 
▪ 

▪ 
▪ 

In the risk assessments, the control or ownership of infrastructure that could hamper diversification efforts needs to be assessed.  
The template for the risk assessments stipulates that risks related to third-country suppliers have to be assessed. The risk of a full Russian supply disruption has in fact been assessed in 24 out of 25 
national risk assessments, while in the latest CRAs, a series of risks were identified often taking a full Russian supply disruption as the baseline scenario. Since the preventive measures outlined in the 
PAPs should be linked to the risk assessments, preventive measures related to a full Russian supply disruptions had to be adopted in those instances. Some preventive measures in the member states’ 
plans were therefore related to diversification, development of renewable energy and gases or fuel switching. 
National diversification measures taken have to be reported in the preventive action plan. 
In the template for the preventive action plan, a breakdown (to the extent possible) of gas import sources per country of origin have to be provided.  

247  Study on energy storage - Publications Office of the EU 

EN 

132 

EN 

 
 
 
 
 
▪ 

▪ 

▪ 

Article 14 of the Regulation gives the option to the Commission to request the supply contracts concluded with a third country supplier, under certain conditions, in order to assess whether it negatively 
impacts the security of supply situation at national, regional or Union level. This is also the case if a concluded contract would constitute the equivalent to 28 % or more of yearly gas consumption. 
Although the Regulation provides for CAs or undertakings to notify some contractual information to the Commission, more transparency regarding the origin of the gas imported would be needed to 
further support achieving REPowerEU objectives. 
In the Preventive action plan, MS have the obligation to identify the main infrastructure relevant to security of supply. This has led many MSs to identify infrastructure linked to the supply of Russian 
gas (prior to 2022). The infrastructure standard obliges MSs to maintain a minimum level of redundancy in the system in the event of a disruption of the single largest gas infrastructure, and thereby 
to diversify the routes. It therefore obliges them to identify options to diversify in case of disruption of the main infrastructure (which in a number of cases was related to Russian gas supply). the N-1 
was essential for SoS as it enabled a complete shift of flow pattern, when the main EU supplier cut its flow. 
In addition, resulting from the regional risk assessments, a Union-level assessment of the emergency supply corridors should be done, identifying emergency diversification routes for the regions. This 
work has for instance been done by the Commission and the CEE regional risk group in preparation for the end of the transit via Ukraine.  

o 

In addition, the Gas Coordination Group and a spin-off regional working group for the CEE region provided useful to discuss the end of the gas transit through Ukraine. The group met regularly to exchange 
views on the possible security of supply impact of the end of transit and proved essential in order to ensure that no security of supply incident occurred, facilitating the further phase out of Russian gas. 

o  However, none of these measures are designed to actively encourage or require a pre-defined level of diversification of supplies. To ensure future relevance in light of the REPowerEU objectives to phase out 

Russian gas, this objective may need to be better incorporated in the Gas SoS Regulation. 

COHERENCE 
How well did the regulations work with other policy interventions and how well did specific measures in the regulations work together? 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators  and 
requirements 

information 

Data sources 

• 

EQ13 - To what extent was the EU 
security  of  electricity  and  gas 
supply 
internally 
coherent? 

framework 

• 

• 

• 

consistent 

EQ13.1. – Which provisions within 
the  Electricity  Risk-Preparedness 
and  the  Gas  SoS  Regulation  were 
particularly 
or 
inconsistent with one another? 
EQ13.2. – Which provisions within 
the  crisis  measures  to  address  the 
energy  crisis  were  particularly 
consistent  or  inconsistent  with  one 
another? 
EQ13.3. – Which provisions proved 
to  be  particularly  consistent  or 
inconsistent  between  the  Gas  SoS 
Regulation,  the  Electricity  Risk-
Preparedness  Regulation  and  the 
crisis Regulations? 

• Consistency  in  risk  management 
approaches across the electricity and 
gas sectors (EQ13). 

• Alignment  of  different  provisions 
within  the  Gas  SoS  Regulation 
(EQ13, EQ13.1). 

• Alignment  of  different  provisions 
the  Electricity  Risk-
(EQ13, 

within 
Preparedness  Regulation 
EQ13.1). 

• Alignment  of  different  provisions 
within the crisis regulations (EQ13, 
EQ13.2). 

• Alignment  of  similar  provisions 
between the Gas SoS Regulation, the 
Electricity 
Risk-Preparedness 
Regulation and the crisis regulations 
(EQ13, EQ13.3).  

Quantitative indicators 
•  Electricity  demand  for  heating,  gas 
demand for heating, gas demand for 
electricity generation (EQ13.3). 
•  Amount of similar provisions applied 
differently in gas SoS and electricity 
risk-preparedness (EQ13.3). 

Qualitative indicators 
•  Coherence  between  measures 

in 
national  plans  of  Member  States 
(EQ13.1, EQ13.1). 

•  Alignment  of  electricity  storage  and 
gas storage from an SoS perspective 
(EQ13.3). 

•  Instances of redundant or conflicting 
the  Gas  SoS 

provisions  within 
(EQ13.1) 

• 
• 
• 

• 

• 

ENTSOG, 

ECG/GCG 
NECPs, PAPs, EPs, RPPs 
ENTSOE-E, 
transparency platforms. 
ACER  2023  report  on  electricity 
SoS 
Public consultation 

GIE 

EN 

133 

EN 

 
 
 
 
• Alignment and interchangeability of 
electricity  storage  and  gas  storage 
(and if  relevant, heating  storage)  to 
satisfy critical end-use demand, such 
as heating (EQ13, EQ13.3). 

• Alignment of gas storage policy and 
(EQ13, 

standard 

supply 

the 
EQ13.2) 

•  Instances of redundant or conflicting 
provisions within the Electricity Risk 
Preparedness (EQ13.1) 

Further information requirements 
from  Member  States  and 
Feedback 
stakeholders  on  perceived  coherence,  as 
well as implementation challenges due to 
inconsistencies or overlaps (EQ13) 

Answers 

EQ13.1 - Which provisions within the Electricity Risk-Preparedness and the Gas SoS Regulation were particularly consistent or inconsistent with one another? 

•  Gas SoS 

There were no major internal inconsistencies noted within the Gas SoS Regulation.  

o 
o  However, there is an overlap between the Crisis Management Group and the Gas Coordination Group. There is room for clarification and simplification as regards which group would be used to which ends 

during a crisis. 

• 

Electricity SoS: 

o 

There are no particular internal inconsistencies observed. 

EQ13.2 - Which provisions within the crisis measures to address the energy crisis were particularly consistent or inconsistent with one another? 

• 

The crisis measures were designed to complement each other and therefore show a high degree of coherence. The 15% gas demand  reduction target was needed to re-establish a healthy supply-demand balance after 
RU’s supply cuts, but it was also needed to meet the 90% storage target. As reports COM(2023) 173 and COM(2024) 88 show, the 90% storage targets could only be met through continued subdued gas demand after 
the RU supplies were reduced.  

•  While the storage and demand reduction targets aimed to address immediate security of supply concerns, the default solidarity provisions introduced by Regulation (EU) 2022/2576 complemented these measures. They 

ensured that if these targets were not enough to combat the crisis, the crisis management and solidarity mechanisms would be operational to address a severe emergency.  

EQ13.3 - Which provisions proved to be particularly consistent or inconsistent between the Gas SoS Regulation, the Electricity Risk-Preparedness Regulation and the crisis Regulations? 

• 

• 

• 

The Gas Security of Supply Regulation and Electricity Risk-Preparedness Regulation were designed in a similar way, so they both follow a risk-based approach. Both Regulations use risk assessments and establish 
plans, while transparency and cooperation are fostered through coordination groups. Both Regulations have crisis management provisions containing crisis levels and emergency cooperation procedures. Therefore, they 
show a large degree of coherence with each other. 
Participants to the public consultation expressed varied views on the coherence between the Gas SoS Regulation and Electricity Risk-Preparedness Regulation. Around 30% of the respondents to this particular question 
answered “yes”, 20 % answered “no”, while around half of the respondents did not express any opinion. Participants notably stressed that interdependence between the gas and electricity sectors was insufficiently 
addressed in the existing Regulations, and that an increased focus on cross-sectoral integration would create a more cohesive and efficient energy system. Integrated risk assessments, harmonised crisis declaration 
procedures, and cross-sectoral exercises were notably mentioned as possible areas for improvement. Participants also stressed that the analysis of  critical gas volumes within electricity adequacy outlooks was an 
improvement for the building of cross-sectoral scenarios and should be maintained in the future. 
There is a certain natural overlap between the supply standard and the gas storage target, even though they are not inconsistent with one another. To meet the supply standard, some undertakings will use underground 
storage facilities to ensure supplies to protected customers during the required climatic/infrastructure disruption scenarios. While they lead to similar outcomes (storing gas in UGS) albeit to different degrees, they have 
slightly different objectives (storage target aims to be prepare for the winter season by filling storages, while the supply  standard aims to have a certain level of supply to protected customers guaranteed under pre-
defined conditions. 

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• 

• 

• 

• 

The definition of protected customers between gas and electricity are not aligned. Logic behind protected customers in gas is to protect customers that cannot protect themselves (e.g. households) and protect an essential 
energy need (heating). In electricity, the concept of special protection against disconnection is meant to protect public safety and personal security. There is a risk that gas protected customer concept becomes un-
operational in case of cascading crisis (gas boilers usually need electricity).  
The fact that households do not necessarily qualify as ‘protected customers’ in electricity, while they do in gas, could arguably constitute a hurdle to electrification in the longer term: customer may feel less protected, 
and could be more reluctant to change. 
There is a slight incoherence in the composition of the coordination groups. The Regulation requires the Gas Coordination Group to be composed also of representative bodies of the industry concerned and those of 
relevant consumers, the Electricity Coordination Group’s composition is limited to Member States’ representatives, NRAs, ACER and ENTSO-E. There is no particular reason explaining this difference. An alignment 
in the composition of the two expert groups could be considered in the future. 
Two joint Electricity-Gas Coordination Groups were held in 2022 to discuss cross-cutting issues such as critical gas volumes for electricity, which were computed as part of ENTSO-E’s winter outlook. These joint 
meetings brought further alignment and a joint understanding of a challenging situation on both the gas and electricity market in 2022, which occurred due to reduced availability of Russian gas supplies at the same 
time as reduced hydro and nuclear availability for electricity generation.   
There are differences between solidarity (gas) and assistance (electricity) provisions.  
There are different crisis levels between electricity and crisis: early warning, alert and emergency in gas, compared to early warning and crisis in electricity.  

• 
• 
•  While in the Gas SoS Regulation, the monitoring of security of gas supply measures is a task of the Commission, in RPR it was given to ACER. 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators  and 
requirements 

information 

Data sources 

• 

• 

• 

EQ14. - To what extent was the EU 
security  of  electricity  and  gas 
supply 
externally 
coherent? 

framework 

consistent 

EQ14.1  -  Which  provisions  of  the 
Gas SoS Regulation, the Electricity 
Risk-Preparedness  Regulation  and 
the  crisis  measures  proved  to  be 
particularly 
or 
inconsistent  with  other  measures 
from wider EU energy acquis? 
EQ14.2  -  Which  provisions  of  the 
Gas SoS Regulation, the Electricity 
Risk-Preparedness  Regulation  and 
the  crisis  measures  proved  to  be 
particularly 
or 
inconsistent  with  other  measures 
from wider EU non-energy acquis? 

consistent 

Quantitative indicators 
•  Number  of  provisions 

that 
demonstrably  do  not  align  with 
climate targets (EQ14). 

that 

• 

• 

Alignment  with  other  legislations 
from  the  EU  energy  acquis  (e.g., 
Electricity  Regulation,  CEF,  etc.). 
(EQ14.1) 
Alignment  with  legislations  from 
(Civil 
EU 
Protection  Mechanism,  NIS-2 
Directive,  CER  Directive,  etc.) 
(EQ14.2) 

non-energy 

acquis 

Qualitative indicators 
•  Degree of compatibility of regulatory 
provisions 
infrastructure 
(e.g. 
standard,  storage  target)  with  the 
EU’s  climate  objectives  (Fit-for-55, 
e.g.  REPowerEU)  and  phase  out  of 
fossil fuels (EQ14). 

•  Instances of redundant or conflicting 
provisions with both Regulations and 
the NECPs (EQ14.1) 

• 
• 
• 

• 

• 

•  Further information requirements 
•  Feedback  from  Member  States  and 
stakeholders on perceived coherence, 
as well as implementation challenges 

ENTSOG, 

ECG/GCG 
NECPs, PAPs, EPs, RPPs 
ENTSOE-E, 
transparency platforms. 
ACER  2023  report  on  electricity 
SoS 
Public consultation 

GIE 

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due  to  inconsistencies  or  overlaps 
(EQ14) 

EQ14.1 - Which provisions of the Gas SoS Regulation, Electricity Risk-Preparedness Regulation and crisis measures proved to be particularly (in)consistent with other measures from wider EU energy acquis? 

• 

Trans-sectoral: 

o  NECPs: as further detailed under efficiency, there is no distinct overlap in timing of reporting requirements between the Gas SoS  Regulation and electricity Risk-Preparedness Regulation. However, the 
updates of the PAPs/EPs come shortly before the draft NECPs have to be issued. Both the Plans and the NECPs are extensive reporting requirements for MSs and while the required deliverables are not 
exactly the same, there may be room for simplification.  

•  Gas SoS: 

o 

TEN-E: Gas infrastructure used to be supported by the TEN-E Regulation and CEF funding, which contributed to the N-1 standard and reverse flow requirements of the Gas SoS Regulation. However, the 
TEN-E Regulation no longer covers natural gas infrastructure development. While this is not fully coherent with the N-1 requirement, it is consistent with the EU’s decarbonisation commitments.  

• 

Electricity SoS: 

o 

o 

Electricity Regulation: in 2023, “ACER recommended to explore the synergies between the Electricity Regulation and the Risk Preparedness Regulation and to clarify the measures involving the procurement 
of capacity for the electricity system for emergency situations that can and cannot be introduced under the latter”. Extreme weather events are the main risk that could lead to an overlap of both regulations. 
The RPR cannot be a tool to bypass the Electricity Regulation. 
TEN-E: They can be considered as significantly consistent. The Electricity Risk Preparedness Regulation requires MSs to “include information on related and necessary plans for developing the future grid” 
(even if the first RPPs contained little information on this aspect) and ECG to discuss the results of TYNDP. Also, under the revised TEN-E regulation (2022)8, “security of supply” is included as a specific 
criterion for the assessment of Projects of Common Interest and Projects of Mutual Interest. Article 4 of TEN-E Regulation, which provides general definitions of the “security of supply” criterion for each 
infrastructure category, notably refers to LOLE indicator. The methodology for assessing electricity project’s contribution to SoS developed by ENTSO-E in the guidelines for cost-benefit analyses of grid 
development projects explicitly includes EENS as an indicator to evaluate security of supply. Hence, both Regulations are consistent in their approaches to assess electricity security of supply.  

Network codes: in the public consultation, some participants highlighted unclear links between the network codes and the Risk-Preparedness Regulation as a potential loss of effectiveness. However, a cautious assessment tends 
to show limited overlap between the various regulations. Recital 5 of the Risk Preparedness Regulation asserts that the two network codes “a detailed rulebook governing how transmission system operators and other relevant 
stakeholders should act and cooperate to ensure system security (…) [to] ensure that most electricity incidents are dealt with effectively at operational level”. The Risk Preparedness Regulation deals with events with larger scale 
and impact, for which operational rules no longer suffice, and should fully respect operation rules even in times of electricity crisis. There are specific situations that may create interactions between the Risk Preparedness Regulation 
and the Emergency and Restoration Network Code, e.g., extreme weather events with extensive damage to the electrical infrastructure or severe disruption of fuel supplies. No particular inconsistency was noticed during the 
implementation (see figure below for details about the interplay between the two). 

Visual representation of System Operation Guidelines and Emergency and Restoration Network Code 

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Source: ENTSO-E248 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators  and 
requirements 

information 

Data sources 

• 

EQ15.  –  To  what  extent  are  the 
Risk-Preparedness  Regulation  and 
the  Gas  SoS  Regulation  aligned 
with  high-level  EU  policy  goals 
(e.g.,  EU  Green  Deal,  Economic 
security & open strategic autonomy, 
competitiveness)? 

N/a 

• Alignment with e.g. EU Green Deal, 
and 

Economic 
competitiveness goals (EQ15). 

security 

Further information requirements 
Feedback 
from  Member  States  and 
stakeholders  on  perceived  coherence,  as 
well as implementation challenges due to 
inconsistencies or overlaps (EQ3) 

• 
• 
• 

• 

• 

ENTSOG, 

ECG/GCG 
NECPs, PAPs, EPs, RPPs 
ENTSOE-E, 
transparency platforms. 
ACER  2023  report  on  electricity 
SoS 
Public consultation 

GIE 

EQ15 - To what extent are the Risk-Preparedness Regulation and the Gas SoS Regulation aligned with high-level EU policy goals (e.g., EU Green Deal, Economic security & open strategic autonomy, competitiveness)? 

• 

Trans-sectoral: 

o  Competitiveness: The energy crisis showed that without SoS, the competitiveness of the EU is at risk, as also emphasised by the Draghi Report. While ensuring security of electricity and gas supplies has a 
cost, which may be perceived by some actors as detrimental for EU short-term competitiveness, this needs to be balanced with the benefits for competitiveness associated with energy security, achieved by 
preventing supply crises or by mitigating the impacts of the actual crises which in turn prevents or mitigates high and  volatile energy prices. Reporting is an administrative burden for MS but are low for 
energy undertakings, so they don’t harm competitiveness.  

248 

 See: https://eepublicdownloads.entsoe.eu/clean-documents/SOC%20documents/Nordic/Nordic%20SOA_Annex%20OS.pdf 

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o 

o 

EU Green Deal: the energy transition and energy security are two sides of the same coin. Energy security is needed to facilitate an orderly phase out of fossil fuels and to ensure public acceptance of the 
energy transition. 
European Pillar for social rights (EPSR): the concept of ‘protected customers’ is in line with point 20 “everyone has the right to access essential services of good quality, including (…) energy”.  

•  Gas SoS: 

o 

Infrastructure standard and gas storage targets need to be balanced with the need to avoid creating stranded assets and avoiding carbon lock-in to support decarbonisation objectives. Infrastructure standard 
incentivises development of fossil infrastructure, which is necessary for security of supply and system flexibility, but in the future may require adaptation.  

EU Added Value 
To what extent did the regulations better reach the objectives, compared to what could have been reasonably expected from regional, national or local actions? 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators  and 
requirements 

information 

Data sources 

• 

• 

• 

• 

EQ16 - To what extent has the EU’s 
security  of  electricity  and  gas 
supply  framework  provided  more 
security  of  supply  and  resilience 
to  what  could  have 
compared 
reasonably 
at 
been 
national, regional or local level? 

achieved 

• 

of 

perform 

intervention 

EQ16.1.  –  How  well  did  the  EU-
level 
in 
improving cross-border cooperation 
and crisis coordination? 
EQ16.2.  –  To  what  extent  did  the 
Improvement 
cross-border/regional 
EU’s security of electricity and gas 
cooperation  and  crisis  coordination  over  the 
supply  framework  prevent  cross-
implementation period (EQ16, EQ16.1). 
restrictions  by  Member 
border 
Degree of coordination regarding declaration or 
that  would  affect  other 
States 
lowering of national crisis levels (EQ16.1). 
Member  States,  aggravating 
the 
• 
Lack  of  cross-border  restrictions  imposed  by 
impact of crises? 
Member States during a crisis (EQ16, EQ16.2, 
EQ16.3. - To what extent were the 
EQ16.3). 
in 
crisis  measures 
Lack  of  cross-border  restrictions  included  in 
2022/2023 more or less adequate to 
Member  States’  PAPs/EPs/RPPs 
(EQ16, 
EQ16.2). 
address  cross-border  security  of 
supply  risks  in  a  united  manner, 
compared  to  individual  actions  at 
national, regional or local level? 

adopted 
• 

• 

Quantitative indicators 
• 

• 

• 

Amount of ECG and GCG meetings 
(EQ16.1). 
Number of gas solidarity agreements 
and of electricity technical, legal and 
financial  arrangements 
the 
provision of assistance (EQ16.1) 
Amount  of 
solidarity/assistance 
procedures actually triggered during 
the implementation period (EQ16.1) 

for 

Qualitative indicators 
Discussions in ECG/GCG meetings 

• 
• 

• 

• 

• 

reviewing 

the  Gas  SoS 

Desk Research 
Report  reviewing 
Regulation 
Report 
Regulation  
Report  reviewing  the  emergency 
Regulations  (demand  reduction  & 
solidarity) 
Table-top (dry run) exercises 

the  Storage 

Answer: 

• 

EQ16.1 - How well did the EU-level intervention perform in improving cross-border cooperation and crisis coordination? 

o  Gas SoS:  

▪ 

▪ 

Best practice measures were exchanged in the GCG in particular during the energy crisis and next steps for EU-wide measures to enhance preparedness during the energy crisis were discussed, 
which played a key role in informing the Commission in order to propose new legislative proposals. 
The declaration of national crisis levels during the energy crisis went in a fairly coordinated manner, which can largely be explained by the fact that MSs reacted to the same or similar incidents 
(e.g. RU cutting supplies to multiple MSs in the same period) and because the EU energy market is well-interconnected. The GCG proved a valuable tool to coordinate, as the declaration of a 

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crisis level and the reasoning thereof was immediately shared and discussed. However, discussions in the GCG pointed to the fact that more guidance is needed on when a crisis level should be 
lowered in a coordinated manner. 
Cross-border cooperation has been facilitated due to the fact that the EU energy market is well-interconnected. This has in part been improved because of the infrastructure standard and the bi-
directionality requirement, which obliged Member States to have a pre-defined level of redundancy in infrastructure which made energy infrastructure more flexible especially in case of supply 
disruptions. 
Insufficient  solidarity  agreements  were  signed  (9  out  of  40),  meaning  that  emergency  cooperation  was  not  operational  until  default  solidarity  agreements  were  introduced  by  the  Solidarity 
Regulation and later enshrined in permanent legislation by the Hydrogen and Decarbonised Gas Package. 

▪ 

▪ 

▪  While the overall content of the PAPs and EPs was often satisfactory, the regional chapter was often underdeveloped, largely due to the fact that the required bilateral solidarity agreements were 

▪ 

not signed.  
The Common Risk Assessments were not submitted on time and the Commission had to step in for the majority of risk groups to help with modelling and the overall assessment. Despite the 
significant shortcomings experienced in the process, common risks facing a region were identified leading to a shared understanding of the security of supply situation in the EU.  

o 

Electricity SoS: 

▪ 

▪ 
▪ 

▪ 
▪ 
▪ 
▪ 

Identification of regional crisis scenarios by ENTSO-E, on which national scenarios had to be based. In the second round of the identification of regional crisis scenario, ENTSO-E involved RCCs 
to improve the assessment of cross-border risks. However, assessment of regional risks is still not fully satisfactory (remains a pan-European assessment).  But very substantial improvements 
achieved in the second cycle. 
Very few information in RPPs about regional exercises. 
Information about regional and bilateral measures (solidarity) to cooperation in the prevention or management of a crisis was very incomplete in RPPs. Only 9 MS referred to existing arrangements 
and identified a number of measures but were not considered complete enough. While, according to the regulation, ACER should technical assistance to Member States with a view to facilitating 
regional/bilateral agreements, this option was never triggered during the implementation period. 
Information about cooperation and coordination with Member States out of their regions for the establishment of the RPPs was also considered as insufficient. 
RCCs have been performing more SoS-related tasks but could do more (cf. JRC report). 
Huge increase of ECG meetings compared to the period before the entry into force of the Regulation. ECG has become a very useful cooperation & monitoring platform. 
Assistance measures were never actually triggered. 

• 

EQ16.2 - To what extent did the EU’s security of electricity and gas supply framework prevent cross-border restrictions by Member States that would affect other Member States, aggravating the impact 
of crises? 

o  Gas SoS:  

▪ 

6 Member States included cross-border restrictions in the PAPs/EPs, no cross-border restrictions were implemented during a crisis. This does not necessarily mean that these  restrictions are undue 
during  a  crisis, as  the justification of  activating  such measures  will depend on  the  situation at hand.  The  Solidarity  Regulation  strengthened the  role of  the  Commission  to  lift  undue  cross-border 
restrictions imposed by Member States on cross-border flows during a crisis. 

o 

Electricity SoS:  

▪ 

No  unjustified  measures  restricting  cross-border  flows  actually  implemented  during  the  implementation  period  (mention  BG  2017  export  ban:  https://eepublicdownloads.entsoe.eu/clean-
documents/news/entso-e_Managing_Critical_Grid_Situations_web.pdf) 

• 

EQ16.3 - To what extent were the crisis measures adopted in 2022/2023 more or less adequate to address cross-border security of supply risks in a united manner, compared to individual actions at national, 
regional or local level? 
o  Gas SoS: 

▪ 

Unilateral supply cuts from Russia required EU level action, due to the scale of the supply cuts that affected the majority of MSs. The gas market is an integrated market, meaning that a supply 
cut to one MS also affects security of supply in a neighbouring MS, either through price increase/volatility or the need to acquire alternative volumes on neighbouring markets.  

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▪ 

▪ 

▪ 

▪ 

By having the 15% demand reduction target at EU level, rather than at national level, demand could be reduced there were it was most efficient to reduce. Wide variety in reduction between 
Member States was observed (ranging from -42% in DK to +7% in MT), which reflects different consumption patterns between MSs. Therefore, the fact that one MSs can voluntarily reduce so 
that there were it is more difficult (e.g. because of a coal-to-gas switch, which happened among others for district heating in Ljubljana), helped lower the joint cost of the energy crisis. 
The Solidarity Regulation introduced default solidarity rules that operationalised the emergency cooperation among Member States in case of a severe gas shortage. These measures never had to 
be implemented but the ‘dry run’ exercise of 2022 showed that these provisions improved the crisis management architecture of the EU. Without an operationalised solidarity mechanism at EU 
level, MSs would not be ensured to have access to volumes of  neighbouring MSs in case of a national gas emergency, if it means that  consumers in the neighbouring MS would have to be 
curtailed.  
The Storage Regulation set a common 90% storage target, which improved the collective winter preparedness of the EU by ensuring that winter demand is met with sufficient supply, as highlighted 
in report COM(2024) 89. The Storage Regulation includes a burden sharing mechanism and obliges that MSs without storage facilities contribute to filling the storages of MSs with storage 
facilities. However, burden sharing remains a contentious issue among MSs, especially for MSs with larger storage facilities.  
In October 2022, DE introduced a gas neutrality charge to refinance storage filling costs incurred, charged at all cross-border points. It substantially impacted cross-border flows and was harmful 
for the EU internal market and SoS. It hampered phasing out RU pipeline gas, as alternative routes for MSs in the CEE region became more expensive. In this particular case, the framework was 
not successful in preventing and resolving the situation, even if the measure is not active anymore since 1 January 2025. This may contribute to why, in the public consultation, the performance 
of the Gas SoS Regulation was deemed the least effective on the following objective: “Enhance regional and EU-wide cooperation, even in times of crisis”. Feedback, however, was overall still 
positive. 

o 

Electricity SoS: 
▪ 

No unjustified cross-border restrictive measure was introduced strictly on electricity SoS grounds. Instead, there was an increased coordination and exchanged of info through the ECG that was very 
welcome and pointed to the way forward to pass the winter (e.g. through the ENTSO-E outlook). In addition, ENTSO-E did extra critical gas volumes calculations that helped MS to take their own 
measures having in mind the situation in neighbouring countries. 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators  and 
requirements 

information 

Data sources 

• 

EQ17 - To what extent has the EU’s 
security  of  electricity  and  gas 
supply  framework  improved  the 
EU’s  collective  preparedness  for 
crisis situations? 

• 

• 

• 

• 

• 

EQ17.1.  –  To  what  extent  did  the 
EU’s security of electricity and gas 
supply framework help identify and 
jointly  address  cross-border  risks 
that  could  affect  several  Member 
States? 
EQ17.2.  –  To  what  extent  did  the 
improve 
intervention 
EU-level 
• 
information 
transparency 
and 
sharing  among  Member  States  and 
market actors? 

• 

Degree  and  quality  of  cross-border  risks 
identified  in  risk  assessments/regional-national 
electricity crisis scenarios (EQ17, EQ17.1). 
Degree  of  cross-border  risks  addressed  in 
PAPs/EPs/RPPs (EQ17, EQ17.1). 
Improvement in transparency of crisis measures 
that  (neighbouring)  MSs  could 
implement 
during a crisis (EQ17, EQ17.2).  
Improvement  in  transparency  for  stakeholders 
under  which  circumstances  non-market-based 
measures  may  be  implemented  by  authorities 
(EQ17, EQ17.2). 

• 

Quantitative indicators 
• 

Amount  of  MSs  that  consulted 
neighbouring MSs and stakeholders 
on their plans (EQ17.2). 
Amount of ECG and GCG meetings 
(EQ17.2). 
Number  of  plans  and  opinions 
published  on  the  Europa  website 
(EQ17.2). 

• 

• 

Qualitative indicators 
Discussions in ECG/GCG meetings. 

• 
• 

• 

• 

• 

reviewing 

the  Gas  SoS 

Desk Research 
Report  reviewing 
Regulation 
Report 
Regulation  
Report  reviewing  the  emergency 
Regulations  (demand  reduction  & 
solidarity) 
Table-top (dry run) exercises 

the  Storage 

• 

EQ17.1 - To what extent did the EU’s security of electricity and gas supply framework help identify and jointly address cross-border risks that could affect several Member States? 

▪  Gas SoS:  

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▪ 

▪ 

▪ 

▪ 

Before the Regulation, there was no framework to identify (let alone address) cross-border risks. The Regulation created the obligation for MSs to create common risk  assessments in regional risk 
groups. In the latest CRAs, a series of risks were identified often taking a full Russian supply disruption as the baseline scenario. On top of a full Russian supply disruption among others individual 
pipeline disruptions, liquefaction trains being out of service, or cold spells were simulated. This means that the common risk assessments have mostly met the policy objective of enhancing preparedness 
and transparency of measures through a risk-based approach, although there are areas that require further work to ensure that this objective is completely met.   
During the ‘dry run’ of 2022, it was considered by participants that the EU emergency level is insufficiently defined, in particular the difference between EU and regional emergency and the role of the 
Commission in an emergency. Participants indicated that an EU-wide emergency would be more effective than regional emergency, as it would include those Member States that may still be in  a 
position to help those in need. However, Member States indicated that the declaration of an EU emergency would not necessarily result in the declaration of a national emergency level, which in some 
Member States would allow for introducing non-market measures. 
The two ‘dry run’ exercises that were organised proved to be tangible examples of EU added value to foster coordination and cooperation. This is in particular  the case since it confirmed the key 
coordinating role of the Commission and the importance of that non-market-based measures implemented nationally do not deteriorate the SoS situation in neighbouring MSs. 
The role of the Commission in an EU emergency is ambiguous beyond its coordinating tasks, as indicated in the report reviewing the Gas SoS Regulation. This is in contrast to the role of the Commission 
in the newly established EU alert, where the role of the Commission in monitoring, coordinating and enforcing demand reduction is clearer. Relates to having a lack of EU emergency plan in contrast 
to national emergency plans. 

▪ 

Electricity SoS:  

▪ 

▪ 

Identification of regional crisis scenarios by ENTSO-E, on which national scenarios had to be based. In the second round of the identification of regional crisis scenario, ENTSO-E involved RCCs to 
improve the assessment of cross-border risks. Despite some flaws, the second cycle of the assessment of regional crisis scenarios displayed very substantial improvements (cf. section on effectiveness). 
Shallow assessment of cross-border risks in electricity. However, work is ongoing with a revision of the methodology to put more emphasis on simulations at regional level Work ongoing, revision of 
methodology to put more emphasis on simulations at regional level 

EQ17.2 - To what extent did the EU-level intervention improve transparency and information sharing among Member States and market actors? 

• 
▪  Gas SoS:  

▪ 

▪ 

▪ 

According to MSs PAPs, all but 1 plan were consulted with (domestic) stakeholders (1 plan did not specify whether it was consulted with stakeholders) and 14 were before publication consulted with 
neighbouring Member States and the Commission.  All plans are available to stakeholders and neighbouring Member States, given that they are required to be published on the Europa webpage by the 
Regulation. 
27 GCG meetings in full format (including market participants) since 2017 and a sharp increase in the amount of GCG meetings during the crisis (mostly restricted to MSs only). Exchange of best 
practice measures and coordination of next steps was greatly facilitated by the GCG’s flexible and adaptable format.  
The Gas SoS Regulation’s Article 14 fosters transparency and avoid security of supply risks stemming from nationally concluded supply contracts at EU level. It provides an obligation on MSs to notify 
to the Commission commercial information related to gas supply contracts in order to assess the security of supply situation at national, regional, and Union level. Moreover, it allows the Commission 
to directly address the gas undertakings to receive the gas supply contracts under specific and duly justified circumstances. However, the enforcement provisions could benefit from further specification 
to  reinforce  the  effectiveness  and thereby  the  EU  added value of  the  measure,  which is necessary  to ensure  an effective implementation  to  strengthen  security  of  gas  supply  while preserving the 
confidentiality of commercial information.  

▪ 

Electricity SoS:  

▪ 

▪ 

A key outcome of the Regulation was increased information exchange after security of supply incident occurred, which fostered coordination and a shared  understanding and sensemaking of the 
situation.   
The Regulation increases transparency as the Risk-Preparedness Regulation requests MSs to describe their national crisis measures in the plans. Typically, the crisis measures used to be described only 
in national laws and countries were not aware of the national measures in their neighbouring countries and the potential effect on their own country. 
▪  MSs were officially consulted on other MSs’ RPPs. But only one MS officially did so (SE provided comments on plans from DK, FI, DE, LT, PL) 
▪ 

28 RPPs (and corresponding Commission’s opinion) that are public on Europa website. 

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▪ 

The frequency of ECG meetings dramatically increased since the adoption of the Regulation. Most Member States met their obligation (even if with some delay) to share their draft RPP with their 
neighbours, giving them the opportunity to provide feedback. Only one Member State made official comments on other MSs’ plans (SE). For example, a 3-day session was dedicated to discussing the 
RPPs in June 2021. 

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Annex IV. Overview of benefits and costsTable 1. Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations249 

Commission and Agencies 

Quantitative   Comment  Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

costs 

Direct 
complian
ce 
(adjustment 
costs, 
administrativ
e 
costs, 
regulatory 
charges) 

Adjustment 
costs 

One-off 

for 

costs 

The 
infrastructure 
development 
is 
ultimately mostly passed 
on to consumers through 
tariffs. 
regulated 
these 
However, 
tariffs 
are 
influenced  by  all 
infrastructure 
developments,  most  of 
which are unrelated to the 
Gas  Security  of  Supply 
Regulation  or  Electricity 
Risk-Preparedness 
Regulation. 

For 

Infrastructure 
standard: 
Bilciurești 
project, 
total 
costs 
eligible 
were estimated at 
EUR  110  million 
(of  which  EUR 
38  million  were 
covered  by  CEF 
funding). 

Infrastructure 
standard:  cost for 
TSOs 
of 
developing 
to 
infrastructure 
meet  the  N-1  and 
the 
flow 
reverse 
obligation. It is not 
possible to have an 
exact estimation for 
provision, 
this 
of 
because 
causality 
issues. 
case 
some 
But 
studies can give an 
idea of the order of 
magnitude. 

Infrastructure 
standard: N/A 

Infrastructure 
standard: N/A 

Infrastructur
e 
standard: 
e.g., 
Bilciurești 
benefitted 
from  EUR  38 
million of CEF 
funding. 

Infrastructure 
standard:  some 
projects 
benefitted  from 
EU  funding  to 
the 
meet 
- 
obligation 
some 
case 
studies  can  give 
an  idea  of  the 
order 
of 
magnitude  (e.g., 
Bilciurești). 

Reverse 
flows 
obligations:    In 
ENTSOG’s 
TYNDPs, 
reverse 
projects 

6 
flow 
were 

Reverse 
flows 
obligations:  TSOs 
investing  to  meet 
the  requirement  – 
some  case  studies 
can give an idea of 

Reverse 
obligations:  N/a. 

flows 

Reverse  flows 
obligations:  
N/a. 

Reverse flows 
obligations:  
Karksi 
received  EUR 
18.7 mln EUR 
CEF 
of 

flows 

Reverse 
obligations:  
Two 
projects 
benefitted  from 
EU  funding  to 

249  The quantitative figures provided for the costs borne by Member States are based on the feedback received directly from them (cf. methodology section). They should be treated with 
caution, as the replies received do not constitute a representative sample. Due to the low number of responses received and their disparate nature the robustness of the data presented 
proved difficult to assess. This is exacarbated by the fact that it was not possible to triangulate the data received with independent third sources. Nevertheless, they constitute the best 
available estimate.  

EN 

143 

EN 

 
 
 
                        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
that 

identified 
were 
commissioned  in 
evaluation 
the 
period 
that 
included  CAPEX 
which 
costs, 
totalled  286  mln 
EUR. 
For 
example,  Karksi 
project  cost  EUR 
to 
37.4  million 
make 
IP 
bidirectional (half 
of 
costs 
were  covered  by 
CEF funding). 

these 

the 

meet 
obligation. 

the 

Certification  of 
SSOs: 
Commission: 
for  the  drafting 
of  the  opinions 
on  the  storage 
certification 

order 

the 
magnitude. 

of 

Certification 
of 
SSOs: 
  Figures 
provided 
range 
total 
180 
from 
hours  spent,  to  2.5 
FTE  (both  for  the 
period  of  2022-
2024). 

Certification 
of 
SSOs: 
It 
is 
conceivable 
that 
costs 
are 
there 
borne  by  the  UGS 
operators  that  had 
to  be  certified,  e.g. 
reporting 
to 
due 
requirements 
but 
no  such  costs  have 
been notified. 

Certification 
of  SSOs:    The 
figures 
by 
provided 
MSs indicated a 
wide 
range, 
partly explained 
the 
by 
difference 
in 
amount of UGS 
sites  on 
their 
territory. 

reverse 
project 

to 
the  IP 

funding 
make 
bidirectional. 
The 
flow 
TENP 
received  9.11 
mln  EUR 
in 
CEF 
funding 
(0.4  mln  EUR 
for studies, 8.7 
in 
mln  EUR 
support 
for 
procurement 
and  execution 
of the works 

N/a 

Administrative 
Costs 

Recurren
t 

Certification  of 
SSOs: N/a. 

GCG/ECG: 
Negligible 

flows 

Reverse 
exemptions:  
Negligible,  given 
the  low  number 
of 
exemption 
requests. 

GCG / ECG: 
Participation 
to 
meetings  (through 
ENTSOs) 

Reverse 
flows 
exemptions:  TSOs 
the 
drafting 
for 
request 
exemption.  

of 

ECG/GCG: 
negligible. 

flows 

Reverse 
exemptions:  
Negligible,  given 
the  low  number  of 
exemption 
requests. 

GCG / ECG: 
Participation 
to meetings 

Reverse flows 
exemptions:  
CAs rafting of 
the 
coordinated 
decision. 

Certification 
of SSOs:  
0.5 FTEs 

All 
administrativ
e provisions: 
ENER 
DG 
3.5 
devotes 
to 
FTEs 
perform 
its 
tasks  (1.5  for 
electricity  and 
2  for  gas)  + 
administrative 
arrangement 
with  JRC  (for 

GCG  /  ECG: 
secretariat  

flows 

Reverse 
exemptions: 
ACER’s opinion 
on reverse flows 
+ 
exemptions 
Commission’s 
decisions. 

EN 

144 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
period 

the 
2022-2025, 
EUR  647  000 
for  gas  and 
EUR  536  000 
for electricity) 

ACER 
estimates  that 
it  devotes  2.5 
FTE 
to 
perform all the 
tasks  from  the 
Gas  SoS  and 
Electricity 
Risk-
Preparedness 
regulations. 

Supply 
standard: N/a 

Plans  and  risk 
assessments: 
Drafting 
Commission’s 
opinions. 

of 

Solidarity/Assi
stance: N/a 

Supply 
standard: 
Negligible 
(cf. 
section) 

cost 
efficiency 

Supply  Standard: 
gas 
Cost 
for 
undertakings 
to 
meet 
the  supply 
standard 
obligation.  

Plans  and  risk 
assessments: N/a 

Plans  and  risk 
assessments: N/a 

Solidarity/Assist
ance:  40 hours/y 
– 130 hours/y 

Solidarity/Assista
  Two  MSs 
nce: 
indicated  that  their 
TSOs  had  borne 
costs  in  relation  to 
the  negotiation  or 
conclusion 
of 
solidarity 
agreements. 

Supply  standard: 
N/a 

Supply 
standard: N/a 

Plans  and  risk 
assessments: 
for 
gas,  the  estimates 
provided  by  MSs 
range  from  EUR 
30k and EUR 300k, 
and  from 0.3  to  33 
FTEs. 
For 
electricity, the only 
feedback  received 
on  this  particular 
task mentioned 320 
hours/y 

Solidarity/Assista
nce:  
On  gas,  estimates 
received 
ranged 
between 40 hours/y 
-  25  days/y.    One 
MS 
it 
indicated 
total  of 
spent  a 
100.000 
EUR 
negotiating 
solidarity 
agreements  during 
the 
evaluation 
period. 

and 

Plans 
risk 
assessments: 
of 
cost 
drafting 
the 
various  plans 
required by the 
regulations 
(RPPs/PAPs/E
Ps) 

the 

Solidarity/As
sistance: costs 
of 
the 
negotiations to 
reach 
agreements 
with 
neighbours. 
Three  MSs 
the 
reported 
spent 
time 
negotiating 
solidarity 
agreements, 
one  Member 

EN 

145 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
On electricity, only 
one  MS  provided 
this 
feedback  on 
particular 
provision, 
estimating it spent a 
200 
of 
total 
hours/y. 

Supply  outlooks: 
N/a 

State  provided 
in 
a  number 
per 
Euros 
The 
year. 
majority 
of 
Member 
States  has  not 
concluded, 
and 
in  some 
instances  not 
negotiated, 
solidarity 
agreements. 
The 
time 
overall, 
therefore 
contained. 

actual 
spent, 
is 

Supply 
outlooks: N/a 

Supply-outlooks, 
Methodologies, 
Risk  assessments 
and 
SoS 
simulations: 
ENTSOs  regulated 
tasks. 
  The  gas 
supply outlooks are 
not within the remit 
the  Gas  SoS 
of 
Regulation  and  are 
therefore out of the 
scope of this fitness 
check. 

Supply-
outlooks, 
Methodologies, 
Risk 
assessments  and 
SoS simulations: 
ENTSOG 
devotes  a  total  of 
2  FTEs  to  their 
tasks  mandated 
by  the  Gas  SoS 
Regulation. 

ENTSO-E 
devotes  a  total  of 
2  FTEs  and  EUR 
50k  (in  2024)  of 
other costs for the 
of 
performance 

146 

Supply 
outlooks: N/a 

EN 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
the 
seasonal 
supply  adequacy 
outlooks;  a  total 
of  2  FTEs  and 
approximately 
EUR  4.4  million 
(in 2024) of other 
the 
costs 
for 
performance 
of 
short-term 
adequacy 
a 
assessments; 
total  of  0.8  FTEs 
for  each  regional 
crisis 
scenarios 
report  (in  2020 
and  in  2024).  All 
this comes on top 
of  0.6  FTEs  for 
regular 
the 
implementation 
of the Regulation. 

filling 

Storage 
measures:  
study, 
ACER 
assessed 
which 
that 
certain 
national measures 
in  three  Member 
States to establish 
strategic  reserves 
cost €19 billion in 
purchase. 
However, 

the 

Storage  filling 
measures: N/a 

Storage 
filling 
measures:      as  the 
commodity 
is 
generally 
purchased and sold 
simultaneously at a 
premium,  the  cost 
of 
is 
storage 
generally  covered 
gains. 
by 
the 
However, 
by 
setting  mandatory 
targets,  operators 

Storage 
filling 
measures:   ACER 
which 
study, 
assessed 
that 
certain 
national 
measures  in  three 
Member  States  to 
establish  strategic 
reserves  cost  €19 
billion in purchase. 
However,  the  total 
cost of the measure 

Storage 
filling 
measures:    as 
the 
commodity 
can  be  resold 
later,  the  cost 
of the measure 
primarily 
is 
the 
cost  of 
storage. 
However,  by 
forcing 

EN 

147 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Demand 
reduction 
measures: N/a 

total  cost  of  the 
measure  depends 
on  the  difference 
with  the  price  at 
which the gas has 
been  or  will  be 
the 
and 
sold 
duration  of 
the 
storage. 

Demand 
reduction 
measures: N/A. 

may  fill  storages 
even 
in 
unfavourable 
market  conditions, 
ultimately 
increasing 
supply costs. 

the 

depends  on 
the 
difference  with  the 
price  at  which  the 
gas has been or will 
the 
be  sold  and 
duration  of 
the 
storage. 

Demand 
reduction 
measures: N/A. 

Demand 
reduction 
measures: N/A. 

to 
operators 
fill 
storages 
regardless  of 
market 
conditions, the 
measure 
can 
ultimately 
increase 
costs. 

the 

Demand 
reduction 
measures: 
Since  the  ‘EU 
alert’ 
was 
never 
the 
declared, 
provisions  of 
the  regulation 
always 
remained 
voluntary,  so 
any  costs  are 
unlikely  to  be 
directly 
attributable  to 
their 
implementatio
n. 

Bi-annual 
electricity 
exercises:  a  group 
of  Member  States 

Bi-annual 
electricity 
exercises: 
costs 
associated 

EN 

148 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
reported  costs  of 
EUR 85 000 – 125 
travel 
(+ 
000 
expenses)  for  the 
organisation  of  a 
crisis 
regional 
(two 
exercise 
exercises 
were 
organized  by  this 
region 
specific 
during 
the 
evaluation period). 

For 
Others: 
electricity 
RPR, 
MSs’  estimations 
of 
the 
administrative 
costs  ranged  from 
645  hours/y  to  1.6 
FTE.  One Member 
State 
reported 
administrative 
costs  of    €262  928 
the 
for 
implementation  of 
both regulations. 

N/a 

the 

such  bi-

with 
organization 
of 
annual 
regional 
exercises. 

DG ENER devotes 3.5 FTEs to 
perform its tasks. 

ACER  estimates  that  it  devotes 
2.5 FTE to perform all the tasks 
from the Gas SoS and Electricity 
Risk-Preparedness regulations. 

Commission 
reports 
(Solidarity, 
Storage, 
RPR) 

SoS, 

SoS 

ACER 
monitoring 
reports 

149 

EN 

N/a 

N/a 

Recurrent 
(ACER 
monitoring reports) / One-
and 
(pilots 
Off 
infringements 
+ 
Commission reports) 

Enforcem
ent  Costs 
(costs 
associated 
with 
activities 
linked  to  the 
implementati
on 
an 
of 
initiative 
such 
monitoring, 

as 

EN 

 
 
 
 
 
 
inspections 
and 
adjudication/
litigation) 

Direct 
Benefits 

Recurrent 

N/a 

Pilots 
infringements 

and 

Indirect 
Benefits 

Recurrent 

As  explained  in  the  section  on  efficiency,  the  benefits  of  the  framework  are  difficult  to  quantify because  of  the  “preparedness  paradox”: 
security of supply works as an insurance, and the benefits are not truly quantifiable. The whole society benefits from the avoided crises (whose 
impacts  by  definition  are  not  measurable)  and  from  the  mitigation  of  actual  crises.  It  is  however  possible  to  use  proxies.    E.g.,  the  total 
economic cost of the 2003 Italian blackout (which lasted some hours) can be estimated at EUR 1.182 billion (source: blackout simulator). 
Other examples can be found in the section 4.1 on efficiency. 

EN 

150 

EN 

 
 
 
 
 
TABLE 2:  Simplification and burden reduction (savings already achieved)  
Report any simplification, burden reduction and cost savings achieved already by the intervention evaluated, including the points of comparison/ where available (e.g. REFIT savings 
predicted in the IA or other sources).  

Citizens/Consumers/Workers 

Businesses 

Administrations 

EU Institutions/Agencies 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative  Comment  

Quantitative  Comment 

Title250 (i) direct compliance cost savings  

Type: One-off / recurrent (select) 

N/a 

N/a/ 

N/a 

N/a 

N/a 

N/a 

N/a 

The  Regional 
architecture  of 
the  Gas  SoS 
Regulation  has 
been 
already 
simplified 
in 
by 
2025 
the 
reducing 
of 
number 
regional 
risk 
groups  to  four. 
Monetisation is 
not 
possible, 
because  (i)  the 
reduction  was 
only 
recently 
implemented251 
the  costs 
(ii) 
linked 
the 
to 
previous 
regional 
architecture 
were 
difficult 
assess. 

already 
to 

PART II: II Potential simplification and burden reduction (savings) 
Identify further potential simplification and savings that could be achieved with a view to make the initiative more effective and efficient without prejudice to its policy objectives252. 

Citizens/Consumers/Workers 

Businesses 

Administrations 

EU institutions/agencies 

EN 

151 

EN 

 
 
               
 
 
 
 
Quantitative  

Comment 

Quantitative  

Comment 

Quantitative  Comment  

Quantitative  Comment 

Description: Direct compliance cost savings 

Type:  One-off / recurrent (select) 

N/a 

N/a 

N/a 

N/a 

Reverse  flows 
exemptions 
the 
(TSOs): 
to 
procedure 
request 
an 
exemption from 
the reverse flow 
obligations 
be 
could 
lightened, given 
its  current  high 
complexity  and 
progress 
the 
already 
achieved 
throughout 
EU. 

the 

N/a 

flows 

Reverse 
exemptions 
the 
(NRAs): 
to 
procedure 
an 
request 
exemption 
from 
the  reverse  flows 
obligations  could 
lightened, 
be 
given  its  current 
high  complexity 
and  the  progress 
already  achieved 
throughout 
the 
EU. 

Plans:  reporting 
requirements  for 
States 
Member 
be 
could 
lightened 
by 
some 
merging 
planning 
and 
obligations 
by 
better 
leveraging  digital 
tools. 

Reverse 
flows 
exemptions 
(ACER/Co
mmission): 
the 
procedure to 
grant 
an 
exemption 
from 
the 
reverse flow 
obligations 
could 
lightened, 
given 
its 
current  high 
complexity 
and 
progress 
already 
achieved 
throughout 
the EU. 

the 

be 

250  Each simplification/saving should be included on a separate line.  

251  As of March 2025, the delegated act is still in the process of adoption. 

252  This assessment is without prejudice to a possible future Impact Assessment. 

EN 

152 

EN 

 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

The objective set out in the consultation strategy was to better understand the views of stakeholders and citizens 
on the effectiveness, efficiency, EU added value, coherence and relevance of the existing security of electricity 
and gas supply policy interventions, in line with the Better Regulation guidelines. The views of stakeholders 
and citizens were also sought on the future issues and priorities of energy security policy. 

The purpose of the consultation strategy of this fitness check was to reach a wide set of stakeholders, including 
the  traditional  stakeholders  that  are  represented  in  Commission’s  expert  groups,  e.g.  the  Gas  Coordination 
Group and Electricity Coordination Group. These stakeholders can be considered as having a high interest in 
the evaluation effort.  

The aim, however, was also to go beyond the usual stakeholders and reach possibly ‘underserved’ stakeholders 
and citizens. While their direct interest or experience may not be on a par with the usual stakeholders, their 
inputs  and  perspectives  are  valuable  to  ensure  a  comprehensive  view  on  energy  security  in  society  while 
minimising  possible  biases.  Allowing  everyone  to  express  their  views  on  energy  security  is  also  a  way  to 
improve democratic legitimacy of the exercise. 

The consultations carried out for this fitness check consisted of a number of activities: 

Commission expert group meetings, in particular the Gas Coordination Group and Electricity Coordination 
Group. 

A 12-week public consultation and call for evidence that ran from 3 September 2024 until 26 November 
2024.  

Other individual stakeholder events, such as the Regulatory Roundtable as part of the Citizen’s Energy Forum 
on 6 December 2024, or an event organised by Energies@Bruxelles on 15 November 2024. 

An  energy  Eurobarometer  was  carried  out  and  published  in  September  2024  to  gauge  citizen’s  general 
perceptions regarding wider energy policy matters.  

In  addition,  several  bilateral  exchanges  were  held  with  a  wide  variety  of  stakeholders,  outside  of  the 
aforementioned events. 

Commission expert group meetings 

The  fitness  check  and  the  wider  review  of  the  EU  security  of  electricity  and  gas  supply  framework  were 
presented and/or have been discussed at several Commission expert group meetings.  

This  included  notably  several  Gas  Coordination  Group  (GCG)  and  Electricity  Coordination  Group  (ECG) 
meetings, where the matter was discussed in more detail. This notably includes meetings of the GCG on 27 
November 2024, 9 July 2024 and 19 June 2024, as well as the ECG on 5 December 2024 and 15 October 2024. 
A discussion and a short presentation of some first preliminary results of the public consultations were also held 
in the Offshore Activities Coordination Group and the Oil Coordination Group on 3 December and 5 December 
respectively.  These  discussions  notably  provided  updates  on  the  public  consultation  and  provided  Member 
States’ authorities and stakeholders the opportunity to highlight points that should be reflected in this report.  

EN 

153 

  EN 

 
In  addition,  stakeholders  were  also  reached  and  the  public  consultation  was  advertised  through  the  Oil 
Coordination Group, the Offshore Safety Group, the Critical Entities Resilience Group, and the CESEC Plenary 
Working Group.  

Call for Evidence 

A total of 90 organisations and citizens provided feedback to the Call for Evidence, of which four responses 
were taken offline due to their incompliance with the feedback rules of the Commission’s ‘Have your Say’ 
portal, resulting in 86 remaining responses from 18 different countries (3 non-EU).  

The contributions received in the context of the call for evidence that are published on the ‘Have Your Say’ web 
portal cannot be regarded as the official position of the Commission and its services and thus does not bind the 
Commission.  In  addition,  the  contributions  cannot  be  considered  as  a  representative  sample  of  the  EU 
population. 

The  four  responses  to  the  call  for  evidence  that  were  taken  offline  concerned  four  Slovak  citizens,  whose 
responses were incompliant with the following rule: “abusive, obscene, vulgar, slanderous, hateful, xenophobic, 
threatening or sexually-oriented comments.”253 

The call for evidence received feedback from a wide variety of stakeholders, as further detailed in Figure 47. In 
particular, it was noteworthy that the largest category was EU citizens, with 30%. This is important, since other 
consultation activities did not manage to reach EU citizens to the same extent, as will be further outlined in 
subsequent sections. Of EU citizens, half of the respondents came from Slovakia, who generally voiced their 
opposition to e.g. the phase out of Russian gas.  

253  Rules for feedback and suggestions 

EN 

154 

  EN 

 
 
 
 
Figure 46: Feedback received on Call for Evidence by category of respondent 

Source: EC-JRC, 2024  

Other categories of respondents came from a wide variety of countries (18 in total), although a large share of 
respondents originated from Belgium (25 out of 86), which can largely be explained by the responses stemming 
from Brussels-based associations. Other countries of origins with a relatively larger share include Austria (9%), 
Germany (8%) and France (7%), as further detailed in Figure 48.  

Figure 46: Respondents per country 
￼ 

Source: EC-JRC, 2024  

In  terms  of  feedback  received,  academic  and  research  institutions  called  for  a  comprehensive  regulatory 
framework that integrates energy, environment, climate, and biodiversity objectives, stressing the importance 
of cybersecurity and the phase-out of fossil fuels for an equitable transition. They also emphasised the potential 
of demand-side solutions to improve energy security through building energy efficiency and sufficiency.  

According to business associations, the EU should establish baseline energy security standards for Member 
States, allowing flexibility in implementation while ensuring compliance. As the EU transitions to clean energy, 
supply resilience must be improved, despite potential cost increases, to ensure an affordable and uninterrupted 
supply for consumers. Business associations emphasised the need for a shift in the EU's energy security strategy 
from  supply-side  to  demand-side  measures,  reducing  reliance  on  energy  imports.  They  also  stressed  the 
importance  of  securing  heat  supply,  alongside  electricity  and  gas,  and  the  need  for  building  renovations  to 
achieve climate targets, provide cost savings, and ensure grid stability. Associations advocated for increased 
electrification and renewable integration, emphasising resilience, affordability, and flexibility. They proposed 
enhanced  strategic  energy  storage  solutions,  such  as  hydrogen,  and  waste-to-energy  systems,  to  mitigate 
geopolitical risks. Additionally, they suggested policy revisions to incorporate nuclear energy, diversify supply 
sources, and support local renewable energy projects to reduce import dependencies and achieve climate goals. 

EN 

155 

  EN 

 
 
Companies and businesses called for a comprehensive approach to transition to a sustainable energy system, 
focusing  on  sector  integration  and  energy  vector  coupling.  They  emphasised  the  need  for  robust  risk 
preparedness, energy efficiency, diversified energy sources, and infrastructure protection. To enhance energy 
security,  they  suggested  leveraging  Ukrainian  gas  storage,  improving  EU  cooperation,  and  implementing 
measures like bilateral gas solidarity agreements. They also stressed the importance of maintaining undistorted 
price  signals,  mitigating  price  volatility,  and  integrating  renewable  gases  into  the  power  sector.  Companies 
urged the EU to prioritise renewable resources, develop investment schemes for storage solutions, and remove 
regulatory barriers to optimise Ukrainian gas storage use. They suggested revising EU gas tariffs and promoting 
cooperation with the UK, Norway, and Switzerland to enhance grid stability and address energy challenges. 
Ultimately, Europe should aim to build self-sufficient infrastructures to ensure a stable energy supply and avoid 
coercive pricing across borders. 

Public authorities, specifically the Hungarian Ministry of Energy, focused on expanding supply sources and 
routes, stressing the importance of long-term contracts and balancing energy security with competitiveness. The 
Ukrainian Ministry of Energy called for strengthened EU-Ukraine cooperation, advocating for amendments to 
regulations to enhance energy security and cross-border collaboration. 

Consumer  organisations  emphasised  the  strategic  and  ethical  importance  of  energy,  advocating  for  social 
responsibility  over  profit.  They  highlighted  the  need  for  regulatory  compliance  and  sustainable  practices, 
stressing adherence to the NEC Directive and securing EU funding.  

Non-governmental organisations (NGOs) called for a transition to a 100% renewable energy system by 2040, 
emphasising  energy  efficiency  and  demand  reduction.  They  supported  local  and  decentralised  energy 
production, infrastructure strengthening, and a socially just energy transition.  

Other  organisations  encouraged  a  comprehensive  EU  energy  security  strategy  that  integrates  renewables, 
modernises infrastructure, and diversifies supply chains. They stressed the importance of renewable energy and 
electrification, and the need for resilient supply chains and green hydrogen deployment.  

Finally,  EU  citizens  expressed  diverse  views  on  energy  security,  with  support  for  renewable  energy  but 
concerns about its current limitations. They advocated for energy diversification, nuclear investment, and long-
term storage solutions, highlighting geopolitical risks and the need for transparency.  

Public consultation 

The  public  consultation  received  a  total  of  114  responses.  Compared  to  the  Call  for  Evidence,  a  slightly 
different picture can be observed in terms of the identity of respondents. Whereas the Call for Evidence received 
a  large  share  of  feedback  from  citizens,  the  responses  largely  came  from  businesses  (44.7%)  and  business 
associations (22.8%), while only 7.9% came from EU citizens. Another noteworthy category includes public 
authorities (8.8%), of which half (5 out of 10) were national authorities and the remainder being local, regional 
or agencies. Very few contributions were submitted by academic/research institutions (2), consumer (1) and 
environmental (1) organisations, and other entities (5). No contributions were provided by non-EU citizens and 
Trade Unions.  

The vast majority of the respondents (99 out of 114) declared to be active in the energy sector, with 60 out of 
114 respondents being active in the gas sector, 56 active in the electricity sector and 16 being active in the oil 
sector. Around 20% of the respondents (23 out of 114) are Transmission System Operators. 

EN 

156 

  EN 

 
Figure 47: Share of contributions submitted by category of stakeholders 

Source: EC-JRC, 2024 

A total of 105 out of 114 respondents are considered to be organisations. Amongst them, around 50% are large 
organisations, 14.3% are medium-size organisations, 18.1% are small and 16.2% are micro-organisations. Of 
the  responding  businesses,  43  out  of  51  are  large  organisations  while  the  vast  majority  of  the  business 
associations (23 out of 26) are either micro or small organisations.  

The country of origin of respondents shows a variety of countries (23 countries in total, 5 non-EU), as is further 
detailed in Figure 50. The highest number of replies (28 out of 114) came from Belgium. This is due to the fact 
that most of the responding business associations (18 out 27), and NGOs (5 out of 9) are based in Belgium. 

The contributions received in the context of the public consultation published on the ‘Have Your Say’ web 
portal cannot be regarded as the official position of the Commission and its services and thus does not bind the 
Commission.  In  addition,  the  contributions  cannot  be  considered  as  a  representative  sample  of  the  EU 
population. 

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Figure 48: All respondents by country of origin 

Source: EC-JRC, 2024 

GENERAL QUESTIONS ON ENERGY SECURITY 

The EU Energy Security Framework received mixed evaluation from 114 respondents. While 30 respondents 
viewed  it  positively,  43  expressed  neutral  opinions.  Some  respondents  acknowledged  its  robustness  and 
coordinated response to recent crises, whereas others highlighted areas requiring improvement, such as the need 
for regulatory harmonisation across national and EU levels and over-reliance on fossil fuels. 

Need for Framework Revision 

In the respondents’ views, a revision of the current EU's energy security framework is necessary. Strengthening 
the  role  of  domestically  produced  renewables,  flexibility,  and  energy  sufficiency  and  efficiency  are 
considered  important.  The  revised  framework  should  also  focus  more  on  energy  consumption  reduction 
measures and consider climate mitigation and adaptation measures. 

A majority of respondents (53.5%, 61 out of 114) believe the current framework does not adequately incorporate 
climate risks. It is highlighted the need of transitioning to climate-resilient infrastructure through long-term 
investments  and  planning,  such  as  developing  underground  transmission  and  storage  systems,  enhancing 
electrical networks to withstand severe weather, and replacing overhead power lines with underground cables. 
The modernisation of aging infrastructure is also seen as crucial. In addition to infrastructure enhancements, 
there is a strong call for improved risk assessment and resilience planning, considering long-term climate effects, 
and involving climate experts in energy security planning. 

The consultation shows that the majority of respondents favour EU legislation as adding significant value to 
energy  security  through  coordination,  standardisation,  investment  in  infrastructure,  and  collective  action, 
which  surpass  the  capabilities  of  individual  Member  States  acting  alone.  There  is  a  general  trend  towards 
recognising the increased importance of EU-level action and coordination in energy security (74 out of 114, 
or  65%),  especially  in  light  of  recent  developments,  such  as  the  phase-out  of  Russian  gas  and  the  growing 
significance of LNG. Some respondents maintained that the importance remains equal (21%) given the existing 
rules  and  infrastructure,  while  a  few  others  suggested  a  decreased  importance  (2%)  due  to  the  rise  of 

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decentralised renewable energy production or environmental concerns. 12% of respondents had no opinion (14 
out of 114). 

The answers highlight that while Member States should retain flexibility, certain measures require a regional or 
Union-wide approach to be effective. Such measures include gas storage obligations, voluntary gas demand 
reduction,  provision  of  solidarity,  and  voluntary  joint  procurement.  EU-wide  coordination  is  deemed 
essential  to  create  efficiencies,  avoid  redundant  infrastructure,  and  ensure  a  coordinated  and  cost-effective 
system. The interconnected nature of the energy network in the EU means that the lack of security measures in 
one Member State can impact others, underscoring the need for common minimum standards. However, it is 
also noted that local measures are crucial for addressing region-specific needs and complementing the broader 
strategy. 

Based on feedback from 105 respondents, electrification has had mixed impacts on EU energy security. On 
one hand, it has reduced reliance on imported fossil fuels and facilitated the integration of renewable energy 
sources.  On the  other  hand,  it  has  increased  electricity  demand  and  dependence  on intermittent renewables, 
posing challenges such as grid stability and infrastructure demands. Respondents agree that while electrification 
is pivotal for energy transition and security enhancement, the current EU framework is insufficient to address 
their challenges, with improvements required in energy system integration, infrastructure, flexibility and storage 
solutions, energy source diversification, and regulatory and market mechanisms. 

A significant majority (103 out of 114, or 90.4%) of respondents agree that the EU energy security framework 
needs enhancements to effectively support a more electrified, renewable-based, and integrated energy system 
thus indicating strong consensus on the need for improvements to the current framework, and specifically 
for a comprehensive and forward-looking approach, which should address infrastructure, regulatory, and 
technological needs.  

Key recommendations from respondents include developing and modernising infrastructure, such as expanding 
grid capacity and integrating renewable energy sources, as well as diversifying energy sources and suppliers to 
reduce dependence. Implementing stable regulatory frameworks to attract investment, enhancing cybersecurity 
and digital resilience, and improving energy efficiency and risk preparedness planning are also emphasised. 
Decentralised renewable production and energy storage were also highlighted.   

Future Risks and Challenges 

The main objective deemed important for the EU energy security architecture is to accelerate investments into 
a domestic decarbonized energy system with 61% of the respondents supporting this goal. This is seen as 
crucial for achieving the EU’s energy independence and meeting climate objectives. Respondents advocate for 
accelerating the deployment of renewable energy sources, including wind, solar, and geothermal, along with 
the development of infrastructure necessary for electrification. The expansion of such systems is recognised not 
only  for  its  environmental  benefits  but  also  for  reducing  the  vulnerability  to  geopolitical  risks  and  market 
volatilities associated with fossil fuel imports. The second objective identified by 55% of the respondents is the 
diversification of energy sources, suppliers and routes to create a more resilient energy system so the EU 
can  circumvent  the  risks  associated  with  reliance  on any  single  supplier.  Strengthening  the  use  of  energy 
storage (49%) is identified as a key enabler for renewable energy integration and a buffer against supply shocks. 
Investments in diverse forms of energy storage, including batteries, pumped hydro, and thermal storage, are 
crucial for balancing supply and demand and providing backup power during peak periods. Additionally, the 
enhancement of interconnections and smartening of infrastructure between Member States are seen by 
40%  of  respondents  as  necessary  steps  to  improve  grid  efficiency,  responsiveness,  and  stability,  while  also 

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supporting  the  large-scale  integration  of  renewable  energy  sources.  Same  level  of  support  (40%)  has  the 
efficient use of existing infrastructure. These involves repurposing and upgrading current systems, such as 
gas networks, electricity grids, and LNG terminals to accommodate renewable energies, and new technologies 
like hydrogen, which is crucial for minimizing costs and accelerating the transition. Cybersecurity, identified 
by 36% of respondents, has emerged as a critical concern due to the increasing digitalization of energy systems. 
Stringent security measures are needed to protect against cyber-attacks, ensuring the integrity and reliability of 
the energy grid.  

The consultation highlights concerns regarding potential risks associated with increased reliance on liquified 
natural  gas  (LNG)  and  global  market  fluctuations.  Concerns  include  exposure  to  adverse  weather  events 
affecting LNG cargo arrivals, intra-EU competition for LNG leading to high prices, and the political instability 
of producers. These factors necessitate a diversified LNG infrastructure and careful planning to mitigate risks 
associated with global market dependencies. 

The  majority  of  respondents  (70  out  of  114,  or  61.4%)  believe  that  future  electricity  imports  from  third 
countries could pose energy security risks to the EU. This concern was shared across the various categories 
of stakeholders, indicating a widespread apprehension about the security implications of relying on external 
electricity sources. 
Many respondents emphasised the need to differentiate non-European countries based on political stability 
and their ties to the EU.  

Concerns were also raised about the vulnerability of infrastructure, particularly interconnectors, to cyber 
and  physical  attacks.  To  address  these  issues,  respondents  recommended  diversifying  electricity  sources, 
forming  long-term  partnerships  with  aligned  countries,  increasing  reliance  on  domestic  renewables,  and 
enhancing  the  internal  market  through  better  interconnections.  Investing  in  resilience  and  implementing 
capacity markets and flexibility services were also suggested.  

The consultation reveals a primarily positive outlook on the role of decarbonised and renewable hydrogen 
in the EU's energy security strategy, with 68% (78 out of 114 respondents) emphasizing its potential benefits 
such as  diversifying  energy  sources, supporting  renewable  integration,  and  aiding  in  decarbonizing  hard-to-
abate sectors. Nonetheless, concerns about hydrogen's cost, efficiency, environmental impacts, scalability, and 
potential import dependencies were noted, with some advocating for a technology-neutral approach prioritizing 
renewable hydrogen. Meanwhile, 21 respondents (19%) perceived hydrogen's role as limited, suitable only for 
specific  sectors  where  electrification  is  not  feasible,  expressing  scepticism  about  its  economic  viability. 
Regarding hydrogen supply security, risks identified include the underdevelopment of the renewable hydrogen 
market and infrastructure, import dependencies, and supply chain vulnerabilities.  

Additionally,  a  significant  majority  of  respondents  (83  out  of  114,  or  72.8%)  believe  that  enhancing 
international cooperation with close partners would be beneficial for the EU's energy security. In terms 
of  key  strategies  for  cooperation,  respondents  emphasised  the  importance  of  diversifying  energy  sources  to 
reduce dependency on single suppliers and mitigate supply risks. Additionally, ensuring regulatory compliance 
with EU standards and avoiding trade distortions was seen as essential for maintaining stable supply chains. 
Building long-term partnerships with countries such as the US, Norway, and Middle East and North Africa 
(MENA) region, as well as strengthening interconnectivity among EU Member States and prioritising domestic 
production of clean energy, while also importing from reliable partners, were also recommended. 

SPECIFIC QUESTIONS ON ENERGY SECURITY FRAMEWORK 

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Out of 114 respondents, 90 chose to answer the specific questions on energy security framework. The 
majority of contributors (87.8%, 79 out of 90) are active in the energy sector, while 12.8% are not. 
Participants that dropped out are primarily citizens and NGOs. 

EU-Level Action and Coordination 

The consultation revealed a generally positive perception of EU-level actions concerning preparedness and 
security of supply in the energy sector, with over half of the respondents (52 out of 90) agreeing or strongly 
agreeing that these actions have been beneficial. A small minority, 8.8%, disagreed/strongly disagreed, while a 
notable  24.4%  abstained,  indicating  some  uncertainty  or  lack  of  opinion  on  the  matter. Similarly,  EU-level 
actions  are  viewed  favourably  in  terms  of  increasing  coordination  and  transparency  among  Member 
States, with 56.8% (43 out of 90) expressing agreement or strong agreement. However, 10% disagreed, and 
again,  24.4% did  not  respond. By  contrast, the perception  of  EU-level  action's impact  on  reducing market 
distortions and spill-over effects in neighbouring countries is less favourable. Only 16.7% of respondents 
agreed  that  such  actions  have  been  effective,  while  the  largest  group,  35.6%,  neither  agreed  nor  disagreed, 
reflecting a significant level of ambivalence or uncertainty. Additionally, 27.8% did not provide a response, 
indicating a possible lack of clarity or understanding regarding the EU's role in addressing these complex market 
issues. This highlights an area where further efforts might be needed to enhance the perceived effectiveness and 
awareness of EU actions in mitigating market-related challenges.  

Regulatory Coherence and Gaps 

The consultation reveals diverse opinions regarding inconsistencies between the Gas Security of Supply and 
Storage  Regulation  and  the  Electricity  Risk  Preparedness  Regulation.  While  22.2%  (20  out  of  90)  of 
respondents perceive emerging inconsistencies hindering the achievement of regulatory objectives, 15.6% (14 
out of 90) believe the regulations are consistent and complementary. A notable portion, 38.9% (35 out of 90), 
did not express a specific opinion, and 23.3% (21 out of 90) provided no response. For improving coherence, 
respondents  suggested  creating  a  joint  energy  security  framework,  integrating  and  harmonizing  risk 
assessments,  and  adapting  regulations  to  reflect  the  growing  prominence  of  electricity  and  decarbonisation 
efforts.  Emphasizing cross-sectoral  integration,  reducing  administrative  burdens,  and  enhancing cooperation 
among stakeholders were also recommended.  

Nearly  half  of  the  respondents  (42  out  of  90)  indicated  that  strategies  exist  in  their  industry  or countries  to 
mitigate  the  impact  of  electricity  crises  on  gas  supply  and  vice  versa,  while  a  small  percentage  (5.6%) 
disagreed. 43 out of 90 respondents either did not have an opinion or abstained. Many respondents, particularly 
from 13 Member States detailed existing strategies, varying in  the level of deployment, like having in place 
emergency  plans,  sectoral  coordination,  renewable  energy  investments,  measures  to  protect  households  and 
critical infrastructure, and cybersecurity measures. 

The survey also found that one-third of respondents (30 out of 90) believe that the roles and responsibilities, 
as well as the coordination mechanisms between the electricity and gas sectors, are effective during crises, 
while 11 (12.2%) respondents did not. However, most of the respondents (49, 54.4%) were either undecided or 
abstained. Some respondents believed that national efforts are more efficient than EU-level efforts, others argue 
that EU-level mechanisms, such as information exchange and coordination among ENTSO-E and ENTSO-G, 
are effective. 

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Effective coordination is hindered by the independent treatment of the gas and electricity sectors, limiting real-
time cross-sectoral responses during disruptions. Furthermore, regulatory authorities and TSOs are considered 
to  have  limited  powers  in  addressing  longer-term  challenges,  and  emergency  plans  lack  testing,  creating 
uncertainty  about  their  effectiveness.  To  address  these  challenges,  it  is  essential  to  develop  integrated 
governance frameworks that address interdependencies between gas and electricity sectors. Long-term measures 
beyond  immediate  crisis  interventions,  such  as  sector  coupling  and  infrastructure  development,  are  also 
considered necessary. 

Future directions 

Out of 90 survey respondents, at least 50% see that regulatory synergies could be sought for the increasingly 
intertwined  electricity  and  gas  markets,  in  particular  in  the  areas  of  risk  assessments,  preventive  action, 
definitions  and  levels  of  crises,  crisis  management  procedures,  protected  customers  and  special  protection 
against disconnection, storage measures for energy security and regional cooperation and solidarity assistance. 
A minority of respondents (14 out of 90, 15.6%) have the opposite opinion, while the remainder of respondents 
either have no specific opinion or abstained. 

The  integration  of  various  energy  sources  and  sectors  is  becoming  increasingly  important  as  the  world 
transitions towards a more sustainable and efficient energy system. A coordinated approach to energy planning, 
taking into account the interdependencies between different energy sectors and sources, is essential for ensuring 
a secure and efficient energy supply. Improvements to the EU energy security framework are needed to tackle 
in particular cybersecurity risks associated with the further digitalization and smartening of energy networks 
and ensure the continuity of supply and security of supply. 

Out of 90 survey respondents, 38 (42.2%) see an additional or increasing role for demand-side measures in 
the future EU energy security architecture, on top of the already existing framework under the recently adopted 
Electricity Market Design. Most respondents acknowledged the crucial role of Demand-Side Response (DSR) 
in enhancing the energy system's flexibility and efficiency. A minority of respondents (11 out of 90, 12.2%) 
have the opposite opinion, while 41 respondents either have no specific opinion or abstained. Key proposals 
emphasised  the importance  of  integrating  various technologies  and  strategies to  optimise  energy  use.  These 
included  leveraging  storage  solutions  and  Power-to-X  technologies,  implementing  voluntary  and  automated 
demand-side measures in areas with high electricity consumption, fostering distributed generation, supporting 
energy  communities,  and  enhancing  interconnection  capacity.  Improving  energy  efficiency  and  consumer 
engagement  were  also  proposed,  alongside  ensuring  the  full  implementation  of  the  Electricity  Directive  to 
establish  consistent  demand-side  measures  across  all  Member  States.  Respondents  also  advocated  for 
implementing the Demand Response Network Code and dynamic pricing models, and the widespread adoption 
of advanced metering infrastructure. 

Although  no  respondents  opposed  demand-side  measures,  they  did  highlight  several  potential  challenges, 
including  cybersecurity  risks,  technological  hurdles,  market  distortions,  and  the  limitations  of  demand-side 
management in addressing periods of low renewable energy generation, such as "dunkelflaute" situations.  

SPECIFIC QUESTIONS ON GAS SECURITY OF SUPPLY 

Regulation evaluation 

Out of 114 respondents, 71 chose to answer the specific questions on gas security of supply. Out of the 71 
contributors, 64 are active in the energy sector, while 7 are not. 

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The  evaluation  of  Regulation  (EU)  2017/1938  (Gas  SoS  Regulation)  presented  mixed  satisfaction  levels 
regarding its effectiveness in ensuring security of gas supply. Of the 71 respondents, a notable portion (ranging 
from 18% to 23%) did not respond to the questions regarding the regulation's performance, suggesting some 
level  of  uncertainty  or  lack  of  familiarity  with  the  Regulation's  impact.  The  Regulation’s  performance  in 
securing adequate preparedness for gas supply disruptions and enhancing regional and EU-wide cooperation 
was  rated  as  good  or  excellent  by  46%  (33  out  of  71)  and  50%  (36).  This  indicates  a  reasonable  level  of 
satisfaction  with  how  the  regulation  is  perceived  to  assess  risks,  ensure  sufficient  infrastructure,  and 
foster collaboration across regions and the EU, particularly in times of supply emergencies. However, when it 
comes to the performance in safeguarding an uninterrupted gas supply to protected customers, only 31% (22 
out of 71) respondents rated the performance as at least good. This lower rating suggests that respondents may 
perceive gaps or challenges in the regulation's effectiveness in implementing necessary measures to ensure 
continuous gas supply to protected customers.  

The consultation reveals mixed perspectives on the relevance of the Gas SoS Regulation in addressing the 
EU's gas supply challenges, particularly during the 2022/2023 energy crisis. Some respondents acknowledged 
that  the  regulation's  provisions,  such  as  emergency  plans,  crisis  teams,  and  minimum  gas  storage  levels, 
contributed significantly to preparedness and market stabilization. However, they also noted limitations, such 
as the regulation's inability to fully address EU-wide supply crises or anticipate market manipulation by major 
suppliers. The Regulation's support for cross-border infrastructure and the Gas Coordination Group's role in 
fostering  cooperation  were  seen  as  positive.  Criticisms  included  the  ineffectiveness  of  joint  purchasing 
procedures and the need for further diversification away from Russian gas. While solidarity mechanisms  and 
risk assessments were considered beneficial, some respondents found them insufficient for the crisis's unique 
challenges. Calls for increased harmonization, infrastructure investments, and a shift towards renewable energy 
sources were emphasized as necessary steps for enhancing resilience and reducing dependency on volatile gas 
markets. 

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Figure 50: Effectiveness of specific provisions of the Gas SoS Regulation 

Source: EC-JRC, 2024 

The consultation respondents marked the majority of the specific provisions of the Regulation as effective or 
very effective in ensuring preparedness, security of supply and/or resilience. The provisions better rated 
were the Gas Coordination Group (by 61% of respondents), the Preventive Action Plans and Emergency Plans 
(55%),  the  infrastructure  standard  and  bi-directional  capacities  (53%),  and  the  crisis  levels  (50%).  On  the 
opposite  side,  the  annual  storage  trajectories  set  by  the  Commission  (rated  as  marginally  effective  or  not 
effective at all by 32% of the respondents) and the solidarity provisions (31%) are the provisions perceived as 
less effective. 

Implementation Challenges and Unintended Effects 

53.5% (38 out of 71 respondents) declared having experienced barriers or difficulties in implementing and 
enforcing the  provisions of  the  Regulation.  Respondents  identified difficulties  particularly  in the areas  of 
solidarity  provisions,  storage  filling  targets,  gas  supply  standards,  and  bi-directional  capacities.  Solidarity 
provisions  are  hindered  by  implementation  difficulties,  operational  complexity,  and  unclear  procedures, 
highlighting the need for more defined mechanisms. Respondents argued that storage filling targets, set hastily, 
have disrupted markets and raised costs, prompting calls for more flexible, regionally coordinated approaches. 
The  gas  supply standard is criticized  for its  vagueness,  with  suggestions to  extend  protections  beyond the 
current definition of protected customers. Bi-directional capacities lack clarity, especially concerning virtual 
interconnection  points.  Additional  concerns  include  gaps  in  preparedness  and  emergency  plans,  market 

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disruptions from uncoordinated measures, infrastructure deficiencies, administrative burdens, and misalignment 
with decarbonisation goals.  

The majority of respondents, 36.6% (26 out of 71), indicated no unexpected and/or unintended effects caused 
by the implementation of the Regulation, while 23.9% (17 out of 71) pointed out the opposite. The majority 
of  the  views  identified  the  gas  storage  level  targets,  noting  that  the  abrupt  implementation  of  these  led  to 
reduction of market flexibility, price spikes, and administrative burdens, calling for more coordinated, market-
aligned solutions. Other views pointed out at differences in risk assessments and regulatory standards across 
countries,  causing  delays  due  to  the  need  of  extensive  bilateral  agreements.  It  was  voiced  that  the  narrow 
definition of protected customers’ needs revision because it could lead to exclude essential industries from 
access to gas during crises. 

 Only  9  out  of  71  respondents  indicated  that  some  provisions  within  the  Gas  SoS  Regulation  proved  to  be 
inconsistent with one another. The majority of respondents, 22 out of 71, did not found provisions inconsistent. 
The general evaluation highlighted the challenges in balancing energy security with climate goals and the need 
for more coherent and transparent regulatory frameworks.  

Cost-Benefit Analysis and Burden: 

The Storage Regulation has been generally praised for enhancing the EU's gas supply security by establishing 
clear, measurable targets and fostering cooperation among Member States. This has helped mitigate market 
volatility  during  energy  crises  and  ensured  a  stable  supply  to  citizens.  However,  the  regulation's  rigid  90% 
storage  targets  and  filling  trajectories  are  criticized  for  potentially  leading  to  high  costs, limiting  storage 
flexibility, and not accounting for regional differences. The sunset clause in 2025 has sparked debate, with some 
advocating  for  its  extension  to  ensure  long-term  supply  stability,  while  others  call  for  more  market-based 
approaches to avoid competitive distortions and inflationary pressures. 
Concerns also revolve around the complexity of the certification procedure for Storage System Operators and 
the need for fair burden-sharing mechanisms to avoid placing unfair costs on specific countries. There is a call 
for more flexibility for Member States during national emergencies and for addressing the lack of measures to 
compel entities to meet storage mandates.  

Respondents recognise the Gas SoS Regulation's role in enhancing overall energy security and robust crisis 
management processes across the EU, although they emphasize the need for improvements in cost allocation 
and regulatory clarity to fully realize its benefits. By establishing storage targets and mechanisms, the regulation 
has reduced the risk of supply disruptions, contributing to the stability of industries and minimizing the impact 
of energy supply cuts on citizens. Tools like the Security Platform Gas (Trading Hub Europe) and the ReCo 
system (ENTSOG) have facilitated transparent information flow and coordinated responses to critical supply 
situations.  However,  these  benefits  come  with  challenges,  such  as  increased  operational  costs  and  market 
distortions. The high costs associated with filling storage targets, especially in response to geopolitical tensions, 
have led to significant economic burdens and price increases, sparking calls for more sustainable cost recovery 
mechanisms. 

On the downside, the regulation's implementation has faced criticism over the administrative burden it places 
on organizations and the lack of clear guidelines in the Solidarity Mechanism, leading to potential market 
inefficiencies and competition hindrances. Market correction mechanisms remain untested and controversial, 

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with concerns about their effectiveness during supply chain disruptions. Additionally, regulatory uncertainty 
and infrastructure gaps pose challenges to the development of hydrogen storage.  

Regulatory Adaptation and Future Directions: 

Respondents proposed several measures to simplify the Gas SoS Regulation's reporting and monitoring 
requirements.  A  key  suggestion is  the  creation  of  a centralized  digital platform  for  submitting  all  required 
documentation,  which  would  standardize formats,  facilitate information  sharing,  and  prevent  duplication  by 
enabling  data  reuse.  Simplifying  the  content  of  preventive  action  plans  to  focus  on  essential  data  for  risk 
assessment and establishing standardized templates for reports are considered crucial steps. Respondents also 
emphasize eliminating redundancy, particularly where reporting overlaps with obligations under Security of 
Supply and REMIT regulations. Simplifying the process for reverse flow exemptions and revaluating public 
disclosure of some documents to avoid inadvertently increasing security risks are additional recommendations. 
While some respondents support reducing the frequency of common risk assessments and making preventive 
action  plans  voluntary,  others argue  for maintaining current  4-year  frequency to  provide  time  for  necessary 
improvements.  

In  the  consultation,  the  regulation  is  praised  for  enhancing  energy  security  and  market  integration,  with 
provisions like emergency plans and storage targets contributing to preparedness against supply disruptions. 
However, there are challenges, such as the need for updates to better align with the EU's decarbonization 
objectives,  including  the  phasing  out  of  fossil  fuels  and  increasing  the  role  of  decarbonized  gases  like 
biomethane and renewable hydrogen. This includes adapting the regulation to support the decreasing use of 
natural gas while maintaining a high level of security of supply during the transition phase. Suggestions are to 
consider establishing a common EU strategic gas reserve and integrating biomethane production targets. 

Respondents  emphasize  the  need  for  efficient  use  of  infrastructure,  improved  cost-sharing  mechanisms 
among Member States, and addressing challenges related to infrastructure sabotage and geopolitical influences. 
Some respondents propose the establishment of a common EU strategic gas reserve. 

Additionally, respondents indicated that more efforts are needed to strengthening solidarity and coordination 
mechanisms, clarifying roles and responsibilities during crises, and ensuring cooperation among Member States 
to ensure the application of non-market emergency measures occur under clear define conditions to avoid market 
fragmentation. Furthermore, there is a need for cybersecurity enhancements to protect energy infrastructure. 

SPECIFIC QUESTIONS ON ELECTRICITY SECURITY OF SUPPLY 

Out of - 114 respondents, 50 chose to answer specific questions on Electricity Security of Supply. Among them, 
45 (90%) are active in energy sector while five (10%) are not.  

Regulation evaluation 

Respondents believe that Electricity Risk Preparedness Regulation (Regulation (EU) 2019/941) proved relevant 
in  addressing  energy  crises,  with  its  provisions  on  detection,  alert,  and  coordination  being  effective  in 
responding to crises such as the COVID pandemic and the 2022-2023 energy crisis. It has strengthened cross-
border interconnections, integrated renewables, and enhanced risk assessment and planning, enabling quicker 
disruption responses.  

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Respondents generally view the Regulation’s performance in meeting its objectives as positive, with varying 
degrees  of  success.  The  Regulation's  performance  on  improving  transparency  and  information  sharing,  and 
coordination  in  electricity  crises,  received  the  most  positive  feedback.  It  also  received  a  generally  positive 
assessment on improving prevention and preparedness, albeit with a slightly more neutral tendency. On the 
contrary, the Regulation's performance on reducing the risk of negative spillover effects was viewed as mostly 
neutral,  with  a  slight  negative  inclination.  .  Its  inflexibility  and  gaps  in  cross-border  cooperation  were  also 
highlighted, with some respondents proposing a midterm reassessment every two years to adapt it to changing 
risks. To enhance crisis management, respondents suggest improvements such as harmonized EU-level actions, 
clearer  guidelines,  stronger  cross-border  coordination,  incorporating  local  capacity  measures,  scenarios  for 
prolonged  conflicts,  and  addressing  blackout  risks.  They  also  recommend  enhancing  communication, 
transparency,  and  cooperation  between  Member  States,  and  linking  Risk  Preparedness  Plans  with  other 
initiatives. 

Overall,  the  Regulation's  effectiveness  depends  on  Member  States'  actions.  While  it  has  facilitated  internal 
energy  balancing  and  regional  coordination,  it  has  not  fully  mitigated  the  impacts  of  the  energy  crisis  on 
electricity prices and consumer financial burdens. EU intervention is seen as crucial for enhancing security of 
supply, promoting cross-border coordination, and fostering integration, with a unified EU strategy needed to 
address the interconnected European electricity system, and coordinated regional scenarios, joint responses, and 
a common crisis approach. 

On the specific provisions of the Electricity Risk Preparedness Regulation, some are seen as more effective than 
others  in  ensuring  preparedness,  security  of  supply,  and  resilience.    Provisions  such  as  National  Risk 
Assessments and Risk preparedness plans as regards national measures were considered quite positive, while 
those related to regional and bilateral measures were viewed as rather negative.  

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Figure 51: Effectiveness of specific provisions of the Electricity Risk-Preparedness Regulation 

Source: EC-JRC, 2024 

Respondents  emphasised  the  need  for  a  more  integrated  and  transparent  Regulation,  improved  crisis 
management,  and  enhanced  cooperation  among  Member  States  to  address  the  complexities  of  the  energy 
market.  They  highlighted  areas  for  improvement,  including  the  definition  of  an  electricity  crisis,  resource 
adequacy,  system  sustainability,  and  managing  renewable  intermittency.  Respondents  also  criticised  the 
Regulation for unclear integration of Risk Preparedness Plans, limited operational impact, and lack of alignment 
with other regulations.  

Regarding  Article  15's  framework  for  cooperation  and  assistance,  the  general  opinion  was  neutral,  with 
respondents suggesting that the framework is fundamentally adequate but in need of more harmonization and 
expanded  applicability.  They  advocated  for  improved  cooperation,  solidarity,  and  mutual  assistance  among 
Member States, and suggested various improvements, including binding mutual assistance, clearer emergency 
coordination procedures, and strengthened local decrees. Overall, the respondents emphasized the importance 
of balancing cooperation and self-reliance in crises, and suggested formalizing regional agreements, enhancing 
cross-border interconnections, and regular framework updates to enhance the effectiveness of the Regulation. 

Implementation Challenges and Unintended Effects 

The  majority  of  respondents  (75%)  reported  no  unexpected  negative  effects  from  the  Regulation's 
implementation, indicating a positive impact on achieving its objectives. However, the implementation of the 
Regulation has been hindered by national emergency measures, which have fragmented the Internal Energy 
Market, disrupted trade, and impacted liquidity and renewable energy investments. Respondents highlighted 

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inconsistencies, distortion of trade, and strain on grid stability resulting from the rapid growth of renewable 
energy. To address these challenges, respondents recommend increasing transparency and dialogue among EU 
Member States, improving information sharing, and prioritising significant risks to inform better policy and risk 
management. 

The Regulation is generally seen as aligned with other EU policy goals, such as the EU Green Deal and Fit for 
55  initiatives,  but  some  respondents  note  that  it  may  not  fully  align  with  all  EU  policy  goals,  particularly 
regarding decarbonisation, system resilience, and climate neutrality. A slight majority of respondents see no 
inconsistencies between the Regulation and other EU legislation, although some identify inconsistencies with 
the Electricity Market Design (EMD) and other EU laws. Some of those identified are related to the Article 66a 
of the EMD - Access to affordable energy during an electricity price crisis and 70% requirement for cross-
border trade, including the issue that some non-EU countries, although quite interconnected such as Switzerland, 
can face ambiguity in the treatment of the 70% rule. Most respondents do not see any inconsistencies between 
provisions in the Regulation, although some identify inconsistencies between short-term crisis rules and long-
term capacity planning needs. 

Respondents suggest improving the Risk Preparedness Plans (RPPs) by enhancing transparency, stakeholder 
engagement,  and  incorporating  detailed  assessments  of  emerging  threats.  They  recommend  a  flexible 
framework for quick updates, simplified reporting, and clearer guidelines, while cautioning against a "one size 
fits all" approach. Comprehensive scenarios, including blackouts, should be covered with thorough analysis and 
mitigation strategies. Ensuring confidentiality, learning from international experiences, and maintaining stable 
methodologies for consistent risk assessment comparisons are also emphasized. 

The Regulation is considered relevant, but respondents emphasize the need for it to adapt to the evolving threats 
landscape, EU's electricity supply, and energy mix. They highlight the importance of addressing climate change, 
in  planning. 
technological  advances,  decentralization,  cybersecurity,  and  demand-side  management 
Respondents  also  stress  the  need  for  comprehensive  capacity  evaluations,  pan-European  actions  to  manage 
crises, and a more significant role for transmission system operators, power generators, and distribution system 
operators in planning. Overall, respondents agree that the Regulation remains relevant but needs to be updated 
to address the changing energy landscape and emerging risks, and to ensure full alignment with EU policy goals 
and legislation. 

Cost-Benefit Analysis and Burden 

The implementation of the Electricity Risk Preparedness Regulation has had varying costs and benefits, with 
some  respondents  reporting  minimal  operational  impact  and  cost  burden,  while  others  required  significant 
resources to implement Risk Preparedness Plans. The estimated costs ranged from 0.2 FTE workload to 1 FTE 
for 1.5 years, with additional costs for regional scenarios and studies. However, the Regulation also brought 
benefits, including a structured framework for measures, consistency, resilience, and enhanced EU coordination. 
Security of Supply, cooperation, market stability, reputation, trust, better risk strategy learning, and information 
exchange were also mentioned as Regulation’s benefits. 

Respondents  generally  considered  the  Regulation's  provisions  to  have  a  low  to  average  impact  on  creating 
disproportionate burdens. Most provisions were deemed to have a "Negligible" or "Low" burden. However, 
some provisions, such as "Risk preparedness plans as regards national measures" and "Risk preparedness plans 
as regards regional and bilateral measures", were considered to have a slightly more significant impact.  

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Respondents  also  emphasised  the  importance  of  streamlining  processes,  ensuring  fair  compensation,  and 
improving  regional  cooperation  to  enhance  the  effectiveness  of  the  Regulation  and  reduce  the  burden  on 
companies and authorities. They suggested simplifying National Risk Assessments and Preparedness Plans to 
improve  efficiency  and  reduce  strain  on  resources  and  advocated  for  simplifying  'early  warning  and  crisis 
declaration'  processes  for  quicker  emergency  responses.  Overall,  the  respondents  acknowledged  that  the 
Regulation  has increased  energy  security  awareness, but  the  cost-benefit  analysis  is  still  premature.  Further 
quality improvements are needed to assess the Regulation's effectiveness. 

Regulatory Adaptation and Future Directions 

Respondents expressed neutral opinions on the timeliness and efficiency of the Risk Preparedness Plans (RPP) 
administrative process, but generally agreed that a four-year update cycle for RPPs is appropriate. The process 
could  be  improved  by  adopting  a  more  tailored  approach  to  scenario  planning,  extending  the  lead  time  for 
calculations,  and  aligning  procedural  requirements  with  other  risk  analyses.  They  emphasised  the  need  for 
clearer guidelines for ad-hoc updates, better alignment between EU and national  timelines,  and stable crisis 
scenarios for consistent monitoring and evaluation. 

The respondents largely agreed that the RPP administrative process that could be improved. To streamline and 
enhance  the  process,  they  proposed  several  enhancements,  including  the  use  of  digital  tools  to  facilitate 
collaboration, the establishment of stable crisis scenarios for consistent monitoring, and the alignment of the 
update cycle with other plans. They additionally emphasised the importance of adopting a more decentralized 
and participatory approach, involving national power generators and reflecting national specifics. 

The was a general consensus on among respondents that the Electricity Risk Preparedness Regulation needs to 
be better adapted to the technological, scientific, environmental, and climatic challenges facing the EU. They 
emphasised the need for a more dynamic and flexible approach to risk preparedness, with a shift from a top-
down to a bottom-up planning approach that incorporates regional and national specifics. They highlighted the 
importance of keeping pace with rapid technological advancements, evolving environmental challenges, and 
integrating new technologies. 

The respondents largely supported the idea of establishing a common definition of electricity crisis applicable 
to all Member States. This definition should be based on common criteria such as the severity and duration of 
supply  disruptions,  impacts  on  essential  services,  and  cross-border  implications.  A  standardized  definition 
would ensure EU-wide harmonisation and coordination, while allowing Member States the flexibility to address 
specific situations. 

A slight majority of respondents supported a revision of the definition of regions in Article 2 of the Regulation. 
They suggested that the current definition, based on Regional Coordination Centres (RCCs), could be improved 
by incorporating additional criteria such as System Operation Regions (SORs), technical, geographical, and 
climatological characteristics, TSO cooperation, and historical ties with third countries. They emphasised the 
need  for  a  more  adaptable  approach  to  account  for  energy  sector  changes,  technological  progress,  and 
geographical interconnections. 

Overall, the respondents agreed that improvements to the RPP administrative process are necessary to enhance 
its effectiveness and efficiency, and that the Regulation needs to be more proactive and adaptive to address the 
emerging  challenges  and  ensure  the  resilience  of  the  electricity  grid.  They  highlighted  the  importance  of  a 
common  definition  of  electricity  crisis,  a  more  flexible  and  inclusive  definition  of  regions,  and  a  more 
decentralised and participatory approach to risk preparedness. 

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Additional comments 

The respondents provided additional comments on the general functioning and future evolution of the Electricity 
Risk  Preparedness  Regulation,  emphasizing  the  need  for  dynamic  and  adaptable  regulations  that  prioritize 
climate risks and emerging threats. They stressed the importance of stronger collaboration between Member 
States and industry stakeholders to enhance energy system resilience and develop proactive strategies to mitigate 
climate-related  risks.  The  respondents  also  highlighted  the  need  for  increased  reliance  on  domestic  and 
European energy sources, transitioning to 100% renewables, and digitalizing electricity supply. They criticized 
the  current  legislation  for  insufficiently  addressing  energy  infrastructure  security  and  advocated  for  clear 
guidelines, collaborative frameworks, and robust cooperation protocols among Member States. The respondents 
also emphasised the necessity of including countries and municipalities in electricity risk preparedness, focusing 
on  large  storage  facilities  and  aged  power  plants,  and  highlighted  the  importance  of  integration  with  new 
technologies,  smart  grids,  and  enhanced  cybersecurity.  Overall,  the  respondents  agreed  that  the  Regulation 
needs  to  be  more  proactive  and  adaptive  to  address  emerging  challenges  and  ensure  the  resilience  of  the 
electricity grid, and that continuous monitoring and assessment are necessary to keep the regulation aligned 
with evolving threats. 

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Individual stakeholder events 

At the Regulatory Roundtable organised by DG ENER in Budapest on 6 December 2024, a dedicated session 
was held on ‘crisis management and access to affordable energy’. The session concluded254:  

“The EU energy security framework aims to ensure a stable and secure energy supply, with a clear focus 
on protecting consumers. The Roundtable takes note of the Commission’s plan to review the framework to 
ensure it offers adequate protection to both citizens and industries in a more decarbonised, electrified and 
integrated energy system. This includes updating the concept of protected customers so that it is adapted to 
changing consumption patterns, while demand response should be better incorporated in energy security 
policy.” 

In addition, on 15 November 2024, DG ENER was invited to speak at a breakfast organized by Energie@Bxl, 
a French-speaking network of energy policy experts, to exchange on the Security of Supply public consultation. 
DG ENER made a presentation about the process to review the energy security framework, and then exchanged 
with the participants about the functioning of the framework and the possible future challenges. 

DG  ENER  also  participated  to  the  following  events,  where  the  fitness  check  was  discussed:  Pentalateral 
Energy Forum’s workshop on 16 January 2025 on “The future coordination of reliable capacities”. 

Eurobarometer 

In September 2024, a new energy Eurobarometer was published, asking about the past and future of EU energy 
policy. While this Eurobarometer was not tailored to all the specific questions that this fitness check seeks to 
answer, it is a useful tool to gauge the general views among citizens.  

Interesting examples from the Eurobarometer include: 

Reducing energy imports and increasing energy independence was considered by 26% of respondents the main 
future  priority  of  energy  policy,  which  was  third  highest.  The  second  highest  was  ‘decreasing  energy 
consumption’ (27%), which in fact was one of the policy instruments used to address the energy crisis. 

When asked about what EU energy policy means to respondents, 22% said preventing electricity black-outs and 
energy shortages, which jumped up from just 7% in 2019. Other policy areas directly relevant to energy security 
also saw a big jump from 2019 to 2024, such as improving energy infrastructure (from 8% to 27%), decreasing 
energy consumption (from 2% to 30%).  

254  Work begins on the Citizens Energy Package to ensure a fair and inclusive energy transition 

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Figure 52: responses to the question: ‘in your opinion, which of the following energy-related issues 
should the European Union tackle as a priority over the next five years  

Source: Special Eurobarometer 555, September 2024. 

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ANNEX VI. STRATEGIC FORESIGHT - MEGATRENDS WORKSHOP 

The EU's energy security is facing unprecedented challenges, exacerbated by recent shocks and 
crises  such  as  the  Covid-19  pandemic  and  the  war  in  Ukraine.  In  response,  the  Commission's 
Directorate-General  for  Energy  (DG  ENER)  has  launched  a  fitness  check  of  the  EU's  energy 
security  of  gas  and  electricity  supply  (evaluating  in  particular  Regulation  (EU)  2017/1938 
concerning measures to safeguard the security of gas supply and a Regulation (EU) 2019/941 on 
risk-preparedness in the electricity sector). In this context, it is relevant to identify potential risks 
and opportunities for energy security arising from long-term megatrends. The JRC has identified 
14 Megatrends that are likely to have profound impact on the EU’s society in the medium to long-
term  future  (i.e.  2040  and  beyond)255.  Those  Megatrends  were  the  methodology  used  in  the 
foresight workshop that took place on 17 October 2024.  

The foresight workshop was structured in three parts. Participants were split in six groups for the 
discussions. First, the participants mapped all Megatrends based on their relevance and awareness. 
In a second step, Megatrends in the high relevance/low awareness quadrant were selected for more 
detailed  discussions  to  explore  the  potential  consequences  of  the  trends  on  the  EU’s  energy 
security. The selection criteria were relevance, paired with lack of awareness among the energy 
security expert community. Although results differed per group, the megatrends that were ranked 
as having the most relevance and least awareness by participants overall, were i) increasing pace 
of technological change, ii) aggravating resource scarcity and iii) the increasing significance of 
migration. The third part of the workshop focused on analysing the policy implications of these 
megatrends. Some of the key results were:  

Workshop  participants  highlighted  the  potential  risks  related  to  an  accelerating  pace  of 
technological change and the potential consequences of it on the EU’s energy security, such as the 
risks stemming from the use of AI. As a policy response, participants noted that the EU should be 
prepared for such instances and have adequate monitoring mechanisms developed that reduce these 
risks.   

Increasing instability of global geopolitics and EU’s dependence on technology and critical raw 
material  imports,  but  also  fossil  fuels  (e.g.,  LNG),  from  third  countries  may  increase  risks  to 
security  of  energy  supply.  As  a  policy  response,  participants  highlighted  the  need  to  invest  in 
strategic autonomy, including through circularity. At the same time, there is a need to strengthen 
relations with strategic partners around the world. In context of the changing security paradigm, 
also strengthening defence for protection of critical infrastructure was mentioned.  

Another aspect highlighted by participants was the access of the most vulnerable groups to energy 
in times of crisis. Those groups are the least likely to invest in independent energy backup solutions 
(e.g. solar panels, batteries, heat pumps) to offset more exposure to energy supply disruptions and 
energy price fluctuations.  

255  https://knowledge4policy.ec.europa.eu/sites/default/files/Megatrends%20briefing%20file.pdf 

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Figure 52: Relevance and awareness of the 14 megatrends (consolidated outcome of 
all six groups)256 

The  Megatrends  workshop  has  mapped  the  most  prominent  risks,  consequences  and  potential 
policy  implications  of  the  underexposed  Megatrends  on  EU’s  energy  security.  However,  the 
approach was holistic and more focused analysis is needed in order to derive more concrete policy 
recommendations.  Further  foresight  exercises  could,  for  instance,  deploy  the  JRC  Foresight 
Scenarios tool257. 

In addition, to triangulate the results, in the public consultation a question was asked to respondents 
to rank the most relevant megatrends for security of gas and electricity supply. The results of this 
ranking can be found in the figure below.  

256  Figure 53 is a consolidation of the Megatrends mappings done by the six groups during the workshop. For each 
group, each megatrend had a numerical value assigned to it (one value for Relevance and another for Awareness, 
based on the position in the map. The values ranged from 1-3, with 1 signifying Low Relevance/Awareness, 2 for 
Medium Relevance/Awareness, and 3 for  High Relevance/Awareness. For example, for Group 1,  Shifting health 
challenges had values (2,2) assigned (see the Annex to view Group 1’s map). After every Megatrend per Group had 
a  value  assigned,  the  values  of  the  two  axes  were  averaged  out.  For  example,  the  final  outcome  for  the 
aforementioned Megatrend was (2;2.17). Subsequently, all Megatrends were mapped onto the consolidated map 
according to the consolidated values. 

257  https://publications.jrc.ec.europa.eu/repository/handle/JRC132943 

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Figure 53: Megatrends for which the EU energy security architecture is considered 
to be least prepared for (N = 76) 

Source: Joint Research Centre, based on the public consultation 

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