CEER Response to the European Commission’s Call for Evidence: Revision of the EU Energy Security Framework

The Council of European Energy Regulators (CEER) has published its response to the European Commission’s Call for Evidence for an Impact Assessment on the revision of the EU framework for security of energy supply (SoS).

In its submission, CEER welcomes the opportunity to contribute to shaping Europe’s future energy security architecture. CEER highlights that effective implementation of the existing rules, especially those ensuring cross-border cooperation, should remain the top priority of the forthcoming legislative review. Rather than proposing entirely new legislation, CEER underlines the importance of guidance, clarity, and practical implementation to make existing provisions fully operational under both normal and crisis circumstances. CEER’s response draws on the lessons learned from the 2022-2023 energy shocks and from the application of current SoS regulations.

CEER’s position focuses on five key areas that merit particular attention in the forthcoming legislative revision:

1. Consumer protection - Safeguard system stability and societal continuity by defining minimum protection levels for customers and improving cross-border coordination of preventive and emergency plans. Support affordability and competitiveness through targeted measures without distorting market signals.
2. Non-market-based measures and solidarity - Clearly define the “turning point” between market-based and non-market-based actions in crisis situations. Ensure that solidarity mechanisms operate only when markets can no longer function effectively, with clear and operational procedures set out in “the plans”.
3. Role of market actors during declared emergencies - Clarify the roles and responsibilities of TSOs, DSOs, LNG operators, and storage operators during crises. Encourage the use of auction mechanisms and adaptive balancing schemes to reallocate energy during shortages efficiently while maintaining contractual neutrality.
4. Price signals and price risks - Maintain strong price signals to support demand response and attract new energy sources. Avoid price caps that distort markets. Instead, address affordability through direct support. Establish fair compensation schemes for cross-border solidarity and flexibility investments.
5. Physical and virtual (demand-response) energy storage - Recognise the crucial role of both physical storage and demand-side flexibility as buffers for energy security. CEER supports flexible, market-based storage mechanisms and the inclusion of demand response in SoS planning.

CEER underlines that the gas and electricity SoS frameworks should be streamlined and consistent, but not merged, as each system has distinct characteristics and interdependencies. Effective coordination between the two will be crucial for managing crises and advancing Europe’s decarbonisation and electrification goals.

CEER reaffirms its commitment to working closely with the European Commission, ACER, and all stakeholders throughout the legislative process to ensure that the revised framework is practical, proportionate, and future-proof.