Energinet backs full-cost balancing on polluter-pays principle

Energinet published its position on full-cost balancing in March 2024, calling for a strict polluter-pays framework in which each balance responsible party covers the costs its own imbalances generate. The TSO's core argument: socialising balancing costs blunts the financial signal that should incentivise accurate scheduling and real-time self-correction.

The position lands in the context of Energinet's ongoing balancing reform agenda. In September 2023 the TSO released an implementation guide for aFRR energy activation mechanism (EAM), and it has amended its countertrade energy procurement methodology at least twice (in December 2021 and again in December 2022), indicating sustained regulatory activity around both reserve procurement and congestion management.

For market participants active in the DK1 and DK2 bidding zones, the full-cost balancing stance raises the practical question of how imbalance settlement prices would be restructured if the position advances to a formal methodology proposal. No timeline for regulatory adoption has been indicated in the materials published by Energinet.