Energy

KEY DEVELOPMENTS

Capacity Market

Challenges were successfully taken to decisions to exclude several bidders from participating in the 2028/2029 T-4 Capacity Auction. Further detail is available in our briefing: Electricity Update: Capacity Market Ruling.

Offshore

It has been reported in the Business Post that the Government is developing a change in approach to offshore development by identifying multiple DMAPs in a roadmap for the development of offshore renewable energy generation and by considering pilots for floating offshore wind projects.

RESS 5

The provisional timetable for the fifth onshore renewable electricity support scheme indicates that final auction results are anticipated in September 2025.

Onshore Grid Connections

In 2024 the CRU published the new connection policy for onshore generation and system services, which we looked at in our briefing: New Connection Policy for Onshore Generators and Storage. The CRU is now consulting until 25 April 2025 (extended from 11 April 2025) on charging and rebating policy (CRU/2025/38). EirGrid is proposing to implement the following:

a streamlined charging model and ‘menu’ of charges,
a rebating methodology where contested assets could facilitate the connection of subsequent customers,
the ability for EirGrid to recover “the unreasonable cost of TSO and TAO oversight time for contested connections that are inefficiently delivered”, and
there will be no change to the current developer payment schedule layout within the Joint TSO/DSO Group Processing Approach Charging and Rebating Principles v2.0 document.

The CRU also announced an ECP-2.5.1 process, which we looked in our briefing: Energy Update: Flash application window for Onshore Grid Connection.

Roads Guidance on Grid Development

The Department of Transport published:

Electricity Transmission Infrastructure Development - Roads Sector Engagement Framework intended to establish protocols between EirGrid, ESBN, and Road Authorities for projects that have the potential to impact public roads, and
Interim Guidance to Road Authorities (placement of Medium or High Voltage electricity assets) intended to assist Road (Local) Authorities in their role relating to proposed placement of assets, including ducts, cables and associated infrastructure.

Guarantees of Origin in Gas

The CRU is consulting until 22 May 2025 on a Supervisory Framework for Guarantees of Origin for Renewable Gas for grid-injected gas. It is intended to cover registration, issuance, transfer, and cancellation of gas GoOs by electronic means. The CRU indicates it should coincide with policy measures to develop a biomethane industry of scale in Ireland. For related amendments to domestic regulations, please see below under ‘Further Domestic Developments’.

Climate Action Plan 2025

The Government published the annual update to the Climate Action Plan. Actions for 2025 include publishing a long duration energy storage procurement recommendations paper. Actions also include development of a smart-flex standards roadmap and consumer-led flexible demand process. It is intended to review and revise the National Ports Policy. Legacy actions carried over from previous Plans are listed at the end of the Annex of Actions (including development of a private wires policy).

CBAM

An Implementing Regulation on conditions and procedures related to the status of authorised CBAM declarants applies from 28 March 2025. The details are available in our briefing: New Rules indicate Lead-in Time to obtain Authorised CBAM Declarant Status.

EU DEVELOPMENTS

Renewable Energy Directive

The European Commission sent letters of formal notice to 26 Member States (including Ireland) for failing to fully transpose provisions of RED III (which includes timelines for the permit-granting process for renewable energy projects). Member States have two months to respond, complete their transposition and notify their measures to the Commission. In the absence of a satisfactory response, the Commission may decide to issue a reasoned opinion.

Electricity

Trading with UK: Recommendation 1/2024 on technical preparations for trading over the interconnectors has been finalised.
Security of Supply: Decision 2/2024 of the Specialised Committee on Energy under the TCA establishes a Work Group on Security of Supply between the EU and UK.
Intraday Market: ACER amended rules to align the single intraday coupling (SIDC) products methodology with the single day-ahead coupling (SDAC) products methodology. This means that electricity can be traded in 15-minute intervals in both day-ahead and intraday markets. Ireland will rejoin the market when the Celtic Interconnector is available.
Demand Response: ACER identified 12 key points to remove barriers to demand response, including stronger price signals and wider adoption of smart meters.
Power Purchase Agreements: To support market participants and facilitate PPA contracting, ACER is gathering and publishing a list of publicly available templates.
Network Tariffs: In a report on how network tariffs are set across the EU and allocated across different network users, ACER sets out principles for cost-reflective tariffs.
Harmonised Allocated Rules: ACER is consulting until 22 May 2025 on updates to the Harmonised Allocation Rules for long-term transmission rights.
Resource Adequacy: ENTSO-E’s annual assessment identifies risks and calls for proactive measures to incentivise necessary investment.
Emerging Technologies: ENTSO-E updated Technopedia, intended to provide insights on emerging technologies for the grid.
Policy Development: The European Economic and Social Committee published it view of how pricing and supply in the electricity market could be reformed over the medium to long term.

Gas

Storage: The Council agreed its position on the legislation to extend by two years Member State obligations to have gas storage facilities 90% full before the winter season.
AggregateEU: The outcome of the second mid-term round for joint gas purchasing aggregated 29 bcm of demand for gas, and 31 bcm of offers. Participants may now negotiate contracts bilaterally.
Post-Brexit Working Arrangements: ENTSOG and the UK TSOs finalised working arrangements, valid until June 2026.

Carbon

The Net Zero Industry Act requires certain EU-based oil and gas producers to contribute to achievement of an EU objective of reaching 50 million tonnes of CO2 injection capacity in the EU by 2030. The Commission is consulting until 16 April 2025 on a Delegated Regulation specifying the rules on identification of the producers, calculation of their contributions, and their reporting obligations.

Buildings

The Commission is consulting until 7 May 2025 on rules for calculating cost-optimal levels of minimum energy performance requirements for new buildings, existing buildings undergoing major renovation, and individual building elements. The revision is required by Article 6(1) of the recast Energy Performance of Buildings Directive. Our overview of the recast Directive is available here: How to get a Net-Zero Building Stock: Q&As on the Recast Energy Performance of Buildings Directive.

REMIT

Updated Questions & Answers (Q&As) on REMIT to incorporate changes made by amendments to the REMIT Regulation are available.

Markets

The latest Commission quarterly reports on electricity and gas markets are available. ACER’s monitoring reports are also available and indicate that renewables grew significantly but that clean energy transition faces persistent challenges. ACER makes recommendations around new cost drivers, harnessing efficiency and flexibility, and expanding market integration.

Connecting Europe

A call for proposals worth up to €600 million under the Connecting Europe Facility to fund key cross-border energy infrastructure projects across the EU is open to PCI and PMI projects until 16 September 2025.

Raw Materials and Supply Chains

The Commission adopted a list of 47 Strategic Projects to boost strategic raw material capacities, under the ambit of the Critical Raw Material Act. The EU also agreed a Global Gateway package with South Africa to include developing strategic industries along supply chains.

Investment

NORD/LB and the EIB announced a partnership intended to provide financing for new small and medium-sized renewable energy projects throughout Europe.

Nuclear

The Council approved a draft Commission Regulation updating Euratom safeguards. It will apply to any entity setting up or operating an installation for the production, separation, reprocessing, storage, disposal or other use of nuclear material.

CASELAW

Gas Tariffs

Article 41(8) of Directive 2009/73/EC required regulatory authorities, when fixing or approving tariffs or methodologies and balancing services, to ensure that SOs are granted appropriate incentive to increase efficiencies. Article 13(1) Regulation 715/2009 set out tariffs for access to networks. (These articles have been succeeded and amended by Article 78(9) of Directive (EU) 2024/1788 and Article 17(1)-(3) of Regulation (EU) 2024/1789.)

In reply to a preliminary request from a Latvian Court in C-87/24, the CJEU indicated that:

Article 41(8) and Article 13(1) did not apply, in principle, to natural gas storage facilities, although the regulatory authorities may apply, by analogy, the general principles provided for in those provisions to storage.
Article 41(8) did not prevent legislation that does not expressly require the regulatory authority, when fixing tariffs or establishing a methodology for fixing them, to include in its statement of reasons the manner in which it provides an appropriate incentive, over both the short and long term, to encourage SOs to improve performance, foster market integration and security of supply, and support related research activities.
Insofar as Directive 2009/73 and Regulation 715/2009 did not provide for a specific and binding methodology for calculating and fixing tariffs for networks as well as storage facilities, it is for the regulatory authority, under the supervision of the national courts, to determine the appropriateness of the method used, on the basis of the relevant facts, while complying with the general principles for fixing tariffs in EU law.

FURTHER DOMESTIC DEVELOPMENTS

Renewable Energy Regulations

S.I. No. 97/2025 - European Union (Renewable Energy)(Amendment) Regulations 2025 amends S.I. No. 350/2022 - European Union (Renewable Energy) Regulations (2) 2022 and S.I. No 33/2012 – European Union (Biofuel Sustainability Criteria) Regulations 2012.

As regards biofuels/biomass fuels, Regulations 9 and 10 of S.I. 350/2022 require participants in support schemes or renewable energy obligations to comply with any request from the SEAI to submit information for each consignment of bioliquids and biomass fuels the participant used in the scheme or obligation. An amendment applies these obligations regardless of whether the bioliquids and biomass fuels are produced within the State or imported. Obligations in S.I. 97/2025 now apply regardless of whether the consignment of renewable transport fuel is produced in the State or imported.

A regards Guarantees of Origin, S.I. 350/2022 is amended as follows:

Regulation 25A transposes Article 19(5) of RED III by providing that competent bodies that design, establish and publish a supervisory framework for the issuance, transfer and cancellation of GoOs shall not have overlapping geographical responsibilities, and shall be independent of production, trade and supply activities.
Amendments to Regulation 26 transpose Article 19(2), seventh paragraph, to provide that a transfer of a GoO shall have no function in relation to the decision to use statistical transfers, joint projects or joint support schemes, for the purpose of compliance with RED III targets. They provide that a gas or electricity supplier shall use for disclosure the same type of GoOs as the energy supplied.
Amendments to Regulation 27 expand the circumstances where it is presumed that the market value of a GoO for gas has been taken into account appropriately in the relevant support scheme applicable to that renewable energy unit to include a limb (c), where the GoO is not issued directly to the producer but to a supplier or consumer who buys the energy either in a competitive setting or in a long-term renewables PPA. The supervisory framework for gas GoOs may provide for the issue and immediate cancellation of a GoO for the purposes of taking into account its market value. GoOs for electricity or for gas shall be valid for 12 months after the production of the relevant renewable energy unit. GNI shall ensure that companies cancel GoOs for gas at the latest six months after the end of the validity of the GoO.

Grid Development

EirGrid, Enterprise Ireland and IDA Ireland signed a Memorandum of Understanding intended to deepen cooperation and collaboration between the agencies, and to support the development of the Irish offshore wind sector, with a focus on attracting inward investment and building supply chains, required for Ireland’s offshore target of 37GW by 2050.

Grid Repairs

The Minister for the Environment, Climate and Communications announced that ESB Networks Winter 2025 Grid Resilience Plan sets out actions to increase resilience in the electricity network for the winter ahead.

Resource Adequacy

EirGrid’s 2025-2034 resource adequacy assessment indicates a potentially challenging outlook up to 2034 requiring management of volume and type of new capacity and of increasing demand. A press report is available in the Irish Times. EirGrid also published information on operational treatment, market treatment, and transparency requirements related to the dispatch of Temporary Emergency Generation Units.

Business Energy Upgrades

The Department of Environment, Climate and Communications introduced new Rapid Approval Grants targeted at small and medium businesses to carry out energy and emission saving investments.

FURTHER CRU BUSINESS

Transmission Infrastructure Delivery

TNEI was tasked to support the CRU in improving processes and recommending actions in relation to common causes of infrastructure delivery delays. TNEI’s report sets out recommendations, and it notes that delivery timescales in PR5, and subsequent NDP updates, seem overly ambitious and unachievable in some areas, albeit that time scales are published on an unconstrained scenario. The report continues that setting out a constrained programme of works is likely to result in a substantial portion of projects not being completed until after 2030, and that such a delay could have a profound impact on meeting system requirements, accommodating developers seeking connections, serving consumers, and reaching EU and national climate targets.

Gas TYNDP

The CRU consulted until 15 April 2024 on GNI’s Ten Year Network Development Plan 2024.

Standard Dynamic Pricing Contracts

The CRU extended the deadline for introduction of Standard Dynamic Electricity Price Contracts to the retail market to 1 June 2026.

Price Comparison Websites

An audit on price comparison websites’ compliance indicates that the CRU is satisfied that the websites are compliant with the Accreditation Framework.

SEMC BUSINESS

Future Arrangements for System Services

The SEMC has set out its decision on the volume forecasting methodology for the Day Ahead System Services Auction. A further decision indicates that there will be a new System Services charge to recover the costs of the Day Ahead System Services Auction as well as any costs to be paid through Layered Procured Framework contracts and the Fixed Contracts Framework.

Indicative Tariff Timetable

Key dates for 2025/6 tariffs are available.

NORTHERN IRELAND

Energy Strategy Action Plan

DfE has published the Energy Strategy Action Plan 2025 detailing the path to net zero energy for 2025. We provide a summary in our briefing: Energy Future – Energy Strategy Action Plan 2025.