Brussels, 04 September 2024
WK 10936/2024 INIT
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AGRI
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INFORMATION
From:
General Secretariat of the Council
To:
Working Party on Energy
Subject:
Communication from the Commission: Guidance on Article 20a on sector
integration of renewable electricity of Directive (EU) 2018/2001 on the promotion
of energy from renewable sources, as amended by Directive (EU) 2023/2413
Delegations will find in the annex a communication from the Commission on guidance on Article 20a on
sector integration of renewable electricity of Directive (EU) 2018/2001 on the promotion of energy from
renewable sources, as amended by Directive (EU) 2023/2413.
WK 10936/2024 INIT
LIMITE
EN

EUROPEAN
  COMMISSION

Brussels, 2.9.2024
C(2024) 5041 final

COMMUNICATION FROM THE COMMISSION
Guidance on Article 20a on sector integration of renewable electricity of Directive (EU)
2018/2001 on the promotion of energy from renewable sources, as amended by Directive
(EU) 2023/2413

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link to page 37 link to page 40 link to page 42
3.5.2. Detailed obligation ............................................................................ 36
Annex I - Obligations under Article 20a ................................................................... 39
Annex II – Relevant definitions ................................................................................ 41

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1.  INTRODUCTION
This  document  aims  to  provide  guidance  to  Member  States  on  the  transposition  of  the
provisions of Article 20a of Directive (EU) 2018/2001(1) on the promotion of the use of energy
from  renewable  sources,  as  amended  by  Directive  (EU)  2023/2413  (hereafter  referred  to  as
“revised RED or the “revised Directive”). Directive (EU) 2023/2413, which introduces Article
20a, was adopted by the European Parliament and the Council in October 2023 and entered into
force on 20 November 2023.
The overall aim of the new Article 20a (and of the definitions contained in points (14c) to (14p)
of  Article  2)  of  the  revised  Directive  is  to  facilitate  energy  system  integration  based  on
renewable  electricity,  and  to  ensure  that  the  electricity  system  allows  for  a  higher  share  of
renewable electricity in a cost-optimal manner. Article 20a thus aims to achieve this by setting
obligations regarding the access to data and market access. Specifically, it requires that:
‒  Transmission System Operators (TSOs) and, if possible, Distribution System Operators
(DSOs) will have to make available information on the share of renewable energy and
the  greenhouse  gas  emissions  content  of  the  supplied  electricity  in  their  territory,  in
order to increase transparency and give more information to electricity market players,
aggregators, consumers and end-users, including to electric vehicle users;
‒  Battery  and  electric  vehicle  (EV)  manufacturers  will  have  to  enable  access  to
information on battery management system to battery owners and users, as well as to
third parties acting on their behalf;
‒  Member  States  will  have  to  ensure  smart  recharging  and,  where  appropriate,  the
interface with smart metering systems, if deployed by Member States, and bidirectional
recharging functionalities for non-publicly accessible normal power recharging points;
‒  Member  States  will  have  to  ensure  non-discriminatory  access  for  small  and  mobile
storage assets to the balancing and flexibility services markets.
Member States will have to transpose Article 20a within 18 months after the entry into force of
the amending Directive, namely by 21 May 2025. In that regard, the aim of this document is to
provide  guidance  to  Member  States  and  their  authorities  on  the  application  of  these  new
provisions. It will help ensure timely transposition and implementation of Article 20a while
ensuring consistency with the other EU legislation, thus reducing the administrative burden to
the minimum.

(1)  Directive  (EU)  2018/2001  of  the  European  Parliament  and  of  the  Council  of  11  December  2018  on  the
promotion of the use of energy from renewable sources (OJ L 328, 21.12.2018, p. 82)
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In preparing this Communication, the Commission took into account recommendations derived
from a dedicated technical assistance study on promoting energy system integration through
the increased role of renewable electricity, decentralised assets and hydrogen(2).
This document is intended uniquely as a guidance. Only the text of EU legislation itself has
legal  force.  The binding interpretation  of EU legislation is  the exclusive  competence of the
Court  of  Justice  of  the  European  Union.  The  views  expressed  in  this  guidance  are  without
prejudice to the position that the Commission might take before the Court of Justice.
2.  LEGAL AND POLICY CONTEXT
2.1.
Legal context
The Commission introduced the new Article 20a as a follow up to the July 2020 Strategy for
Energy System Integration (3) to promote a more energy efficient and circular system, adapted
to higher shares of renewables and increased electrification.
The new Article 20a is complementary to and/or directly interlinked with other pieces of Union
legislation,  in  particular,  the  Alternative  Fuels  Infrastructure  Regulation  (EU)  2023/1804
(AFIR)(4), Batteries Regulation (EU) 2023/1542(5), Type Approval Regulation (EU) 2018/858
(as  amended)(6),  Directive  (EU)  2019/944  on  common  rules  for  the  internal  market  for
electricity (Electricity Directive)(7) and Regulation (EU) 2019/943 on the internal market for
electricity  (Electricity  Regulation)(8),  including  the  recently  adopted  amendments  on
flexibility(9).  In  addition,  Article  20a  has  interlinks  with  the  revised  Energy  Performance  of
Buildings Directive (EPBD)(10), which contains specific requirements on recharging points in

(2)  Specific contract ENER/C1/2022-530 under Framework contract ENER/C1/2022-530
(3)  COM(2020) 299 Final, communication on Powering a climate-neutral economy: An EU Strategy for Energy
System Integration
(4)  Regulation (EU) 2023/1804 of the  European Parliament and of the  Council of 13 September 2023 on the
deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU
(5)  Regulation  (EU)  2023/1542  of  the  European  Parliament  and  of  the  Council  of  12  July  2023  concerning
batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing
Directive 2006/66/EC
(6)  Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval
and market surveillance of motor vehicles and their trailers, and of systems, components and separate technical
units  intended  for  such  vehicles,  amending  Regulations  (EC)  No  715/2007  and  (EC)  No  595/2009  and
repealing Directive 2007/46/EC
(7)  Directive (EU) 2019/944 of the European Parliament and of the Council of 5 June 2019 on common rules for
the internal market for electricity and amending Directive 2012/27/EU (recast)
(8)  Regulation (EU) 2019/943 of the  European Parliament and of the  Council of 5 June 2019 on the  internal
market for electricity (recast)
(9)  Regulation  (EU)  2024/1747  of  the  European  Parliament  and  of  the  Council  of  13  June  2024,  amending
Regulations (EU) 2019/942 and (EU) 2019/943 as regards improving the Union’s electricity market design
(10)  Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy
performance of buildings (recast)
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link to page 8
buildings. Article 20a also has links with the Regulation on harmonised rules on fair access to
and use of data (Data Act)(11), which  contains basic principles  for accessing and using data
across the European economy (see Table 1 below).
Table 1: Overview of Article 20a provisions and interlinks with the EU legislation
Article 20a
Electricity
Electricity
AFIR
EPBD
Battery
Data Act
Directive
Regulation
Regulation

Paragraph 1
Art. 23
Art. 6

Art. 33
Paragraph 2
Art.  23&24,  Art. 57

31, 40, 59
Paragraph 3

Art. 14
Art. 5,7, 9 &
40(2)
Paragraph 4

Art. 15(3) & (4),  Art.  14,  15

Art. 20, Art. 5(7)  and 16
&  (8),  Art.  22
and Annex II(2)
Paragraph 5
Art.  3,  11,  Art.  6,  18,

13,  15  -  17,  20, 22
31,  32,  33
and 40
2.2.
Policy context
The new EU target for renewables for 2030 is set at 42.5%, with aspiration to achieve 45% by
2030. Although renewable energy is set to expand across various sectors, its highest shares are
expected to be reached in the power sector. The share of renewable energy in the electricity
sector is projected to increase from 37.5% in 2020 to around 69% in 2030(12). At the same time,
electricity  demand  is  expected  to  increase  significantly,  reaching  1/3  of  the  final  energy
consumption in 2030 from 22.1% in 2022.
This increasing renewables-based electrification coupled with system integration provides an
opportunity  for  a  cost-effective  pathway  to  decarbonise  end-use  sectors  such  as  transport,
heating and cooling and industry. This is already happening: 16 GW of new wind capacity and
41 GW of new solar capacity were installed in the EU in 2022, an increase of 45% and 47%
respectively compared to 2021. Sales of heat pumps reached 3 million in 2022 (an increase by
40% compared to 2021), and sales of EVs reached 1.2 million in 2022 (an increase by 14%
compared to 2021).
Energy system integration must progress more rapidly. To this end, the revised RED provides
an  enabling  framework  to  promote  electrification  through  renewables  deployment  across
different demand sectors and integrating distributed energy resources such as electric vehicles

(11)  Regulation (EU) 2023/2854
(12)  COM(2022)230 final
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(EVs),  photovoltaic  systems  (PVs)  and  heat  pumps.  These  measures  will  also  facilitate
electrification  from  renewables  thanks  to  streamlined  permit  granting  for  renewable  energy
projects and removing barriers to power purchase agreements.
However, there is an urgent need to tackle the remaining barriers that still prevent a massive
roll-out  of  renewable  electricity.  These  include  the  need  for  expanding  grid  capacities  at
distribution  and  transmission  levels  and  developing  a  more  flexible  and  smarter  grid
infrastructure  that  can  integrate  an  increased  amount  of  variable  renewable  electricity,  and
distributed  energy  resources  such  as  electric  vehicles  (EVs),  PVs  and  heat  pumps.  The  EU
Action Plan on Grids (13) proposes concrete measures to accelerate investments in deployment
and digitalisation of the grids.
In fact, flexibility in the EU electricity system needs to almost double by 2030 compared to
2022(14). Demand response is an important source of flexibility and allows energy resources and
consumers to change or adjust their consumption or production in response to price signals.
Having information on the distributed energy generation and flexibility resources installed in
their grids, such as EVs, batteries, heat pumps or solar panels, would allow distribution system
operators to better plan and operate their networks. DSOs are also key actors to make the grid
more flexible, smart and able to serve connected customers and avoid risk of congestion. The
more granular and dynamic data DSOs will have on decentralised generation installations and
from connected consumers, the better and more flexibly they will be able to plan and manage
the grid.
In the context of energy system integration, EVs will play a key role in decarbonising Europe’s
economy and transport sector, in particular, and allow dependence on imported fossil fuels to
be reduced, as well as in contributing to the uptake of renewable electricity. The sales of new
EVs are expected to rise to around 40 million in 2030 and 152 million in 2040(15,16). Studies
show that by 2030, EV batteries could fully meet the need for short-term electricity storage
globally. This would bring substantial benefits in terms of grid efficiency and reduced energy
bills for consumers, as EVs would be able to provide balancing and flexibility services through
demand  response  and  storage  thanks  to  smart  and  bi-directional  recharging  in  non-publicly
accessible  parking  spaces  (i.e.,  residential  and  office  buildings  where  vehicles  are  usually
parked for a longer duration).
The  increasing  number  of  EVs  requires  the  optimisation  and  effective  management  of
recharging operations for their swift integration into the electricity grid. To achieve this, it is
crucial that Member States ensure full implementation of the revised RED and related pieces

(13)  COM(2023) 757 final
(14)  Joint report by the European Environment Agency (EEA) and the EU Agency for the Cooperation of Energy
Regulators (ACER) (sept 2023)
(15)  Impact Assessment accompanying the Climate Target Plan 2040, SWD(2024) 63 final
(16)  Eurelectric estimates that the share of EVs will increase to some 57-58% in 2040 and 79-80% in 2050, with
the share of electricity in energy consumption of passenger cars estimated to reach around 31-33 % by 2040
and 60-70% by 2050 (An EV Explainer - Eurelectric – Powering People)
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of  legislation,  and  work  together  with  the  stakeholders  and  market  actors  to  overcome  the
remaining barriers to smart and bi-directional recharging.
Finally, active engagement of consumers in electricity markets directly or through aggregators
is key, through various forms of participation as self-consumers individually or via collective
self-consumption schemes, or as part of energy communities. To achieve this, consumers need
to have access to real-time data about the characteristics of energy supplied (such as renewable
energy share, GHG emissions content), similarly to the information they already have about
energy prices. This will enable them to make informed decisions to switch away from fossil
energy use towards renewable energy sources.
3.  IMPLEMENTATION OF OBLIGATIONS UNDER ARTICLE 20A
3.1.
Access to information on the share of renewable electricity and greenhouse
gas  emissions  content  of  supplied  electricity  and  on  demand  response
potential
3.1.1.  General overview of obligations in Article 20a(1)
Consumers need to have useful information on renewable based electricity penetration in the
grid, in a transparent  way and close to real time,  to allow them to adjust their consumption
accordingly. The provisions of Article 20a(1) aim to ensure this by increasing the granularity
of information on the share of renewable electricity in the grid to the public, in an accessible
way.  This  will  allow  consumers  to  take  conscious  consumption  decisions  and  adapt  their
electricity use, for example EV users to charge or discharge their vehicle and provide flexibility
services  based  on  signals  about  renewable  energy.  This  will  also  create  incentives  for
investments into innovative business models, integrating renewable electricity and increasing
the efficiency of the grid.
Specifically, paragraph (1) of Article 20a obliges Member States to:
•  require TSO and, if available, also DSO to make available data on the share of renewable
electricity and the greenhouse gas emissions content of the electricity supplied in each
bidding zone;
•  make  this  data  available,  as  accurately  as  possible  in  intervals  equal  to  the  market
settlement frequency but of no more than one hour, with forecasting where available;
•  ensure that distribution system operators have access to the necessary data;
•  provide incentives for upgrades for smart grids and
•  ensure  that  distribution  system  operators  make  available,  if  technically
available, anonymised and aggregated data on the demand response potential
and  the  renewable  electricity  generated  and  injected  to  the  grid  by  self-
consumers and renewable energy communities.
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The objective of Article 20a(1) is to ensure access to information on the available renewable
electricity  in  the  grid  in  real-time,  so  for  example    consumers  can  adjust  their  electricity
consumption to hours with high renewable electricity share.
3.1.2.  Data sharing
Based  on  the  obligations  of  Article  20a(1),  Member  States  must  stipulate  in  their  national
legislation that system operators make available data on the share of renewable electricity and
the  greenhouse  gas  emissions  content  of  the  electricity  supplied  in  each  bidding  zone,  in
intervals equal to the market settlement frequency and not exceeding one hour with a possibility
to use forecasting.
Most TSOs, and in some Member States also DSOs, already provide close to real-time data on
electricity generation and consumption, including the contribution of renewable energy sources,
on their official websites, which serve as data platforms (either as Data Exchange Platforms or
Data hubs)(17) (see Box 1). Thus, using existing Data Exchange Platforms to publish the data
on the share of renewable electricity and GHG emissions content close to real time (equal to
market frequency interval) is an effective way to implement Article 20a(1). These platforms
could also be useful for statistical purposes. The requirement on data availability implies access
to  those platforms  in  a simple manner. Member States’ authorities  will need to  assess what
additional data categories need to be added to existing Data Exchange Platforms to ensure the
provision of information under Article 20a(1).
Box 1- Data platforms in the context of the electricity market legislation
Data exchange platforms (DEPs) or Data hubs could be seen as a single gateway for access to
electricity market data at national level in line with electricity market legislation. Information
on wholesale and balancing electricity prices and the renewable electricity share are already
available  in  nearly  real  time(18).  Electricity  Directive  provides  basic  requirements  on  data
exchange  and  data  availability  to  consumers  in  real  time.  In  addition,  electricity  market
technical regulations require data exchange between market participants.
Article 33 of Regulation (EU) 2023/2854 on harmonised rules on fair access to and use of data
(‘Data  Act’)  provides  the  general  rules  for  ensuring  the  availability  of  information  on  data
sharing services or platforms via e.g., Application Programming Interfaces (API) (19) and where
possible enabling the interoperability of tools for harmonised data exchange.
There are different methods to share data from Data Exchange Platforms with DSOs and other
market actors, for instance via API, web services and file-based exchanges (e.g., XML, CSV,

(17)  Microsoft Word - EUSYSFLEX 5.1.3 Report - Data Platforms - FINAL.docx (eu-sysflex.com)
(18)  Electricity Regulation (EU) 2019/943 and Commission Regulation (EU) 2017/2195 on electricity balancing,
Directive (EU) 2019/944 on the internal market for electricity
(19)  An API is  a  set  of  rules  or  protocols  that  allow  software applications communicate  with  each  other  to
exchange data, features and functionality. For example, Energy labelling product registry (EPREL) also uses
an API, which provides access to public data for products registered in EPREL.
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RDF,  JSON).  APIs  allow  efficient  data  retrieval  and  integration,  and  offer  better  flexibility
compared to the other methods.
Data  platforms  in  most  cases  are  operated  by  TSOs  and  DSOs.  For  example,  EDSN  in  the
Netherlands is owned by seven DSOs and a TSO, with hereby DSOs actively involved in data
management.  The  data  platforms  in  Estonia  and  the  Netherlands  are  more  electricity  end-
customer oriented (consumers, prosumers), whereas the Belgian and the Italian data platforms
focus on suppliers and balancing responsible parties to facilitate their business processes. Some
of these data platforms publish combined ex-ante (forecasts) and ex-post (realised flows) data.
The data granularity of those data platforms may vary between one minute and one hour.
The obligation to make data on the RES share and GHG emissions content available close to
real time is in line with the rules under the Electricity Regulation. Article 8(4) of the Electricity
Regulation requires that the imbalance settlement period must be 15 minutes in all scheduling
areas  by  1  January  2021,  unless  the  regulatory  authority  has  granted  a  derogation  or  an
exemption(20).
To ensure consistency of implementing the obligation of Article 20a(1) to publish information
on the RES share and GHG emissions content, it would be necessary to take into account
imports and exports in order to reflect the consumption of electricity in a given bidding zone.
For DSOs it would mean accounting for electricity flows between distribution and transmission
networks. Specifically, as regards the data format:
‒  For the RES share, expressing it as a percentage of supplied electricity by accounting
for  imported  and  exported  electricity  flows  is  coherent  with  most  TSOs  already
publishing RES data on their Data Exchange Platforms as percentages for every type of
renewable generation (for example, Belgium and Germany);
‒  For  GHG  emissions  content,  expressing  it  in  grams  of  CO2  equivalent  per  kWh,
calculated  based  on  the  weighted  average  of  electricity  injected  into  the  grid  by
accounting for imported and exported electricity flows is recommended.
An optimal way to make this data available in near real time would be using APIs to allow
interested parties, especially consumers and end-users, to retrieve the information directly from
a  single  data  access  point  and  to  receive  this  data  directly  to  their  devices  (e.g.,  energy  or
building management systems, mobile phones and EVs). For example, the data of ENTSO-E
Transparency Platform is publicly available and can be accessed via an API. At a Member State
level, Energieopwek data platform in the Netherlands (21) provides the information on renewable
energy generation within 10 minutes timeframe and it is made available via an API.

(20)  Some Member States have obtained derogations and by 1 January 2025, the imbalance settlement period must
be implemented in all scheduling areas.
(21)  https://energieopwek.nl/en
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To ensure consistency in accounting the RES share and the GHG emissions content, for the
purposes of implementing of Article 20a(1), it is essential that Member States promote the use
of  a  harmonised  approach  and  methodology  by  system  operators.  Member  States  should
encourage system operators to cooperate across Member States in the collaboration framework
of the European Network of Systems Operators for electricity (ENTSO-E) and the association
of European distribution system operators (EU DSO Entity) to ensure that cross-border flows
are accounted for consistently across bidding zones.
3.1.3.  Access to information for distribution system operators
In  relation  to  the  obligation  for  Member  States  to  ensure  that  DSOs  have  the  necessary
information on the RES share and the GHG emissions content, Article 31 of the Electricity
Directive already includes obligations on DSOs to provide system users with the information
they need for efficient access to, including the use of, the electricity system and as regards the
cooperation between TSOs and DSOs.
With the increasing number of active customers producing their own electricity, DSOs need to
become more proactive service providers to ensure the optimal operation of the grid and serve
customers  cost-effectively.  For  this  to  happen,  it  is  crucial  that  DSOs  have  the  necessary
information on the available renewable electricity in their electricity system to become able to
use the services connected to distributed energy resources such as demand response and energy
storage, based on market signals.
In Member States where smart metering systems are deployed, DSOs are usually responsible
for the installation of smart meters, while they also participate in the data management process.
Member States are responsible for setting the rules for the management and exchange of data
(i.e., metering and consumption data as well as data required for customer switching, demand
response  and  other  services),  in  accordance  with  Articles  23  and  24(22)  of  the  Electricity
Directive. In this framework, Member States assign specific roles and responsibilities to DSOs
and other actors, on the basis of their data management model.
It is essential that Member States stipulate in their national framework how DSOs will be able
to  obtain  the  data  from  market  actors  such  as  aggregators,  electricity  suppliers  and  self-
consumers, energy communities, metering companies, etc. on the renewable electricity. Where
such data constitute personal data, it is crucial that the access and processing of this data is
ensured in accordance with the general data protection rules(23). Given the large diversity of the
DSOs across the EU and the different levels of development of data collection models deployed
in the Member States, it is important that Member States put in place  or adjust the existing

(22)  According  to  Article  24,  the  Commission  shall  adopt,  by  means  of  implementing  acts,  interoperability
requirements and non-discriminatory and transparent procedures for access to metering and consumption data
as well as data required for customer switching, demand response and other services.
(23)  Article 23 of the Electricity Directive contains principles on data management activities and provides that
Member  States  shallensure  efficient  and  secure  data  access  and  exchange.  In  addition,  it  recalls  that  the
processing of personal data shall be carried out in accordance with Regulation (EU) 2016/679.
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mechanisms for ensuring effective cooperation arrangements amongst the DSOs and TSOs at
national level for facilitating data collection for the purposes of implementing Article 20a(1).
Those mechanisms should provide the way for DSOs to record the data close to real time on
the share of renewable electricity and the GHG emissions content of the electricity supplied in
the respective electricity distribution system by taking into account the exported and imported
electricity  flows,  and  the  way  how  this  information  is  made  available  via  a  centralised
information channel at national level (as referred to above).
Data Exchange Platforms in the Member States are usually a single gateway for access to data
from data providers (such as data hubs, flexibility service providers, TSOs, DSOs) to data users
(such  as  TSOs,  DSOs,  Balancing  Responsible  Parties,  consumers,  suppliers,  energy  service
providers) and this makes them the primary channel of information.
To implement the obligations on access to information in an effective manner, Member States
can enable access to data in data platforms by using APIs or can ensure the data exchange via
available standards such as Inter-Control Centre Communications Protocol (ICCP, IEC 60870-
6/TASE.2), Communication networks and systems for power utility automation (IEC 61850-
7), RESTful(24) services using the DEP(s); however, those standards may not ensure the same
level of efficiency for enabling access to data as using the APIs.
In case the DSOs do not have the data available on  the RES share and the GHG emissions
content of the electricity supplied in distribution grids, as an alternative Article 20a(1) provides
a possibility to use the existing data reporting system under the ENTSO-E Transparency
Platform (25).  This  Platform  provides  centralised  data  on  generation,  transportation  and
consumption  of  electricity  at  EU  level  with  the  granularity  at  a  level  of  the  bidding  zone,
collected from data providers, including TSOs and other qualified third parties.
At the moment, reporting to ENTSO-E Transparency Platform is limited to installations with
generation capacities of 100 MW and above(26). Therefore, when opting to use this alternative
for enabling access to data for DSOs, Member States should ensure that DSOs can provide the
additional information on smaller generation capacities, to overcome this data limitation.
3.1.4.  Incentives for upgrades of smart grids
As regards the obligation for Member States to provide incentives for upgrades for smart
grids  (see  examples  in  Box  2),  recital  51  of  Directive  (EU)  2023/2413  explains  that  the
deployment  of  innovative  business  models  and  digital  solutions  have  the  capacity  to  link

(24)  RESTful APIs are commonly used in web and mobile applications to retrieve or modify resources and data
on remote systems; e.g., social media sites use REST APIs to integrate with third-party applications and allow
posting updates.
(25)  The ENTSO-E Transparency Platform
(26)  In  line  with  Article  16(1)a  of  Regulation  (EU)  543/2013  on  the  submission  and  publication  of  data  in
electricity markets
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consumption to the level of renewable energy in the electricity grid and thus provide incentives
for the right network investments.
The obligation to incentivise investments into smart grids complements the requirement in the
Electricity  Directive  on  the  development  of  distribution  systems  to  be  based  on  network
development plans to be conducted every two years by the DSOs, containing the smart grid
deployment needs in each DSO’s area.
The implementation of these obligations requires that Member States and national regulators
ensure  that  DSOs  establish  adequate  network  development  plans  based  on  transparent  and
regular  exchanges  with  the  relevant  stakeholders  such  as  renewable  energy  producers  and
suppliers, aggregators including electromobility service providers and local authorities etc.
Member  States  with  a  high  need  for  distribution  grid  modernisation  and  local  smart  grid
deployment should consider available options to  increase allocations under Cohesion policy
funds for this sector. DSOs and TSOs, with support from the respective Member States, are
encouraged  to  consider  partnering  for  proposing  candidate  Projects  of  Common  Interest  on
smart electricity grids, in accordance with the TEN-E Regulation(27) process.
Box 2 - Actions on grids and on the digitalisation of the Energy System
The  EU  Action  Plan  for  Grids (28)  calls  for  enhancing  distribution  network  development
planning, encouraging anticipatory investments in certain grid projects, adapting network tariff
structures to encourage network and system developments including on smart grids, ensuring
access to finance, streamlining grid permitting and facilitating supply chain investments. The
Action  Plan  supports  the  development  of  distribution  network  development  plans  and  the
uptake of smart, innovative and network efficiency technologies. In the framework of the EU
Action Plan for Digitalising the Energy System (29), work is under way by the European Union
Agency for the Cooperation of Energy Regulators (ACER), CEER and the national regulatory
authorities  (NRAs),  in  cooperation  with  ENTSO-E  and  EU  DSO  Entity,  to  define  common
smart grid indicators. NRAs monitor smart and digital investments in the electricity grid in line
with the objectives of Article 20a.
The Smart Energy Expert Group (30) and its dedicated ‘Data for Energy’ (D4E) working group
as  announced  in  Action  Plan  for  Digitalising  the  Energy  System  will  bring  together  the
Commission,  Member  States  and  the  relevant  public  and  private  stakeholders  to  build  the
European framework for sharing energy-related data. D4E will help strengthen the coordination

(27)  Regulation (EU) 2022/869 of the European Parliament and of the Council of 30 May 2022 on guidelines for
trans-European energy infrastructure
(28)  eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023DC0757
(29)  Digitalising the energy system - EU action plan (COM/2022/552)
(30)  The Smart Grids Task Force will be succeeded by the ‘Smart Energy Expert Group’
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at EU level on data exchanges for the energy sector, defining the driving principles and ensuring
consistency across different data-sharing priorities and initiatives (31).
3.1.5.  Data  on  demand  response  potential  and  electricity  generated  by    self-
consumers and renewable energy communities
Demand response is pivotal for enabling distributed energy resources such as heat pumps, small
storage assets and EVs to participate in the flexibility services, which will be crucial for energy
system integration in general as stated in recital 55 of the revised RED. Recital 51 also explains
that, in order to allow demand response and provide further incentives for the absorption of
green electricity, data need to be based not only on dynamic prices but also on signals about the
actual penetration of green electricity in the system.
Article 20a(1) contains an obligation for DSOs to provide anonymised and aggregated data,
if technically available, on demand response potential and renewable electricity generated and
injected into the grid by self-consumers and renewable energy communities. This obligation
builds  on  Article  23  of  the  Electricity  Directive,  which  requires  access  to  data  of  final
customers.  The  Implementing  Regulation  (EU)  2023/1162(32)  also  contains  complementary
provisions for consumers to obtain access to their metering data and also give authorisation for
data on their energy consumption or generation to be used by third parties.
The  demand  response  potential  in  a  distribution  system  depends  to  a  large  extent  on  the
availability of flexible load, i.e., electricity consumption assets that can adjust their demand,
either  behind  or  in  front  of  the  meter.  Such  assets  can  be  linked  to  industrial  customers  or
processes and to commercial or residential customers, and can include heat pumps, residential
or publicly accessible EV charging points, home and industrial batteries, etc.
The technical availability of collecting data on demand response potential largely depends on
the processes whereby the DSO is informed of the flexible load assets installed in its system.
More granular information on the existing and potential flexibility in an electricity system is
also necessary in line with the revised Electricity Regulation.
To this end, Member States should set forward in their national legislation specific conditions
to  render  the  required  data  on  demand  response  potential  referred  to  in  Article  20a(1)
“technically available”.
The  key  condition  for  DSOs  to  be  able  to  collect  data  on  demand  response  potential  and
renewable electricity generation and injection to the grid is that they are fully informed of the
renewable  energy  generation  and  flexible  load  assets  installed  in  their  systems.  The  most
common means for DSOs to collect this information is a permitting or notification procedure
for  a  renewable  energy  installation  (see  Box  3). In  cases  where  a  permitting  or  notification

(31)  eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52022SC0341
(32)  Commission Implementing Regulation (EU) 2023/1162 of 6 June 2023 on interoperability requirements and
non-discriminatory and transparent procedures for access to metering and consumption data
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procedure does not appear necessary, an obligation to inform the DSO can also be established
and enforced in cooperation with installers.
Another useful source of information for DSOs could be an identification or registration of all
potential flexibility service providers in each Member State, as recommended by ACER in their
framework guideline on a network code on demand-side flexibility(33). It would allow capturing
those  service  providers  that  are  potentially  qualified  to  participate  in  flexibility  services  in
demand response directly by shifting demand via the use of smart appliances or indirectly via
a contract with an aggregator.
The collection and processing of personal data for the requirements of Article 20a(1) should be
carried  out  in  accordance  with  the  Regulation  (EU)  2016/679  on  data  protection.  For  this
purpose, Member States shall ensure that in their transposition of the requirements of Article
20(a)(1)  this  right  is  clearly  established  in  national  law  (legal  basis  for  the  collection  and
processing of personal data) and respects the EU data protection rules. Subsequently, Member
States  could  require  that  national  regulators,  in  consultation  with  competent  authorities,
including data protection authorities, adopt guidelines for DSOs on collecting the anonymised
and  aggregated  data  on  demand  response  potential  and  renewable  electricity  generated  and
injected into the grid by self-consumers and renewable energy communities, and on making it
available via digital means to the relevant actors. This data are important for the purpose of
compiling official statistics at EU level, therefore access to this data is of essence to national
statistical authorities.
The data management operations required by Article 20a should also be taken into account by
national regulators regarding the DSOs’ capital and operational expenditure, when deciding on
a  possible  cost  recovery  through  network  tariffs,  which  will  be  required  under  the  revised
Electricity Market Regulation(34).
Box 3 – Data collection on the renewable electricity generated and injected into the grid by
self-consumers and renewable energy communities
DSOs need to be informed about the installation of renewable generation equipment in their
systems,  which  is  generally  the  case  in  the  EU  through  a  grid  connection  permitting  or
notification procedure. As long as the renewable energy generation equipment is fitted with
a dedicated metering device, the system operator can in principle establish the amount of
electricity  generated  by  that  equipment.  If  accurate  enough,  this  information  will  also
contribute to fulfil the obligation to provide data on the share of renewable electricity.

(33)  Paragraphs 34 and 57,  FG_DemandResponse.pdf (europa.eu), published by ACER on 20 December 2022
(34)  Improved  data  management  by  DSOs  will  also  be  necessary,  among  other  things  for  them  to  properly
implement the energy sharing provisions of the revised Electricity Market Directive, according to which DSOs
must “monitor, collect, validate and communicate metering data related to the shared electricity with relevant
final customers and market participants at least every month.”
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To determine the amount of renewable electricity injected into the grid by self-consumers
and  renewable  energy  communities  it  is  also  necessary  to  establish  the  amount  of  self-
consumed  renewable  electricity.  When  both  generation  and  self-consumption  take  place
behind the same meter, the electricity injected into the grid is the net result of the subtraction
between generation and self-consumption. When generation and self-consumption take place
behind  different  meters,  e.g.,  because  electricity  is  generated  in  one  location  and  self-
consumed in a different one (e.g., in energy sharing schemes), electricity consumed in the
consumption  point  is  considered  as  self-consumed,  and  needs  to  be  subtracted  from  the
electricity generated at the generation point.
3.2.
Interoperability and harmonised approach for access to data
3.2.1.  General overview of obligations in Article 20a(2)
Paragraph (2) of Article 20a requires that Member States ensure that the data (referred to in
paragraph one) are made available digitally in a manner that ensures interoperability based on
harmonised data formats and standardised data sets. This effective and digital data exchange is
a key enabler for the integration of renewable energy, the uptake of demand response and the
overall flexibility of the electricity network.
The  objective  of  this  provision  is  that  the  relevant  electricity  market  participants,  including
aggregators  and  consumers,  can  access  and  use  the  data  in  a  simple  way,  via  electronic
communication devices such as smart meters, electric vehicle recharging points, heating and
cooling  systems  and  building  energy  management  systems.  This  will  benefit  consumers,
including EV users, aggregators and energy management companies, as they will be able to
read and use in efficient and simple way the data that can be updated close to real time, using
standardised data formats.
3.2.2.  Interoperability and harmonisation
To  limit  administrative  burden  and  facilitate  the  implementation  of  interoperability
requirements  for  the  purpose  of  Article  20a(2),  Member  States  are  advised  to  use  already
commonly agreed and compatible data exchange formats and standards based on the Common
Information Model (CIM) developed by International Electrotechnical Commission (IEC)(35),
which allows standardised data exchanges between energy system operators. The IEC 62325
series standards, (namely IEC 62325-351, CIM European market model exchange profile(36)
and the set of IEC 62325-451 standards targeting core business processes of internal electricity
market, such as scheduling, settlement, capacity allocation and nomination, acknowledgement,

(35)  Common Information Model (CIM) (entsoe.eu)
(36)  CIM Guidelines for the IEC 62325-351 European Style Market Profile Approved as a Technical Specification
(entsoe.eu)
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etc.)  would  be  the  most  appropriate,  as  they  provide  necessary  guidelines  to  exchange
information among system operators(37).
In addition, the Member States, to deliver on the requirement which applies to them to ensure
interoperability  of  data,  can  require  and  put  in  place  measures  to  facilitate  collaboration
amongst the system operators to make the different data platforms and data hubs interoperable
at least at national level in terms of applying the same standards for data exchange and format,
and  if  possible  using  a  standardised  API  methodology.  Member  States  are  encouraged  to
collaborate  closely  with  the  established  European  style  market  profile  CIM  (Common
Information Model) governance structure (for example, the ENTSO-E CIM working group) for
conformity testing, in order to improve compliance with the respective CIM standards.
In  addition,  Member  States  are  encouraged  to  make  use  of  the  established  fora  in  the  field
including the working group on D4E under the Smart Energy Expert Group, in order to facilitate
the development and the use of harmonised data formats and standardised data sets to ensure
interoperability for the purposes of implementing Article 20a(2).
In relation to cybersecurity safeguards, Member States are encouraged to use the existing rules
and standards put in place and promote best practices, notably on cyber-hygiene, at every level
of the concerned organisations (see Box 4 below).
Box 4 - Data availability and interoperability
Specific  requirements  for  cooperation  and  data  exchange  between  the  system  operators  are
already included in the Electricity Regulation (Article 57) and the Electricity Directive (Article
40),  and  related  network  codes.  National  regulatory  authorities  have  an  overseeing  and
monitoring  role  in  the  implementation  of  the  electricity  market  legislation.  The  electricity
market  legislation  also  promotes  cooperation  on  cross-border  issues  with  the  regulatory
authorities  of  the  Member  States  concerned  and  with  ACER  (Article  59  of  the  Electricity
Directive).
Since  2009,  the  ENTSO-E  fulfils  a  coordinated  action  at  EU  level  to  promote  use  of  the
Common  Information  Model  (CIM),  which  enables  standardised  data  exchanges.  The
International Electrotechnical Commission (IEC) Technical Committee in collaboration with
ENTSO-E,  is  currently  developing  the  IEC  CIM  62325  standards  for  the  exchange  of  data
required  by  decentralised  energy  markets.  The  IEC  62325  series  of  standards  could  be
considered as a default option for pan-European data exchange and have been also discussed in
the context of the proposal of the network code on demand response and relevant projects.
The Smart Grids Task Force (38)  proposed recommendations in this area, and the Smart Energy
Expert Group and Working Group ‘Data for Energy (D4E)’ will advise the Commission on
developing an interoperable framework and a governance structure for seamless data exchange.

(37)  Common Information Model (CIM) for Energy Markets (entsoe.eu)
(38)  The Smart Grids Task Force will be succeeded by the ‘Smart Energy Expert Group’ pursuant to the decision
of the Commission of 18/9/2023; 75247a4c-ac08-4884-b743-956b3e3cde8f_en (europa.eu)
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The  Implementing  Regulation  (EU)  2023/1162  lays  down  interoperability  requirements  and
rules for non-discriminatory and transparent procedures for access to electricity metering and
consumption  data  by  final  customers  and  eligible  parties  in  accordance  with  the  Electricity
Directive.  The  Implementing  Regulation  establishes  a  reference  model  for  metering  and
consumption data that sets out rules and procedures that Member States shall apply to enable
interoperability.
The  key  principles  for  ensuring  cybersecurity  for  data  communication  are  regulated  by
Directive (EU) 2022/2555 on measures for a high common level of cybersecurity across the
Union  (NIS  2  Directive)(39).  More  relevant  for  the  electricity  market,  the  network  code  on
sector-specific  rules  for  cybersecurity  aspects  of  cross-border  electricity  flows  sets  the
necessary  rules(40).  The  IEC  62351  series  of  standards  also  defines  the  cybersecurity
requirements for implementing security technologies in the operational environment, including
network and system management objects.
3.3.
Requirement to enable access to basic battery information
3.3.1.  General overview of obligations in Article 20a(3)
Article  20a(3)  seeks  to  allow  owners  or  users  of  batteries,  or  the  entities  acting  on  their
behalf (41), to have real-time access to basic battery information. It puts an obligation on Member
States  to  ensure  that  manufacturers  of  domestic  and  industrial  batteries,  as  well  as  vehicle
manufacturers,  enable  real-time  access  to  basic  Battery  Management  System  (BMS)
information.

BMS information specifically covers four parameters:  a) battery  capacity, b) state of health
(SoH), c) state of charge (SoC) and d) power set point. The three last parameters are defined in
Article  2,  points  14j,  14k  and  14l  of  the  revised  RED.  In  relation  to  EV  batteries  (2nd
subparagraph  of  Article  20a(3)),  BMS  information  must  also  cover,  where  appropriate,  the
location of electric vehicles.
Enabling free and real-time access to BMS information is essential for renewables’ integration,
for  promoting  efficient  charging  services  and  practices,  for  saving  cost,  and  ultimately  for
improving customer experience. It will also contribute to the development of flexibility and
balancing  services  from  the  aggregation  of  distributed  storage  assets-.  Fostering  the
development of interoperable BMSs with improved diagnostic and predictive capabilities will
open up new business opportunities and facilitate energy system integration.

(39)  Article 29 on on Cybersecurity information-sharing arrangements, NIS 2 Directive (nis-2-directive.com)
(40)  Commission  Delegated  Regulation  (EU)  2024/1366  of  11  March  2024  supplementing  Regulation  (EU)
2019/943 of the European Parliament and of the Council by establishing a network code on sector-specific
rules for cybersecurity aspects of cross-border electricity flows
(41)  Such as building energy system managers, mobility service providers and other electricity market participants
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Stationary storage (using domestic and industrial batteries) enables to store energy for later
use,  helping  to  balance  supply  and  demand,  increase  grid  stability,  and  integrate  renewable
energy into the grid more effectively.
Regarding EVs, smart and bi-directional recharging mainly rely on open access to BMS data.
Making data directly available to the relevant third parties acting on the owners’ and users’
behalf,  such  as  electro-mobility  service  providers  or  aggregators,  is  needed  to  increase  the
uptake of these charging functionalities or to better plan charging operations. This is particularly
relevant given that today, this information is not made widely available in a comprehensive and
harmonised manner, which is burdensome.
➢  Scope of the obligation
The  obligation  in  the  first  subparagraph  of  Article  20a(3)  applies  for  all  new  domestic  and
industrial batteries placed on the internal market as from 21 May 2025.
The obligation in the second subparagraph of Article 20a(3) applies for all new EV batteries
placed  in  the  internal  market  as  of  21  May  2025,  unless  there  are  technical  limitations
preventing it. In case there are technical limitations, the obligation in subparagraph 2 of Article
20a(3) applies for all new types of EVs approved under Regulation (EU) 2018/858 as of 21
May 2025. The obligation in subparagraph 2 of Article 20a(3) covers batteries used in both
battery electric vehicles (BEVs) and Plug-in hybrid electric vehicles (PHEVs), of category L
(if it does weigh more than 25 kg), or of categories M, N or O, according to the definition (14h)
of Article 2 of the Directive.
Even  though  the  obligations  of  20a(3)  apply  for  the  manufacturers  of  domestic,  industrial
batteries and of EVs, they introduce in fact additional requirements on the products themselves,
similarly to the Batteries Regulation. Therefore, these products (stationary batteries and EVs)
need to comply with the requirements introduced by the revised RED when placed on the EU
market,  regardless  of  where  they  are  produced,  thereby  including  those  being  imported.
Specifically, for subparagraph 2 of 20a(3), the obligation affects the EVs, which need to be in
compliance with the requirements of the revised RED in order to be placed in the EU market.
Therefore, this obligation also affects the entity that introduces the product on the EU market,
i.e. the manufacturer, the distributor or the importer. Consequently, Member States must ensure
in  their  national  legislation  that  all  products  placed  in  the  market  are  in  line  with  the
requirements set by Article 20a(3), ensuring consistency in the Internal Market.
➢  General requirement
The entry point for accessing the data mentioned in the obligation is the BMS. Existing BMSs
often rely on proprietary software to define battery parameters, which limits interoperability.
The  transposition  of  Article  20a(3)  will  ensure  access  to  the  parameters  mentioned  in  this
paragraph through obligations on manufacturers of domestic and industrial batteries and on EV
manufacturers.
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link to page 22
Access to BMS data involves:
-  A  harmonised  format  for  data  points  to  avoid  fragmentation.  At  this  stage,  some
standards already exist or are being developed, but this does not cover all parameters
mentioned in the revised RED (see Table 2).
-  Using  a  same  interface  for  the  data  exchange:  some  legislative  texts  are  already
asking for data exchange regarding certain parameters (see Table 2). On the basis of the
revised  RED,  battery  and  electric  vehicle  manufacturers  must  ensure  that  the
communication of the data happens in real time (see para 3.3.4).
The Commission will support Member States in implementing the Directive in line with this
guidance and further specify the parameters and data that are not standardised yet, as necessary,
via a dialogue, based on existing fora (such as the Working Group on Motor Vehicles, the Smart
Energy  Expert  Group  and  the  Sustainable  Transport  Forum (42)),  which  will  involve  the
Commission, Member States’ representatives responsible for energy and transport, the industry
and relevant stakeholders. This dialogue may provide recommendations in complementarity to
the legislation and the guidance, on the implementation of this provision.
Table 2: Legislative texts or initiatives linked to the parameters mentioned in Article 20a(3)

Stationary batteries
EV
Parameter
Static/
Standard for
Requirement for
Standard for
Requirement for sharing
dynamic
calculation
sharing
calculation
Battery
Static
Standardised
Batteries Regulation  CEN/CENELEC
Batteries
Regulation
capacity
(“rated
(ongoing)(45)
(“rated
capacity”
capacity (43)”
Timeline: May 2025
defined  in  Annex  IV  -
defined in Annex IV
Timeline: 18 Aug 2024 –
-  Timeline:  18  Aug
see box 5)
2024 (44))
Data Act (see box 5)

(42)  https://transport.ec.europa.eu/transport-themes/clean-transport/sustainable-transport-forum-stf_en
(43)‘Rated capacity’ (annex IV) means the total number of ampere-hours (Ah) that can be withdrawn from a fully
charged battery under reference conditions)
(44)  From 18 August 2024, rechargeable industrial batteries with a capacity greater than 2 kWh, LMT batteries
and electric vehicle batteries shall be accompanied by a document containing values for the electrochemical
performance and durability parameters set out in Part A of Annex IV.
(45)  prEN 18060 Road vehicles - Rechargeable batteries with internal energy storage - Performance of alkali-Ion
(Li-Ion, Na-Ion), Pb, NiMH and combined chemistries EV modules and batteries
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Stationary batteries
EV
Parameter
Static/
Standard for
Requirement for
Standard for
Requirement for sharing
dynamic
calculation
sharing
calculation
State
of  Dynamic,
CEN/
Batteries Regulation  CEN/CENELEC
Batteries  Regulation  -
health
decreasing
CENELEC
(parameters
for  (ongoing) (46)
Timeline:  18  August
(SoH)
over
(ongoing):
determining  SoH,  Timeline: May 2025
2024 (47) (periodic basis
lifetime  of  Methodology
periodic  basis  -
– see box 5)
the battery
based  on  the  5  Timeline: 18 august
parameters
2024)
Euro  7  Regulation  and
listed  in  Annex
UN  Global  Technical
VII  of  Battery
Regulation  No.  22  (via
Regulation.
the  OBD  port  and
optionally  over  the  air)

(timeline: end 2026)
Data Act (see box 5)
State
of  Dynamic
No standard
Batteries Regulation  No standard
Batteries
Regulation
charge
(periodically
(periodically  recorded,
(SoC)
Common
recorded,  timeline:  Common  definitions  timeline: 18 Feb 2027 –
definitions
in  18  Feb  2027  –  see  in  revised  RED  and  see box 5)
revised RED and  box 5)
Batteries Regulation
Batteries
Data Act (see box 5)
Regulation

ISO  15118-2  already

enables  its  exchange
every  500  ms  or  1s
between the vehicle and
the  charging  point.  ISO
15118-20  also  enables
its exchange.
Battery
Dynamic
No standard
No requirement
No standard
Data Act (see box 5)
power
set
point

Location
Dynamic
Not requested
Not requested
Standardised
Data Act (see box 5)
(where
appropriate)

(46)  prEN 18061 Road vehicles - Electrically propelled vehicles - Steps, conditions and protocols for the safe repair
and re-use of modules and batteries originally designed for EV applications
(47) From 18 August 2024, up-to-date data for the parameters for determining the state of health and expected
lifetime of batteries as set out in Annex VII shall be contained in the battery management system of stationary
battery energy storage systems, LMT batteries and electric vehicle batteries.
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Box 5 - Relevant elements of the current legislation
The  Data  Act (48)  aims  to  ensure  that  users  can  access  and  use  the  data  generated  by  their
connected devices such as EVs. The Data Act provides for a general obligation to design and
manufacture products in such a manner that data are directly accessible (49) to the user, where
this is relevant and technically feasible (Article 3(1)).This obligation covers “product data”, i.e.
data generated by the use of the vehicle that the manufacturer designed to be retrievable (via an
electronic  communications  service,  a  physical  connection  or  on-device  access).  Where  data
cannot be directly accessed by the user, the data holder has to make “readily available data”
(defined under Article 5(1)) accessible to the user by some other means. Where relevant and
technically feasible, this data shall be made accessible continuously and in real time (Article
4(1)).  Consequently,  when  system  data  points  are  defined  in  the  legislation,  the  Data  Act
recognises the right of users to access and share these data with third parties that they choose,
under fair, reasonable, non-discriminatory, and transparent terms and conditions. For example,
location is a data point clearly defined and the Data Act allows the driver to share the location
of his vehicle in line with the GDPR and the ePrivacy Directive. Likewise, the state of charge
is a data point generated by the EV manufacturer, which is already shared in real time with the
driver. However, for data holders, the Data Act provides for a compensation for making data
available to third parties (50). The Data Act applies in addition to the EU and national laws on
the protection of personal data and electronic communication.
The Batteries Regulation will require that some data of new stationary battery energy storage
systems and new electric vehicle batteries are shared, but it does not address the need for real
time access as the scope of data sharing provision in that Regulation focuses on helping the
evaluation for a potential second life for batteries.
Battery capacity, as from 18 August 2024, has to be included in a document accompanying the
battery. At a later stage, it will be shown on the battery label and as from 18 February 2027, it
will also have to be available in the public access part of the battery passport.
For the state of health (SoH), as from 18 August 2024, parameters for determining the state of
health shall be up to date and shared with the natural or legal person who has legally purchased
the battery or a third party acting on their behalf.
For state of charge (SoC), from 18 February 2027, the battery passport requires this information
in Annex XIII of the Batteries Regulation to be available to persons with a legitimate interest,
but only periodically recorded information is required.

(48)  Article 3: “Obligation to make data accessed from connected products or generated during the provision of
related services accessible to the user. 1. Connected products shall be designed and manufactured, and related
services shall be designed and provided, in such a manner that product data and related service data, including
the relevant metadata necessary to interpret and use those data, are, by default, easily, securely, free of charge,
in  a  comprehensive,  structured,  commonly  used  and  machine-readable  format,  and,  where  relevant  and
technically feasible, directly accessible to the user.”
(49)  For example, accessible on the device or via a remote server to which the data is communicated
(50)  Article  9  of  Regulation 2023/2854:  “1.  Any  compensation agreed  upon  between  a  data  holder  and  a  data
recipient  for  making  data  available  in  business-to-business  relations  shall  be  non-discriminatory  and
reasonable and may include a margin”.
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3.3.2.  Battery data format
The requirement for access to battery data under Article 20a should be ensured by making use
of the existing standardisation when it is available. Member States should not create their own
standards at national level to avoid fragmentation.
When  parameters  are  not  yet  standardised,  Member  States  should  recommend  battery  and
vehicle manufacturers to ensure that measurements and calculations are made using reliable,
accurate and reproducible methods which take into account the generally recognised state-of-
the-art  methods,  and  the  results  of  which  are  deemed  to  be  of  low  uncertainty,  including
methods set out in standards for which references have been published for those purposes in the
Official Journal of the European Union. They should also ask them to document these methods
in view of potential verification by competent authorities to allow for interoperability.
➢  State of health (SoH)
Member States should recommend manufacturers to use the outcomes of the standardisation
currently being developed by CEN-CENELEC (see timeline in Table 2).
For EVs, the data point should be the State of health (in %).
For stationary batteries, the data point should stem from the calculation using the 5 parameters
listed in Annex VII of Batteries Regulation (51), using state-of-the-art methods.
➢  Battery capacity
The definition of battery capacity should be the rated capacity, namely the capacity value of a
battery, under specific conditions, such as temperature and relative humidity, and declared by
the manufacturer.
➢  State of charge (SoC)
For the SoC, even if this data point is not yet standardised, it is already available (and for EVs,
normally displayed by the vehicle manufacturer on the EV dashboard, and possibly on the user
application). Therefore, it is recommended that car manufacturers share the current SoC in %.

(51)  ANNEX  VII  -  PARAMETERS  FOR  DETERMINING  THE  STATE  OF  HEALTH  AND  EXPECTED
LIFETIME  OF  BATTERIES  -  Part  A:  Parameters  for  determining  the  state  of  health  of  electric  vehicle
batteries,  stationary battery energy storage  systems and LMT batteries:  […]  For stationary battery energy
storage  systems  and  LMT  batteries:  1.  the  remaining  capacity;  2.  where  possible,  the  remaining  power
capability; 3. where possible, the remaining round trip efficiency; 4. the evolution of self-discharging rates; 5.
where possible, the ohmic resistance.
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➢  Battery power set point
The battery power set point is not standardised yet. It can cover for example the maximal power
that  the  battery  can  support  at  a  given  moment  (in  kW),  as  this  maximal  power  changes
dynamically depending, for example, on battery temperature (52).
3.3.3.  Data  access  to  owners,  users  and  third  parties  “acting,  with  explicit
consent, on the owners’ and users’ behalf”
➢  General requirement
Member  States  have  to  adopt  measures  to  require  that  both  vehicle  manufacturers  and
domestic/industrial batteries manufacturers make available in real time those data and at no cost
to battery and EV owners and users. Direct communication between the battery/vehicle and the
third party acting on the owners’ and users’ behalf must be enabled.
Member  States  need  to  introduce  the  right  of  users  and  owners  to  access  data  through  the
transposition of the provision. In this legislation, they should also lay down the exact data point
that is meant to be shared when not standardised yet (see point 3.3.2 above).
Moreover, the right of owners and users to share these data with third parties is established
under  the  conditions  of  ‘explicit  consent’.  This  ‘explicit  consent’  should  be  understood  as
authorisation of the owner/user for the data to be shared with the third party acting on their
behalf,  and  not  as  a  consent  in  the  sense  of  the  Regulation  (EU)  2016/679  (GDPR).  These
conditions are included in the provision to ensure that battery and EVs owners and users are in
control of these data, and that they are protected while sharing them. Therefore, Member States
need to transpose the condition of accessing battery data, including the requirement of explicit
/authorisation of battery and EV owners and/or users in their legislation in order for the sharing
of the data to be lawful. In case the agreement for sharing the data is given by natural persons,
the  GDPR  also  applies  regarding  the  access  and  subsequent  processing  of  personal  data  of
batteries and EV users.
For electric vehicles, even though not written expressly in the provision, the mention of the
fact that third parties need to be acting on owners’ and users’ behalf, leads to the conclusion
that the explicit authorisation by EV owners/users is also needed for access to data mentioned
in  the  second  subparagraph  of  20a(3),  mirroring  the  conditions  of  the  first  subparagraph.
Owners  and  users  of  EVs  can  either  be  natural  or  legal  persons  (i.e.  enterprises,  leasing
companies). In cases where the owner and the user are different (for example in the case of
leasing  companies  or  of  shared  vehicles  within  a  household),  both  should  give  their
authorisation to make the data available. However, for the sake of streamlining and accelerating
procedures,  the  owner  may  be  requested  to  authorise  the  data  access  only  once.  It  is  also

(52)  As part of the data to be communicated between the charging point and the vehicle under ISO 15118, “power
set point” is a set of data types (dynamic information) prescribing the electric power settings at which the
battery should optimally operate during a recharging or discharging operation.
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recommended that he does not restrict access as the user is the most concerned by this data
sharing.
When transposing the provision, Member States should provide details on how the authorisation
of the owner or user is given and the characteristics of this authorisation. It is recommended
that the authorisation given by the owner/user is specific, informed and explicitly brought to
attention of the owner/user. It must be done through a distinct authorisation for this specific
purpose,  in  an  intelligible  and  easily  accessible  form,  using  clear  and  plain  language  (for
example by a written statement, including by electronic means). Member States are encouraged
to  provide  specific  authorisation  forms.  This  could  include  ticking  a  box  when  visiting  a
smartphone application or internet website, choosing technical settings for information society
services  or  another  statement.  Silence,  pre-ticked  boxes  or  inactivity  should  not  constitute
consent/authorisation.
The authorisation for the battery data should be revokable at any time in order for users who
will be data subjects in the sense of data protection rules to remain always in control of the data
flow.
➢  Case of location
As  regards  EV  batteries,  in  addition  to  the  four  parameters  indicated  above,  Article  20a(3)
contains an obligation to share, where appropriate, the location of electric vehicles.
There  are  several  reasons  why  sharing  the  location  would  contribute  to  energy  system
integration. By knowing the location of EVs, energy providers can better plan the distribution
of charging loads across different locations to help balance the overall demand on the grid and
minimise the need for expensive peak capacity. Sharing location of the vehicles may be also
relevant  for  the  aggregator’s  planning  and  anticipation  of  charging  sessions.  It  informs  the
aggregator  where  the  vehicles  usually  park,  at  what  times  and  for  how  long.  Moreover,
coordination of EV charging over periods with high renewable energy generation allows for
more  sustainable  charging  practices.  The  data  exchange  that  would  take  place  prior  to  the
charging  event  could  also  include  exchanging  information  about  availability  of  charging
stations to efficiently route users to free charging stations, especially in peak events such as
holidays.
Location  sharing  also  enables  vehicle-to-grid  integration.  Knowing  the  location  of  EVs
equipped  with  bi-directional  functionalities  could  incentivise  using  EVs  as  a  storage  asset
where  it  is  needed  and  feed  energy  back  into  the  grid  during  peak  demand.  Consequently,
energy providers can offer location-based incentives to encourage EV users to charge/discharge
their vehicles at specific locations or times, helping to optimise energy consumption across the
grid and reduce congestion.
Considering  the  need  for  ensuring  data  protection,  Member  States  shall  make  sure  that  the
location is  always shared  after the  authorisation  of the owner/user of the EV,  as mentioned
above, and in accordance with the data protection rules.
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➢  Enforcement
Sanctions  (including  fines)  should  be  adopted  by  Member  States  to  enforce  the  new
requirements laid down in the revised RED, but this should not result in the refusal of a type
approval, or in the prohibition of the placing of the type approved vehicle on the market (53).
Member States could carry out an audit to check that data are made available in real time, i.e.
that manufacturers of domestic and industrial batteries and of electric vehicles are complying
with the requirements of 20a(3).
3.3.4.  Ensuring access to battery data in “real time”, under “non-discriminatory
terms” and “at no cost”
As  regards  real  time,  the  Electricity  Regulation  establishes  that  the  settlement  period  of
ancillary and flexibility markets is equal to 15 minutes. However, according to stakeholders
and experts, in order to reflect significant changes of the parameters referred to in the revised
RED and the usefulness of the data, the frequency can be in the range of a second for some
parameters. Therefore, the recommended frequency of availability is below one minute.
For EVs, it is important to distinguish between two use cases, namely sharing in real time data
when the vehicle is not plugged in (namely parked or on the road) to optimize the next charging
operation (which is the aim of Article 20a(3)), and sharing data when the EV is plugged to the
charging station. The latter case should notably be enabled by the new standard ISO 15118-20.
The  mandatory  implementation  of  this  standard  will  be  subject  to  upcoming  secondary
legislation  under  Regulation  (EU)  2023/1804  on  the  deployment  of  alternative  fuels
infrastructure (54) but  that  communication  protocol  can  already  be  used  on  a  voluntary  basis
before it is made mandatory.
In relation to non-discriminatory terms, Regulation (EU) 2023/2854 (recital 5) explains that
users  of  a  connected  product  or  related  service  in  the  Union  shall  have  access,  in  a  timely
manner, the data generated by the use of that connected product or related service and that those
users can use the data, including by sharing them with third parties of their choice. It imposes
the obligation on data holders to make data available to users and third parties of the user’s
choice in certain circumstances. It also ensures that data holders make data available to data
recipients in the Union under fair, reasonable and non-discriminatory terms and conditions and
in a transparent manner.

(53)  The list of requirements necessary to obtain the approval of a new type is exclusively defined in the context
of  Regulation  (EU)  2018/858  (Type  Approval  Regulation).  Furthermore,  as  stated  in  article  6(5)  of  Type
Approval  Regulation,  Member  States  shall  not  prohibit,  restrict  or  impede  the  placing  on  the  market,
registration or entry into service of vehicles, systems, components or separate technical units which comply
with that Regulation.
(54) Pursuant to Art.21 of Regulation (EU) 2023/1804, the Commission shall adopt delegated acts to amend Annex
II by introducing technical specifications for the areas listed in Annex II (Technical specifications) to enable
full technical interoperability of the recharging and refuelling infrastructure.
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For  the  purposes  of  Article  20a(3),  “at  no  cost”  should  be  understood  as  making  the  data
available without cost to battery owners, users and third parties.
3.3.5.  Exchange interface
Regarding  the  interface  for  the  data  to  be  exchanged,  it  is  crucial  to  avoid  incompatible
implementation in Member States leading to a lack of cross-border interoperability.
In relation to EV batteries, in addition to the data collected by vehicle manufacturers or for
maintenance purposes, the vehicle transmits data when connected to a charging station via the
OBC (on-board charger). For charging purposes, charging stations and EVs predominately use
the standard ISO 15118 for physical (wired) communication. In this situation, the data transfer
takes  place  when  the  EV  is  connected.  For  forecasting  purposes  and  planning  of  the  next
charging operation, data must be communicated over the air in order to enable real-time and
remote communication with third parties.
Access to vehicle data has been regulated at EU level since 2007 for repair data and on-board
diagnostics (OBD) to ensure fair competition on the repair and maintenance aftermarket. Since
then, the market for connected vehicles has developed. It is estimated that in 2020, around 48%
of all new cars shipped that year had built-in connectivity (55). In 2030, 96% of all new cars
shipped worldwide are expected to be connected cars.
In  order  to  harmonise  the  way  Article  20a(3)  is  implemented  across  the  EU,  vehicle
manufacturers should be encouraged to make available parameters mentioned in this provision
through an harmonized interface that enable real time sharing. Today, some data points
mentioned in the revised RED (state of charge, battery capacity, …) are already shared ad hoc
with  third  parties  through  bilateral  contracts.  The  obligation  under  Art.  20a(3)  allows  third
parties to connect to the interface easily and at no cost, and ensures access to the data mentioned.
For the case of stationary batteries, data flows go from the Battery Management System to
the Energy Management System (EMS) installed in the building as a standalone unit or as part
of a building management system. From EMS, information can be shared with users and third
parties using different standards.
In that regard, Member States should facilitate for owners/users of stationary batteries and third
parties the direct access to EMS or BMS, in accordance with data protection regulation, and the
Data and Cybersecurity Acts(56).

(55)  https://www.statista.com/statistics/1276018/share-of-connected-cars-in-total-new-car-sales-worldwide/
(56)  REGULATION (EU) 2019/881 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 April
2019 on ENISA (the European Union Agency for Cybersecurity) and on information and communications
technology cybersecurity certification and repealing Regulation (EU) No 526/2013 (Cybersecurity Act)
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The nature of devices connected to the BMS and the connection architecture differ with the
application  and  the  system  provider.  It  can  be  done  either  via  an  inverter  or  via  a  direct
communication with the EMS. In general, many standardised options for communication with
EMS  and  BMS  are  currently  available  in  the  market.  Therefore,  Member  States  should
recommend manufacturers to implement, when available, the standardised protocols in order to
achieve interoperability.
It is necessary to use existing standards for the data model and communication between the
BMS and the EMS, and then from the EMS to the third parties(57). Communication with the
owners  or  third  parties  could  be  enabled  via  standardised  communication,  or  messaging
standards  and  APIs  (e.g.  using  web  services),  and  building  on  underlying  existing  domain-
specific data exchanges.
3.4.
Obligation  to  ensure  smart  and  where  appropriate  bi-directional
recharging functionalities
3.4.1.  General overview of obligations in 20a(4)
Article 20a(4) puts an obligation on Member States or their designated competent authorities
to ensure that, as of the transposition date, new and replaced non-publicly accessible normal
power recharging points installed in their territory will support smart recharging functionalities.
Article 14 of the EPBD has the same requirement.
New and replaced recharging points are considered to be all new charging points that are
installed in charging stations or that replace existing charging points.
Article  5(8)  of  AFIR  already  has  an  obligation  to  ensure  smart  recharging  capabilities  on
publicly accessible recharging points which is placed on the operators of publicly accessible
recharging points. However, AFIR does not address smart recharging at non-publicly accessible
recharging points.
Article 20a(4) of RED also stipulates that, where appropriate, new and replaced non–publicly
accessible normal power recharging points with smart recharging functionalities must be able
to support the interface with smart metering systems, provided that the latter are deployed in
the Member States.
In addition, Article 20a(4) stipulates that, where appropriate, new and replaced non–publicly
accessible normal power recharging points must be able to support bi-directional recharging
functionalities, in connection with Article 15(3) and (4) of AFIR (58).

(57)  Standards: IEC TC57 (Power systems management and associated information exchange) such as IEC 61850,
OpenAdr and IEC 60870-5-104. Using IEC 6087-5-104 or IEC 61850 allows DSOs to connect directly to
SCADA systems.
(58)  Regulation (EU) 2023/1804 on the deployment of alternative fuels infrastructure
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Smart recharging can provide benefits to the grid by shifting the load in time without acting as
storage. It requires ensuring efficient and timely charging and balancing the load on the grid
depending  on  the  state  of  charge  of  the  battery.  Since  bi-directional  recharging  allows  EV
batteries to behave like other batteries connected to the grid, it facilitates integration of variable
renewable energy by allowing to store excess energy when prices are low and supplying this
energy back to the grid when energy prices are high and the renewable generation is scarcer.
Open access to battery management system (BMS) data allows for precise control of the bi-
directional flow of energy, enabling grid integration strategies such as vehicle-to-grid (V2G)
and vehicle-to-home (V2H) systems.
Article  20a(4)  aims  to  enable  a  market  for  smart  and  bi-directional  recharging  of  electric
vehicles  at  non-publicly  accessible  recharging  infrastructure.  Smart  and  bi-directional
recharging are especially relevant for private recharging infrastructure, in homes, offices, and
for  private  fleets  where  cars  are  usually  parked  for  longer  periods  of  time.  It  can  provide
flexibility  and  balancing  services  to  the  grid.  Only  if  the  recharging  infrastructure  is  bi-
directional, EVs can serve as energy storage devices providing power during peak demand and
thus provide stability to the electricity grid during peak hours or during emergencies.
Bi-directional recharging is still in an early stage of development and is only available in some
European countries (and in pilot phases) due to several barriers such as unfavourable electricity
grid tariffs, double taxation, lack of markets for distributed energy resources and conversion
need from  DC (battery) to  an AC recharging point, which is the typical  technology  used in
home/workplace recharging points. However, the recent finalisation of supporting standards
(namely  ISO  15118-20(59))  enables  smart  and  bi-directional  recharging  and  ensures
interoperability of data communication between EVs and charging points.
The implementation of the provisions of the revised RED on bi-directional recharging is closely
linked with provisions in other legislative acts such as Article 15(3) and (4) of AFIR and Article
14 of the EPBD. It is therefore essential that Member States ensure close collaboration across
their  different  government  departments  to  achieve  effective  and  coherent  transposition  and
implementation of this Article at national level.
3.4.2.  Smart recharging
The obligation of Article 20a(4) requires Member States to ensure that non-publicly accessible
recharging points that are installed from the transposition date of the Directive as new ones or
to replace existing ones can support smart recharging functionalities. They shall ensure that
private charging points installed from the transposition date of the Directive are smart i.e., allow
the intensity of the electricity delivered to the battery to be adjusted dynamically, on the basis
of information received through electronic communication.
Member States should set up incentives for EV users to make use of smart recharging, namely
support the emergence of smart recharging contracts in the market. They should ensure that

(59)  Standard finalised:  https://www.iso.org/standard/77845.html
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dynamic  price  contracts  are  available  to  final  customers,  as  stipulated  in  the  Electricity
Directive,  and  that  distributed  energy  resources  (such  as  car  batteries)  can  participate  in
balancing services, notably for grid congestion management.
Member States’ regulation should also encourage off-peak charging as a way to optimise the
use of the grid. By incentivizing EV owners to charge their vehicles during off-peak hours, it
would  avoid  excessive  strain  on  the  grid  during  peak  demand  times  while  promoting  cost-
effective charging for consumers. In that regard, charging points that operate off peak by default
should be encouraged.
Today,  EU  legislation  does  not  directly  regulate  direct  connection  of  charging  stations  to
renewable generation. Within the framework of energy system integration, taking electricity
from  the  grid  remains  the  most  efficient  way  to  optimize  production  from  renewables  and
recharging operations.
•  The revised Electricity Market Directive (EMD) has included measures to accelerate
grid  connections  (notably  (i)  the  framework  to  be  provided  by  MS  to  facilitate  the
connection  of  recharging  points  to  the  distribution  networks,  (ii)  the  publication  by
DSO,  within  three  months  of  the  submission  of  the  request,  of  information  on  the
capacity available for new connections including the capacity under connection request,
(iii) the possibility to request grid connection exclusively in digital form).
•  The Grid Action Plan also announced important measures such as support to system
operators by ENTSO-E and the EU DSO in digitalising and streamlining procedures for
grid connection requests (guidance and recommendations to  be issued by mid-2025)
and sharing of data by network users to support DSOs in the planning of network needs.
•  With the revision of the RED, the EU has also taken important measures to accelerate
the permitting for grid connections of RES and co-located storage projects.
Consequently, Member States are encouraged to:
-  ensure simpler streamlined procedures, when they exist, for connecting EV charging
points to the grid by setting in relevant legislation concrete provisions so that DSOs
have to respond in a reasonable amount of time to the request of new users requesting
grid connection (e.g. EVs, storage, RES…);
-  ensure that DSOs and TSOs regularly provide information on the available grid hosting
capacities in their areas as well as pipeline of grid connection requests, with as much
space and time granular information as possible, so that potential future networks users,
including charging point operators, can consider them in their planning and investment
decisions.
Member States should also ensure that relevant stakeholders involved in the planning for and
development of electromobility infrastructure (e.g., municipalities, transport authorities, private
entities) provide regular information to DSOs on future projects for e-charging infrastructure,
ahead of the grid connection requests, to support DSOs’ network development planning.
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3.4.3.  Interface with smart meters, where appropriate
Overall, smart meters can greatly facilitate demand response, by allowing consumers to increase
awareness of their energy consumption and providing granular and accurate data in a timely
manner to energy suppliers, that in combination with time-of-use tariffs and dynamic prices
incentivise the charging at times when demand is low or the renewable share is high. In that
regard, interfaces with smart metering systems are a necessary component of a smart recharging
system where such systems are deployed by Member States.
The Electricity Directive (60) provides in its articles 19 and 20 detailed requirements regarding
the deployment of smart metering systems.  Where smart metering systems are systematically
deployed after 4 July 2019, they should comply with the specific functionalities described in
article 20 and Annex II, including the capability of providing to final customers information on
accurate  actual  consumption  and  time  of  use.  Customers  should  be  able  to  have  access  to
validated historical consumption data and to non-validated near real-time consumption data.
Non-validated data should  be accessible through a standardised interface or through remote
access,  in  order  to  support  automated  energy  efficiency  programmes,  demand  response  and
other services (e.g. smart recharging). Consequently, for smart metering systems meeting the
requirements of Article 20 and Annex II of the Electricity Directive, Member States should
ensure that new and replaced non–publicly accessible normal power recharging points installed
in their territory can support the interface with smart metering systems.
The  Electricity  Directive  also  states  that  smart  metering  systems  that  do  not  meet  the
requirements of Article 20 and Annex II, shall not remain in operation after 5 July 2031.
Member  States  should  provide  practical  guidelines  with  certain  criteria  or  technical
specifications for ensuring the interface with smart metering systems.
Furthermore, according to Implementing Regulation (EU) 2023/1162 (61), for the provision of
non-validated near real-time data through a standardised interface, where applicable, Member
States shall have due regard for the use of relevant available standards, including standards that
enable interoperability. Without prejudice to future developments, standards available and in
use in national practices at the time of publication of the Implementing Regulation include the
following (non-exhaustive) list:
•  EN 50491-11
•  EN 62056 series – DLMS/COSEM
•  EN 13757 series – Wired and Wireless M-bus
•  EN16836 - Zigbee SEP 1.1

(60)  Directive (EU) 2019/944 on common rules for the internal market for electricity
(61)  In Annex, Table 3 – Procedure Conditions
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3.4.4.  Bi-directional recharging, where appropriate
Bi-directional recharging is defined as a smart recharging operation where the direction of the
electricity  flow  can  be  reversed,  allowing  that  electricity  flows  from  the  battery  to  the
recharging point that it is connected to. It therefore encompasses the main V2X applications,
namely Vehicle-to-Grid (V2G), Vehicle-to-Home (V2H), Vehicle-to-Building (V2B), etc.
Bi-directional recharging will help better integrate renewables in the energy system and make
the  grid  more  resilient,  while  providing  financial  benefits  for  consumers.  EVs  have  a  large
potential  to  ensure  flexibility  and  security  of  supply (62)  that  will  result  in  a  lower  carbon
intensity of the electricity system.
It is in the discretion of Member States or their designated competent authorities to define in
which cases private recharging points must support bi-directional recharging functionalities.
When defining this, Member States should take into account the provisions of Article 15(3) and
(4) of AFIR, that apply to both public and private recharging points and require undertaking
specific assessments related to bi-directional recharging by June 2024 and every three years,
namely on:
•  how the deployment and operation of recharging points could enable electric vehicles to
further contribute to the flexibility of the energy system (Article 15(3));
•  the potential contribution of bi-directional recharging to reducing user and system costs
and increasing the renewable electricity share in the electricity system (Article 15(4)).
It is also required by Article 15(3) and (4) of AFIR that Member States take into account the
results of the assessments mentioned above and make them publicly available, and if necessary,
take appropriate measures as regards ensuring consistency of infrastructure planning with the
corresponding  grid  planning  and  adjust  the  geographical  availability  and  distribution  of  bi-
directional recharging points in private areas.
Article 15(3) states that Member States may task the national regulatory authority to carry out
the  assessment,  while  for  Article  15(4)  it  is  required  that  the  regulatory  authority  needs  to
undertake  the  assessment  on  the  basis  of  input  from  transmission  and  distribution  system
operators.
To this end, Member States would need to take into account the recommendations stemming
from  those  assessments  under  AFIR  to  elaborate  on  cases  when  bi-directional  charging  is
feasible.
Cases where bi-directional charging might be the most relevant are:
•  When expected private benefits exceed costs - The expected benefits of bi-directional
recharging which would benefit the households/businesses owning the charging stations

(62)  EC (2019), Effect of electromobility on the power system and the integration of RES
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exceeds the additional costs of installing the charging infrastructure that allows for bi-
directional recharging.
•  When the size of the recharging infrastructure is large, for example in office spaces
and large residential buildings.
•  When  there  is  a  significant  potential  of  renewables  generation  -  Bi-directional
charging can store excess renewable energy and release it back to the grid when needed.
•  When flexibility is especially needed due to power grid congestion in a specific area
-  Bi-directional  charging  in  congested  areas  can  help  to  increase  the  production  of
renewables while reducing grid expansion needs.
•  When there is a specific need to enhance grid stability and reliability - Bi-directional
charging can support the grid by providing other services, such as voltage control and
emergency services.
•  When there are behind-the-meter storage or solar-PV in the building - Users could
be encouraged to allow bi-directional recharging functionalities if they have storage or
distributed renewables, as they would increase the benefits of bi-directional charging.
Fast charging points are not suitable for bi-directional charging operations.
Even though Article 20(4) does not set specific requirements on how to ensure smart and bi-
directional recharging for non-publicly accessible charging points, in addition to the technical
requirements,  Member  States  could  set  up  incentives  for  EV  users  to  use  bi-directional
recharging such as:
•  Provide financial (or other) incentives for installing bi-directional recharging points.
•  Enable  dynamic  pricing  (or  simpler  time  of  use  pricing  strategies)  to  encourage  EV
owners and users to  adjust the charging behaviour according to  the price signals.  The
Electricity  Regulation  and  Electricity  Directive  (Art.  11)  already  contain  certain
provisions  to  address  dynamic  pricing.  Introducing  time-differentiated  grid  tariffs  and
ensuring  that  vulnerable  consumers  are  protected  via  social  policy,  rather  than  price
interventions (as per Article 5(2) of Electricity Directive) would be key.
Member  States  also  have  to  avoid  double  charges,  including  network  charges,  for  stored
electricity  remaining  within  the  premises  of  active  customers  that  own  an  energy  storage
facility,  or  when  providing  flexibility  services  to  system  operators,  as  requested  in  Article
15(5) (63) of the Electricity Directive.

(63)  Member States shall ensure that active customers that own an energy storage facility: (a) have the right to a
grid connection within a reasonable  time after the request, provided that  all necessary conditions, such as
balancing  responsibility  and  adequate  metering,  are  fulfilled;  (b)  are  not  subject  to  any  double  charges,

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Member  States  should  also  enable  a  flexibility  market  for  distributed  energy  resources
(including storage) to improve coordination of bi-directional recharging initiatives and DSO
activities.
When implementing provision on smart and bi-directional recharging, it is crucial that Member
States abstain from adopting national standards or technical specifications and use instead the
existing European standards or requirements stemming from the internal market legislation to
enable a smooth European market of bi-directional charging. In particular, a communication
standard between EVs and recharging infrastructure to enable bi-directional charging, but also
facilitate  smart  recharging,  was  adopted  in  2022  (ISO  15118-20).  The  mandatory
implementation of this standard will be the subject of upcoming secondary legislation under
Regulation  (EU)  2023/1804  on  the  deployment  of  alternative  fuels  infrastructure(64).  It  can
already  be  implemented  on  a  voluntary  basis  by  car  manufacturers.  In  that  regard,  when
Member States deploy bi-directional recharging, EVs and recharging stations hardware should
rely on ISO 15118-20.
3.4.5.  E-roaming
Recital 56 of Directive (EU) 2023/2413 stresses that it is beneficial that EV users can use their
subscription to e-mobility services at multiple recharging points (“e-roaming”). This possibility
of e-roaming ensures consumer choice and facilitates charging operations for the user. Already
today, e-roaming is widely established and available at the vast majority of publicly accessible
recharging  points  throughout  the  Union.  Further  facilitating  e-roaming  at  privately-owned,
shared recharging points, such as those in the parking lots of hotels or offices, can also have
several  benefits.  EV  users  can  make  use  of  their  subscriptions  with  their  mobility  service
provider, increasing the convenience of charging. Furthermore, it would reduce the need for
EV  users  to  carry  multiple  cards  or  smartphone  apps  to  access  different  private  recharging
networks  to  which  the  EV  user  has  access  to.  Therefore,  Member  States  are  encouraged  to
assess the possibilities to further promote roaming at private recharging points (except for own
use), under the rules established in Article 5 of Regulation (EU) 2023/1804.
3.5.
Non-discriminatory access for small and mobile storage assets to the
electricity markets
3.5.1.  General overview of obligations in 20a(5)
Article 20a(5) requires that Member States ensure that the national regulatory framework allows
small or mobile systems (for example, EVs, electric bikes, electric cargo bikes, heat pumps,
solar  panels,  batteries  and  other  small  decentralised  energy  sources)  to  participate  in  the

including network charges, for stored electricity remaining within their premises or when providing flexibility
services to system operators; (c) are not subject to disproportionate licensing requirements or fees; (d) are
allowed to provide several services simultaneously, if technically feasible.
(64)  The Commission is planning, via a delegated act under AFIR to be adopted in 2024, to mandate that standard
on publicly accessible and non-publicly accessible recharging points.
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electricity markets, including for congestion management and for the provision of flexibility
and balancing services, including through aggregation. In addition, it is required that Member
States  provide  a  level  playing  field  and  non-discriminatory  participation  in  the  electricity
markets for small, decentralised energy assets or mobile systems.
Furthermore, Article 20a(5) requires that Member States, in close cooperation with all market
participants and regulatory authorities, establish technical requirements for the participation
of small or mobile systems in the electricity markets, on the basis of the technical characteristics
of those systems.
The  overall  objective  of  this  provision  is  to  increase  the  role  of  distributed  resources  by
enabling them to provide flexibility and balancing services to the grid with a view to increasing
the overall efficiency of the electricity grid.
Exploiting the full potential of distributed energy resources (such as domestic and EV batteries,
heat  pumps  or  PV  panels)  will  offer  considerable  flexibility  to  the  grid, in  order  to  balance
supply  and  demand.  Moreover,  such  resources  limit  investments  for  grid  expansion  due  to
increased electrification.
Recital 57 of the revised RED explains that in order to facilitate the development of flexibility
services provided by distributed energy resources, the regulatory provisions, such as the ones
related to tariffs, commitment times and connection specifications, should be designed in a way
that does not hamper the potential of all storage assets, including small and mobile ones and of
other devices for example, heat pumps, solar panels and thermal storage, to offer flexibility and
balancing  services  to  the  system  and  to  contribute  to  the  further  penetration  of  renewable
electricity,  in  comparison  with  larger,  stationary  storage  assets.  In  addition  to  the  general
provisions preventing market  discrimination  laid down in  the Electricity  Regulation  and  the
Electricity  Directive,  specific  requirements  should  be  introduced  to  address  holistically  the
participation of those assets and to remove any remaining barriers and obstacles to unleash the
potential of such assets to help the decarbonisation of the electricity system and empower the
consumers to actively participate in the energy transition.
More specifically, in relation to non-discriminatory participation of mobile storage systems and
other small decentralised energy assets in the electricity markets, recital 58 of the revised RED
states that this means that small assets are able to participate in all electricity markets, including
congestion  management  and  the  provision  of  flexibility  and  balancing  services  in  a  non-
discriminatory  manner  as  compared  to  other  electricity  generation  and  storage  systems,  and
without disproportionate administrative or regulatory burden.
3.5.2.  Detailed obligation
In relation to the specific technical requirements referred to in  Article 20a(5)  for ensuring
participation  in  the  electricity  markets,  a  number  of  technical  rules  under  the  Electricity
Directive and the electricity Regulation are currently being put in place and will provide the
basis  also  for  transposing  and  implementing  Article  20a(5).  The  most  relevant  is  the
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forthcoming  network  code  on  demand  response(65),  which  is  expected  to  be  adopted  as  a
delegated act by the Commission in 2025, and will provide the harmonised rules and necessary
clarifications  on  the  outstanding  issues,  including  on  facilitating  the  role  of  independent
aggregators  and  addressing  the  specific  particularities  of  small  storage  assets  such  as  EV
batteries.
Member States are encouraged to promote the use of load management systems as they have
benefits to distribute the load throughout time and between vehicles, and thereby avoid peaks
when several EVs are charged at the same location.
The following specific aspects are of particular importance when transposing and implementing
the above obligation:
1.  Participation  in  capacity  markets  –  Member  States  are  recommended  to  ensure
seamless  participation  in  capacity  mechanism  markets  for  distributed  assets,  by
lowering minimum bid sizes, lowering  minimum lead times between concluding the
allocation  process  and  start  of  delivery,  limiting  the  option  for  long-term  contracts
which favour conventional sources of capacity and larger assets over aggregators with
newer sources (e.g., France practices certification of capacity up to 2 months before the
year of delivery); limiting delivery periods (e.g., for specific seasons or hours of the
year);
2.  Local  flexibility markets  /  services,  including congestion  management  -  Member
States could mandate at national level common product definitions for other services
procured by DSOs on basis of the technical requirements set at EU level. This can be
achieved by market-based platforms for congestion management (e.g. GOPACS in the
Netherlands), which verify re-dispatching and load curtailment bids at national level (by
combining  relevant  congestion  management  actions  with  opposite  market  actions  to
balance the grid);

3.  Retail  market  distortions  –  Member  States  should  ensure  that  flexibility  of
small/mobile  assets  is  explicitly  mentioned  in  the  price  in  a  transparent  manner.
Therefore, flexibility would be unleashed by their owners and would become available
for aggregators for various flexibility services.
Member States could already start simplifying prequalification procedures that will be
addressed  in  the  network  code  on  demand  response.  It  allows  for  a  common  national
prequalification  across  all  markets,  applying  ex-post  verification  for  local  services  for
congestion  management  and  voltage  control  (by  reducing  the  prequalification  process  to  a
communication test, data exchange, financial aspects and legal provisions, e.g. as already done
in Estonia and France for some balancing products). It could also allow for different unit types
to  be  aggregated  within  the  same  product  and  reducing  requirements  for  similar  assets  of

(65)  Based on ACER Framework Guidelines on Demand Response, which be developed into a set of harmonised
EU-wide rules governing various aspects of demand side flexibility.
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aggregated  products,  and  reduce  pre-prequalification  requirements  in  the  case  of  product
changes. For example, in Spain, aggregator products are prequalified as a whole if individual
assets have capacity below 1MW.
Box 6 - Relevant aspects under the Electricity Directive and the Electricity Regulation
The  Electricity  Directive  puts  in  place  the  basic  rules  on  non-discriminatory  access  to
flexibility markets (Article 3), possibilities for (independent) aggregation (Article 13) and the
role of active customers (Articles 15-17) participating in the electricity markets (that own an
energy storage facility). It requires that Member States put in place appropriate measures to
ensure that distribution system operators are able to procure flexibility services from providers
of  distributed  generation,  demand  response  or  energy  storage.  It  also  puts  in  place  the
requirements for dynamic pricing availability (Article 11). Therefore, the full transposition of
the existing Electricity Directive should address the main barriers to non-discriminatory market
access for small and mobile systems and their aggregators to electricity markets and provide
good basis for implementation of provisions of Article 20a(5).
In addition, the Electricity Regulation (EU) 2019/943 contains provisions for functioning of
electricity markets in Article 6 (on the organisation of balancing markets), Article 18 (charges
for  network  access),  Article  20  (resource  adequacy),  and  Article  22  (capacity  mechanisms
design principles).
The legal provisions will be complemented by a network code on demand response specifying
conditions for small sources to be active in flexibility markets. It will set specific technical rules
at EU level to enable non-discriminatory market entry and participation in flexibility services
for various types of small and mobile systems including EVs and their aggregators. The network
code will clarify the framework and technical requirements for aggregators to fulfil their role at
EU  level,  e.g.,  defining  different  aggregation  models,  collecting  and  sharing  methods  to
quantify  the  provided  flexibility  (baseline  methodologies),  and  proposing  simplified
prequalification procedures and principles for the financial settlement of revenues generated by
flexibility.

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Annex I - Obligations under Article 20a
Article 20a - Facilitating system integration of renewable electricity

1.  Member States shall require transmission system operators and, if the data are available
to them, distribution system operators in their territory, to make available data on the
share of renewable electricity and the greenhouse gas emissions content of the electricity
supplied in each bidding zone, as accurately as possible in intervals equal to the market
settlement frequency but of no more than one hour, with forecasting where available.
Member  States  shall  ensure  that  distribution  system  operators  have  access  to  the
necessary data. If distribution system operators do not have access, pursuant to national
law, to all the data needed, they shall apply the existing data reporting system under the
European  Network  of  Transmission  System  Operators  for  Electricity,  in  accordance
with the provisions of Directive (EU) 2019/944. Member States shall provide incentives
for upgrades of smart grids to better monitor grid balance and make available real time
data.

If  technically  available,  distribution  system  operators  shall  also  make  available
anonymised and aggregated data on the demand response potential and the renewable
electricity generated and injected to the grid by self-consumers and renewable energy
communities.

2.  The data referred to in paragraph 1 shall be made available digitally in a manner that
ensures interoperability on the basis of harmonised data formats and standardised data
sets  so  that  it  can  be  used  in  a  non-discriminatory  manner  by  electricity  market
participants, aggregators, consumers and end-users, and that it can be read by electronic
communication  devices  such  as  smart  metering  systems,  electric  vehicle  recharging
points, heating and cooling systems and building energy management systems.

3.  In addition to the requirements laid down in Regulation (EU) 2023/1542, Member States
shall  ensure  that  manufacturers  of  domestic  and  industrial  batteries  enable  real-time
access  to  basic  battery  management  system  information,  including  battery  capacity,
state of health, state of charge and power set point, to battery owners and users, as well
as to third parties acting, with explicit consent, on the owners’ and users’ behalf, such
as building energy management undertakings and electricity market participants, under
non-discriminatory terms, at no cost and in accordance with the data protection rules.

Member  States  shall  adopt  measures  to  require  that  vehicle  manufacturers  make
available, in real-time, in-vehicle data related to the battery state of health, battery state
of charge, battery power set point, battery capacity, and, where appropriate, the location
of electric vehicles, to electric vehicle owners and users, as well as to third parties acting
on  the  owners’  and  users’  behalf,  such  as  electricity  market  participants  and
electromobility service providers, under non- discriminatory terms and at no cost, in
accordance with the data protection rules, and in addition to further requirements with
regard to type approval and market surveillance laid down in Regulation (EU) 2018/858
of the European Parliament and of the Council (*).

4.  In addition to the requirements laid down in Regulation (EU) 2023/1804, Member States
or  their  designated  competent  authorities  shall  ensure  that  new  and  replaced  non–
publicly  accessible  normal  power  recharging  points  installed  in  their  territory  can
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support smart recharging functionalities and, where appropriate, the interface with smart
metering  systems,  when  deployed  by  Member  States,  and  bi-directional  recharging
functionalities  in  accordance  with  the  requirements  of  Article  15(3)  and  (4)  of  that
Regulation.

5.  In addition to the requirements laid down in Regulation (EU) 2019/943 and Directive
(EU)  2019/944,  Member  States  shall  ensure  that  the  national  regulatory  framework
allows  small  or  mobile  systems  such  as  domestic  batteries  and  electric  vehicles  and
other  small,  decentralised  energy  sources  to  participate  in  the  electricity  markets,
including  congestion  management  and  the  provision  of  flexibility  and  balancing
services,  including  through  aggregation.  To  that  end,  Member  States  shall,  in  close
cooperation with all market participants and regulatory authorities, establish technical
requirements for participation in the electricity markets, on the basis of the technical
characteristics of those systems.

Member States shall provide a level playing field and non-discriminatory participation
in the electricity markets for small, decentralised energy assets or mobile systems.

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Annex II – Relevant definitions
Relevant definitions for Article 20a(1):
•  Distribution system operator is defined in Article 2(29) of Directive (EU) 2019/944
as a natural or legal person who is responsible for operating, ensuring the maintenance
of  and,  if  necessary,  developing  the  distribution  system  in  a  given  area  and,  where
applicable,  its  interconnections  with  other  systems,  and  for  ensuring  the  long-term
ability of the system to meet reasonable demands for the distribution of electricity;
•  Transmission system operator is defined in Article 2(35) of Directive (EU) 2019/944
as a natural or legal person who is responsible for operating, ensuring the maintenance
of  and,  if  necessary,  developing  the  transmission  system  in  a  given  area  and,  where
applicable,  its  interconnections  with  other  systems,  and  for  ensuring  the  long-term
ability of the system to meet reasonable demands for the transmission of electricity;
•  Bidding  zone  is  defined  in  Article  2(14a)  of  the  Revised  RED,  and  refers  to  the
definition  of  Article  2(65)  of  Regulation  (EU)  2019/943,  namely  the  largest
geographical area within which market participants are able to exchange energy without
capacity allocation;
•  Near real-time is defined in Article 2(26) of Directive (EU) 2019/944 in the context of
smart metering as a short time period, usually down to seconds or up to the imbalance
settlement period in the national market;
•  Market  settlement  frequency  is  equal  to  ‘imbalance  settlement  period’,  as  Article
2(15) of Regulation (EU) 2019/943;
•  Demand response is defined in Article 2(20) of Directive (EU) 2019/944 as the change
of electricity load by final customers from their normal or current consumption patterns
in response to market signals, including in response to time-variable electricity prices or
incentive payments, or in response to the acceptance of the final customer's bid to sell
demand reduction or increase at a price in an organised market as defined in point (4) of
Article 2 of Commission Implementing Regulation (EU) No 1348/2014, whether alone
or through aggregation;
•  Renewables self-consumers is defined in Article 2(14) of Directive (EU) 2018/2001 as
a final customer operating within its premises located within confined boundaries or,
where permitted by a Member State, within other premises, who generates renewable
electricity for its own consumption, and who may store or sell self-generated renewable
electricity, provided that, for a non-household renewables self-consumer, those activities
do not constitute its primary commercial or professional activity;
•  Renewable  energy  communities  is  defined  in  Article  2(16)  of  Directive  (EU)
2018/2001 as a legal entity, which, in accordance with the applicable national law, is
based on open and voluntary participation, is autonomous, and is effectively controlled
by shareholders or members that are located in the proximity of the renewable energy
projects  that  are  owned  and  developed  by  that  legal  entity;  (b)  the  shareholders  or
members  of  which  are  natural  persons,  SMEs  or  local  authorities,  including
municipalities; (c) the primary purpose of which is to provide environmental, economic
or social community benefits for its shareholders or members or for the local areas where
it operates, rather than financial profits.

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Relevant definitions for Article 20a(2):

•  Interoperability is defined in Article 2(40) of Regulation (EU) 2023/2854 as the ability
of two or more data spaces or communication networks, systems, connected products,
applications, data processing services or components to exchange and use data in order
to perform their functions;
•  Interoperability in the context of smart metering is defined in Article 2(24) of Directive
(EU)  2019/944  as  the  ability  of  two  or  more  energy  or  communication  networks,
systems,  devices,  applications  or  components  to  interwork  to  exchange  and  use
information in order to perform required functions.
Relevant definitions for Article 20a(3):
•  Domestic  battery  is  defined  in  Article  2(14g)  of  the  revised  RED  as  a  stand-alone
rechargeable  battery  of  rated  capacity  greater  than  2  kwh,  which  is  suitable  for
installation and use in a domestic environment;
•  Electric vehicle battery is defined in Article 2(14h) of the revised RED and is referring
to  Article  3(1),  point  (14)  of  Regulation  (EU)2023/1542,  namely  a  battery  that  is
specifically designed to provide electric power for traction in hybrid or electric vehicles
of category L as provided for in Regulation (EU) No 168/2013, that weighs more than
25 kg, or a battery that is specifically designed to provide electric power for traction in
hybrid or electric vehicles of categories M, N or O as provided for in Regulation (EU)
2018/858;
•  Industrial battery is defined in Article 2(14i) of the revised RED and is referring to
Article 3(1), point (13) of Regulation (EU) 2023/1542, as a battery that is specifically
designed  for  industrial  uses,  intended  for  industrial  uses  after  having  been  subject  to
preparation for repurposing or repurposing, or any other battery that weighs more than
5 kg and that is neither an electric vehicle battery, an LMT battery, nor an SLI battery;
•  State of health is defined in Article 2(14j) of the revised RED and is referring to Article
3(1), point (28) of Regulation (EU) 2023/1542, as a measure of the general condition of
a rechargeable battery and its ability to deliver the specified performance compared with
its initial condition;
•  State  of  charge  is  defined  in  Article  2(14k)  of  the  revised  RED  and  is  referring  to
Article  3(1),  point  (27),  of  Regulation  (EU)  2023/1542,  as  the  available  energy  in  a
battery expressed as a percentage of its rated capacity as declared by the manufacturer;
•  Power  set  point  is  defined  in  Article  2(14l)  of  the  revised  RED  as  the  dynamic
information  held  in  a  battery’s  management  system  prescribing  the  electric  power
settings  at  which the battery optimally  operates  during a  recharging or  a discharging
operation, so that its state of health and operational use are optimised;
•  Battery Management System is defined in Article 3(25) of Regulation (EU) 2023/1542
as an electronic device that controls or manages the electric and thermal functions of a
battery in order to ensure the battery’s safety, performance and service life, manages and
stores  the  data  for  the  parameters  for  determining  the  battery’s  state  of  health  and
expected  lifetime  and  communicates  with  the  vehicle,  light  means  of  transport  or
appliance  in  which  the  battery  is  incorporated,  or  with  a  public  or  private  charging
infrastructure.
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Relevant definitions for Article 20a(4):
•  Smart metering system is defined in Article 2(14c) of the revised RED  and is referring
to  Article  2,  point  (23),  of  Directive  (EU)  2019/944;  as  an  electronic  system  that  is
capable of measuring electricity fed into the grid or electricity consumed from the grid,
providing  more  information  than  a  conventional  meter,  and  that  is  capable  of
transmitting and receiving data for information, monitoring and control purposes, using
a form of electronic communication;
•  Recharging point is defined to in Article 2(14d) of the revised RED and is referring
to Article 2, point (48), of Regulation (EU) 2023/1804 as a fixed or mobile, on-grid or
off-grid interface for the transfer of electricity to an electric vehicle which, although it
may have one or more connectors to accommodate different connector types, is capable
of recharging only  one electric vehicle  at  a time, and which excludes devices with  a
power  output  less  than  or  equal  to  3,7  kW  the  primary  purpose  of  which  is  not  the
recharging of electric vehicles;
•  Smart  recharging  is  defined  in  Article  2(14m)  of  the  revised  RED  as  a  recharging
operation  in  which  the  intensity  of  electricity  delivered  to  the  battery  is  adjusted
dynamically, on the basis of information received through electronic communication;
•  Bi-directional  recharging  is  defined  in  Article  2(14o)  of  the  revised  RED  and  is
referring to Article 2, point (11), of Regulation (EU) 2023/1804 as a smart recharging
operation  where  the  direction  of  the  electricity  flow  can  be  reversed,  allowing  that
electricity flows from the battery to the recharging point it is connected to;
•  Normal power recharging point is defined in Article 2(14p) of the revised RED and is
referring to Article 2, point (37), of Regulation (EU) 2023/1804 as a recharging point
with  a  power  output  less  than  or  equal  to  22  kW  for  the  transfer  of  electricity  to  an
electric vehicle.
Relevant definitions for Article 20a(5):
•  Aggregation  is  defined  in  Article  2(18)  of  Directive  (EU)  2019/944  as  a  function
performed  by  a  natural  or  legal  person  who  combines  multiple  customer  loads  or
generated electricity for sale, purchase or auction in any electricity market;
•  Independent aggregator is defined in Article 2(19) of Directive (EU) 2019/944 as a
market  participant  engaged  in  aggregation  who  is  not  affiliated  to  the  customer's
supplier;
•  Distributed  generation  is  defined  in  Article  2(32)  of  Directive  (EU)  2019/944  as
generating installations connected to the distribution system;
•  Energy  storage  is  defined  in  Article  2(59)  of  Directive  (EU)  2019/944  as,  in  the
electricity system, deferring the final use of electricity to a moment later than when it
was generated, or the conversion of electrical energy into a form of energy which can be
stored, the storing of such energy, and the subsequent reconversion of such energy into
electrical energy or use as another energy carrier;
•  Flexibility is defined in Article 2(79) of the amended Regulation (EU) 2019/943 means
the  ability  of  an  electricity  system  to  adjust  to  the  variability  of  generation  and
consumption patterns and grid availability, across relevant market timeframes.

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