Brussels, 11 September 2025
EREF welcomes the Commission’s initiative to develop a Citizens’ Energy Package (CEP).
Citizens and communities must be recognised as structural market actors, with enforceable
rights and practical access to markets and infrastructures. Ensuring non-discriminatory grid
access and fair participation opportunities for citizens, SMEs, cooperatives and energy
communities is essential for a 100% renewable, decentralised, and resilient energy system.
Unlocking this potential also delivers clear system-wide benefits. Energy communities and
citizen participation reduce overall expenditure on energy by lowering infrastructure costs,
alleviating price volatility, and enabling affordable price levels for consumers, if the overall
energy system architecture is aligned with a more distributed and decentralised, approach
and specificities of renewable production cycles and combined with high efficient storage
technologies for all sizes and for all application needs, from short-term to long-term storage,
and high grid intelligence. Renewables strengthen Europe’s resilience, reduce dependency on
outside supply through shorter supply chains and local value creation, support domestic
labour markets, and increase public support for renewable energy projects. Smart energy
management in combination with storage, demand response, and energy sharing can avoid
costly grid extensions, while broadening the base of active participants enhances Europe’s
energy security. Citizens’ renewables respond to the societal responsibility to care for local
renewable energy demand and supply.
EREF has long emphasised the untapped potential of Europe’s energy citizens. Already in 2016,
CE Delft calculated that around 83% of EU households (an estimated 187 million) could
actively participate in the energy system, either by producing renewable electricity, storing
energy, or providing demand-side flexibility. The study showed that more than half of
households could generate energy, while even more could contribute flexibility through electric
vehicles, smart boilers, or stationary batteries. Nearly a decade later, part of this potential has
been realised through more than 9,000 energy communities across Europe. Yet much remains
untapped, and only the implementation of effective operational frameworks in Member States
will allow the full realisation of citizen participation in practice.
Diagnosis: from good legislation to effective implementation
The EU has adopted robust legislation on citizens’ participation in the energy transition, first
through the 2019 Clean Energy Package, through the Renewable Energy Directive II/III and the
reform of the Electricity Market Design. The challenge is no longer the absence of legislation,
but the absence of full transposition into national frameworks, and also of effective and
uniform implementation. Rights granted on paper often remain inaccessible in practice.
EREF is participating in the RESCHOOL project consortium, which focuses on empowering
energy communities as relevant actors in the energy value chain, as collective self-consumers,
providers, and prosumers. The project supports four pilot energy communities in Girona,
Amsterdam, Stockholm, and Athens/Rafina, providing insights into the integration of energy
communities into European energy markets and systems. First findings illustrate persistent
barriers across different regulatory contexts across Member States (link to full report):
● Netherlands: A long tradition of energy cooperatives is now reinforced by the new
Energy Act, which legally recognises communities and active consumers. Yet severe
grid congestion, rising connection costs, and the phase-out of net metering create
major risks for the viability of community projects. Despite legal progress, communities
still lack practical access to flexibility markets and revenue streams.
● Sweden: Energy communities remain without a clear legal definition. While demand for
local self-consumption is rising rapidly, and pilots such as in Hammarby Sjöstad are
pioneering virtual sharing, transposition of EU rules is incomplete. Without swift
reforms, initiatives remain marginal and excluded from markets despite the potential to
relieve grid stress.
● Spain: The self-consumption framework is highly developed and citizen participation is
growing, but energy communities lack an enabling framework. Definitions exist only on
paper, and reforms on aggregation and flexibility are still pending. Communities,
therefore, rely on collective self-consumption schemes with limited scope, while
regulatory uncertainty holds back their expansion.
● Greece: Thousands of energy communities have been established, supported by
ambitious legislation, but grid saturation and confusing parallel legal definitions
undermine their impact. Pending reforms on virtual net billing and access to finance
will determine whether communities can remain viable actors or be sidelined by
incumbents.
Across these cases, the picture is consistent: the EU’s legal framework is sound, but
incomplete and/or inconsistent transposition, administrative barriers, real or alleged grid
congestion, and lack of effective market mechanisms mean citizens cannot yet act as genuine
participants in the energy system.
Policy recommendations
EREF strongly recommends the Commission to use the Citizens’ Energy Package to create
more certainty in frameworks and help Member States, including through dedicated guidances
and recommendations, in setting up the necessary enabling frameworks:
- Ensure full and uniform implementation of EU law: establish robust monitoring and
enforcement mechanisms for citizen and community rights under RED II/III and the
Electricity Market Design, with indicators and annual Commission reporting linked to
EU governance processes such as the NECPs and the European Semester. - Strengthen the legal status of energy communities: recognise them as distinct market
actors with defined rights and responsibilities. Provide dedicated guidance
distinguishing energy communities as organisational forms from energy sharing as an
activity, to avoid confusion and dilution. - Ensure citizens’ access to local flexibility markets: citizens, communities and SMEs
must be able to participate in and benefit from local flexibility markets. This requires
defining tradable flexibility products and guaranteeing fair remuneration for demand
response and congestion management, thereby reducing grid stress and unlocking
demand-side potential. - Invest in decentralised and digitalised grids: adapt infrastructures to distributed
generation and energy sharing. Require DSOs to assess non-wire alternatives before
reinforcement and to procure standardised flexibility products, including storage, open
to small actors, in synergy with the forthcoming European Grids Package. - Remove administrative barriers: establish one-stop shops for citizens’ initiatives at
national/regional level and simplify permitting/licensing with proportional
requirements. - Ensure dedicated and accessible financing windows: create funding streams tailored
to citizen and SME initiatives, with single access points and technical assistance to
overcome complexity. Tariff and connection cost structures must be proportionate so
that smaller projects are not priced out. - Support workforce development: invest in skills and reskilling for local jobs in
renewable energy, flexibility provision and system operation, ensuring that citizens-led
projects can be delivered at quality and scale. - Safeguard the integrity of citizen initiatives: frameworks must ensure that energy
communities remain citizens-led, transparent and locally rooted, with governance
safeguards that prevent misuse of the label without overburdening smaller actors. - Integrate citizen energy into regional and national planning processes: distribution
development plans, Renewable Acceleration Areas, and other sectoral plans should
explicitly reflect the role of energy communities and citizens’ participation as
contributors to national targets. - Guarantee citizens’ information rights: fully implement the Market Design provisions
on transparent billing, clear contractual information, and access to consumption data.
Citizens must be able to compare offers, switch suppliers without barriers, and
participate in energy sharing or community schemes on an informed basis.
The CEP is a crucial opportunity to consolidate citizens, SMEs and communities as relevant
pillars of Europe’s renewable energy transition. EREF urges the Commission to ensure existing
rights are effectively implemented, barriers removed, and smaller actors given
non-discriminatory access to markets and infrastructures. Only then can Europe realise the
vast potential of citizens to deliver a decentralised, cost-efficient and resilient energy system.
For more information, please contact
Prof. Dr. Dörte Fouquet
Director
doerte.fouquet@eref-europe.org
Dirk Hendricks
Secretary General
dirk.hendricks@eref-europe.org