Response to the assessment review of the Imbalance Settlement Harmonisation Methodology

While implementation has progressed, we see opportunities to improve practical application and focus on the progress of harmonisation. We are concerned about TSOs taking different approaches with specific and increasingly complex solutions. We encourage TSOs to find solutions aligned with the European methodology and common principles.

Coherence and transparency are key; we support TSOs’ recommendations for clarification within the text to make interpretation and implementation more coherent across Europe.

As recommended in our flagship report, Integrate by 28, more can be done based on the methodology and implementation with very different price structures across Europe. We advocate for a truly harmonised imbalance pricing methodology implemented in Europe, with the real cost faced by customers when electricity is not delivered is well reflected in the price. This needs the coordination of ACER and National Regulatory Authorities based on a TSOs’ proposal.

This call for harmonisation is about finding the best practices and having them be replicable and clearly have system differences accounted for via explicit flexibility. Harmonisation is not just relevant to market participants active in several markets but to anyone active in cross-border trading for achieving a level playing-field.