The Whole Picture Matters: Rethinking Efficiency Assessments

Energy Traders Europe’s response to ACM’s Concept Jaarplan Procestoetsing 2027

Brussels, 13 July 2026 – Energy Traders Europe welcomes the opportunity to comment on ACM's 2027 Process Assessment Plan. While we support the ACM's objective of strengthening oversight of network operator processes and recognise the value of understanding how network operators organise and govern key processes, the proposed approach appears too limited for drawing meaningful conclusions regarding cost efficiency. Please find our detailed comments below.