16/04/2026
Briefing

With total dispatch-down levels across Ireland at 14% in 2024 (PDF 1.1MB) and significant acceleration required to electrify heat, transport and industry, delivering and optimising use of the grid is critical to the success of Ireland’s energy transition and economic resilience.

There has been significant EU legislative momentum over the last decade to drive renewable energy rollout. Much has depended on the capacity of Member States to implement the solutions developed at EU level. In Ireland, there is a clear appetite to accelerate infrastructure delivery demonstrated, for example, by the Accelerating Infrastructure Plan (PDF 7.4MB) and Critical Infrastructure Bill.

Overview

Along with the European Commission’s Communication, the Grids Package includes two legislative proposals and two guidance notes. They are:

The Commission also published guidance on future proof network charges for reduced energy system costs and on the establishment of areas for grid and storage infrastructure necessary to integrate renewable energy into the electricity system.

This briefing focuses on the legislative proposals, which are aimed at improving planning of grid infrastructure, project cost-sharing, streamlining of permitting processes, efficient use of existing infrastructure (including through new technology, flexibility, and storage capacity), and resilience and security of cross-border infrastructure.

Accelerating permitting (amendments to the Renewable Energy Directive “RED”)

It is proposed to amend the RED to strengthen the existing permitting framework to make it more prescriptive, streamlined and deadline‑driven.

Main principles of the permit-granting procedure

Member States would be required to establish a single national digital portal for all the steps of the permit-granting procedures for renewable energy, storage and grid projects, through which applications and supporting documentation would be submitted and tracked, with enhanced transparency on procedural steps and compliance with permit‑granting timelines.

The portal would be required to ensure access to relevant environmental and geological data and decisions available through a single digital geographic information system‑based portal to be provided for under EU legislation. Subject to defined exceptions, certain procedural steps may be deemed approved where competent authorities do not respond within the applicable deadlines.

Repowering

The proposal would refine the framework for repowering by safeguarding the ability to repower existing installations where land status has changed, and by extending streamlined environmental assessment treatment to certain repowering projects that do not require additional land and continue to comply with existing mitigation measures.

Presumption of overriding public interest

Amendments aim to strengthen the presumption that renewable energy plants, their connection to the grid, related grid infrastructure and storage assets are in the overriding public interest for the purposes of balancing tests under the Habitats, Water Framework and Birds Directives, by removing previously applicable qualifications.

Amendments would also introduce a presumption that the above assets, as well as recharging stations, are to be treated as being in the overriding public interest and given priority when balancing legal interests other than those mentioned above, subject only to limited exclusions for cultural heritage.

Absence of alternative or satisfactory solutions and implementation of compensatory measures for the purpose of the Habitats Directive

A new provision is intended to clarify how key derogation tests under EU nature and water legislation are to be applied to renewable energy projects. The requirement to have no satisfactory alternatives would be met where no alternative solution exists that can deliver the same renewable energy capacity using the same technology, within the same or a similar timeframe and without significantly higher costs.

The proposal would also allow, in justified cases, for compensatory measures required under the Habitats Directive to be implemented in parallel with project delivery, provided it can be demonstrated that the project would not irreversibly affect the ecological integrity of the site or overall coherence of the Natura 2000 network prior to compensation being put in place. Compensatory measures could be adapted over time to reflect the timing of anticipated impacts.

Stand-alone energy storage other than hydrogen storage and recharging stations

New provisions would introduce dedicated permitting frameworks for stand‑alone energy storage (other than hydrogen storage) and for recharging stations. For projects with a total installed capacity above 100 kW, permit‑granting procedures (including grid connection permits and, where required, environmental assessments) would be subject to a maximum timeframe of six months. In the case of pumped hydropower storage, a longer permitting timeframe of up to two years would apply.

For stand‑alone energy storage installations and recharging stations with a total installed capacity of 100 kW or less, Member States would not require administrative permits, including on environmental aspects, (other than grid connection permits), subject to restrictions in Natura 2000 sites and other protected or cultural heritage areas. Those installations would also benefit from an exemption from the requirement to carry out a dedicated environmental impact assessment.

Hybridisation of renewable energy plants

‘Hybridisation’ would be defined as the conversion of a renewable energy plant that is not a hybrid plant into a hybrid plant behind the same connection point, with ‘hybrid plant’ meaning ‘a renewable energy plant that combines multiple renewable energy technologies, or that combines one or more renewable energy technologies with energy storage’.

A new provision would streamline permitting for the hybridisation of renewable energy plants by requiring any screening or environmental impact assessment, where applicable, to be limited to the potential impacts arising from the additional hybrid component. Subsequent changes in land use status would not prevent the continued operation or hybridisation of existing renewable energy projects.

Grid connections

A new provision would provide a consolidated framework for certain grid‑connection timelines. These include a three‑month deadline for repowering or hybridisation of existing renewable energy plants, subject to defined technical and safety exceptions.

More generally, system operators would be required either to grant a grid connection where sufficient capacity exists and system security is not compromised or, where capacity constraints arise, to propose a flexible connection agreement. Where a flexible connection is rejected by the developer, system operators would be obliged, on justified technical or safety grounds, to propose an alternative connection solution, an alternative provisional connection date, or to issue a formal refusal.

Renewables acceleration areas

There is a clarification that, when designating renewables acceleration areas, Member States would endeavour not to designate large areas where renewables and their related infrastructure are legally or de facto restricted for environmental reasons, including landscape protection. It allows the restriction where the Member State can demonstrate that the relevant types of renewable energy plants would result in irreversible damage which cannot be mitigated or compensated for through the environmental impact assessment process and, where applicable, appropriate assessment. The purpose of this is to avoid undermining the objectives of designating renewables acceleration areas.

The proposal also introduces targeted provisions on benefit‑sharing for renewable energy projects with an installed capacity above 10 MW, together with the availability of an independent facilitator in support of public participation.

Solar energy equipment

The proposed amendments are based on a differentiated approach to solar installations by scale and location. For installations above 100 kW located on existing or future artificial structures (provided that the primary aim of such artificial structures is not solar energy production or energy storage), permit‑granting procedures must not exceed three months. Those installations would also benefit from an exemption from the requirement to carry out a dedicated environmental impact assessment, provided the applicable conditions are met.

Accelerating permitting (amendments to the Electricity Market Directive)

The proposal would recast Article 8 of the Electricity Market Directive by introducing a detailed and deadline‑driven permitting framework for not only electricity generation capacity, but also electricity network infrastructure. It would extend accelerated permitting concepts to grid, including a general two‑year cap on authorisation procedures for transmission and distribution projects.

The replacement text would broadly align grid permitting methodology with the Renewable Energy Directive approach by strengthening the treatment of grid infrastructure as being in the overriding public interest, streamlining environmental assessment requirements for certain upgrades and reinforcements, recalibrating the application of the “absence of alternatives” test, and increasing flexibility around timing and adaptation of compensatory measures for grid projects under the Habitats, Water Framework and Birds Directives.

The proposal would repeal Article 51 of the Electricity Market Directive and re‑introduce its network development planning and investment‑enforcement framework in a consolidated provision. While the substance of the existing regime is largely maintained, there is more alignment with TEN‑E planning, cross‑sector coordination and the energy‑efficiency‑first and climate‑neutrality objectives.

Accelerating permitting (amendments to the Gas Market Directive)

In a similar vein, the proposal recasts Article 8 of the Gas Market Directive to tighten and formalise authorisation procedures for natural gas facilities, hydrogen production facilities and hydrogen system infrastructure, aligning permitting more closely with the approaches adopted under the Electricity Market Directive and the Renewable Energy Directive.

TEN-E Regulation

The TEN-E Regulation lays down rules for development of Projects of Common Interest (“PCIs”) and Projects of Mutual Interest (“PMIs”), intended to ensure interoperability of trans-European energy networks, functioning of markets, security of supply and integration of renewable energy. It seeks to provide streamlined permit granting and regulatory assistance, cross-border allocation of costs and risk-related incentives, and access to financing from the Connecting Europe Facility (“CEF”).

For Ireland, the TEN‑E framework is of particular importance in supporting strategic interconnection.

The Commission has proposed a revision of the TEN-E Regulation in light of objectives in the Clean Industrial Deal and European climate law, aiming to:

  • ensure that PCIs/PMIs address identified infrastructure needs with due consideration of non-wire solutions (defined as investments in the Annex II infrastructure in electricity which can increase grid capacity or improve efficiency of operation by deploying grid enhancing technologies),
  • facilitate the use of cost-sharing tools for faster project delivery,
  • simplify and accelerate permit granting procedures for PCIs/PMIs, 
  • enhance physical and cyber security and resilience of cross-border energy infrastructure, and
  • simplify the TEN-E Regulation and reduce compliance and regulatory costs where possible.

Some of the main changes proposed to be made to the TEN-Regulation are summarised below.

PCIs/PMIs

The proposal would simplify the process for projects to remain on the PCI or PMI lists where they continue to satisfy the applicable eligibility criteria.

In relation to PMIs, the proposal would clarify the treatment of projects involving non-EU countries by confirming that cost‑benefit analysis may take account of relevant impacts arising outside the EU, and that the geographical scope of a PMI may extend, where technically necessary, to the first connection point in the third country, together with any complementary investments required for assessment purposes.

More generally, the proposal would introduce strengthened implementation and monitoring requirements for PCIs and PMIs, including an obligation on project promoters to submit an implementation plan within two months of inclusion on the Union list, and requirements relating to physical and cyber‑security risks.

Permit-granting and public participation

The revised TEN‑E Regulation refines the permit‑granting and public participation framework for PCIs and PMIs, with a focus on earlier coordination, clearer procedures and improved efficiency. For certain electricity infrastructure projects, the revision would codify a rebuttable presumption of overriding public interest and public safety for the purposes of specified EU environmental balancing tests, subject to strict conditions.

The revised framework also reinforces the designation of a single national competent authority to coordinate the permit‑granting process. It would introduce several features including a time limit of 42 months (subject to suspensions and extensions).

Cross-sectoral infrastructure planning

The revised TEN‑E includes provisions to strengthen cross‑sectoral planning by introducing common scenarios, enhanced needs identification by ENTSO-E and ENNOH, and a new electricity‑sector needs‑matching process to address gaps in EU Ten Year Network Development Plans (“TYNDP”). It is worth noting the proposal to prolong the current two-year TYNDP cycle to four years, albeit that there is flexibility for updates if needed.

Offshore grids

Revised provisions are intended to strengthen the content of existing cooperation frameworks by explicitly extending them to cover coordinated planning of offshore renewable generation alongside offshore grid development. Member States would be required, as part of their non-binding agreements (for example on North Seas Energy Cooperation), to consider establishing specific cross-border goals, such as for hybrid or cross-border radial projects, to achieve the goals for offshore renewable generation to be deployed within each sea basin in the most efficient manner.

Regulatory framework

There are provisions to strengthen the regulatory framework for cross‑border energy infrastructure by further specifying principles to be applied by national regulatory authorities in cross‑border cost allocation (“CBCA”), including that costs should, where appropriate, be allocated in line with the distribution of net benefits. Provisions also look to enhance regulatory cooperation and consistency by facilitating the bundling of related PCIs and PMIs, strengthening ACER’s supporting role on cross-border cost allocation practices, and providing for the targeted use of congestion rents to support projects addressing interconnector congestion.

Financing

Eligibility for CEF Energy funding has been closely linked to cross‑border cost allocation decisions taken by national regulatory authorities. That model is not suitable for all infrastructure categories addressed by the revised TEN‑E Regulation, particularly where projects fall within the competence of a single national regulatory authority and therefore do not receive a CBCA decision (for example certain offshore grid components, smart grid or storage‑related projects). The revised Regulation addresses this by providing for a substitute evaluation mechanism and the conditions under which such projects may be assessed for CEF funding.

Next steps

Legislative discussions are underway in both the Council and the European Parliament on the EU Grids Package proposals. Once each institution has adopted a consolidated negotiating position, inter‑institutional negotiations will follow with a view to agreeing a final text. In parallel, the Commission guidance documents published alongside the legislative proposals are already applicable and are intended to shape regulatory and System Operator practice in advance of full adoption of the legislation.

The ultimate effectiveness of the package will depend heavily on national‑level implementation, both in terms of transposing new legal requirements and mobilising the institutional, regulatory and operational capacity required to ensure that the reforms are meaningful and accessible to industry.

In Ireland, continued evolution of grid, market and planning frameworks will be necessary if the Grids Package is to deliver its intended benefits in practice. A clear example is hybridisation, the potential of which cannot yet be fully realised within the existing Irish regulatory and grid‑connection framework.

Against that backdrop, Ireland’s forthcoming EU Presidency in the second half of 2026 presents a timely opportunity to engage constructively in shaping the final contours of the Grids Package and to align domestic reform priorities with the accelerated direction of EU‑level grid and infrastructure policy.