5 Meeting ACER’s Scenarios Framework Guidelines, Addressing Opinion 05-2024 and critical European Commission feedback //

With the document “Framework Guidelines for the joint TYNDP scenarios to be developed by ENTSO for Electricity and ENTSO for Gas “TYNDP Scenarios Guidelines””, issued on 23 January 2023, ACER established criteria for a transparent, non-discriminatory and robust development of scenarios in the context of the European energy networks development. As the publication of ACER’s TYNDP Scenarios Guidelines interfered with the TYNDP 2024 Scenarios cycle, the guidelines could not be completely accounted for. Thus, the TYNDP 2026 Scenarios are the first cycle in which the TYNDP Scenarios Guidelines were followed from the beginning of the development process.

The ACER “TYNDP Scenarios Guidelines” are grouped into criteria for timely scenario preparation process, criteria for robust objective-driven scenarios, and criteria for a transparent, inclusive and streamlined development process. The document further contains guidelines on how to ensure stakeholder scrutiny, timely updates, and reporting requirements on how the guidelines were implemented.

ENTSO-E and ENTSOG have ensured that the TYNDP 2026 Scenario is fully aligned with ACER’s TYNDP Framework Guidelines, demonstrating a robust and transparent methodology that meets all applicable regulatory expectations. Throughout the process, both organisations have proactively and systematically addressed critical regulatory and legislative feedback to the widest extent possible, integrating stakeholder input and regulatory recommendations wherever feasible while clearly justifying any remaining constraints. As a result, the TYNDP 2026 Scenario reflects a high level of compliance with the European regulatory framework, supports informed decision‑making at EU and national level, and fully adheres to all regulatory requirements.

To capture the ENTSOs’ compliance with the requirements of ACER’s Scenarios Framework Guidelines¹, ENTSOG and ENTSO-E implemented a structured scenario development process that addressed each of ACER’s guideline specifications. A table summarising the defined criteria and how the ENTSOs implemented those in the TYNDP 2026 scenario cycle can be found in the Annex III. Additionally, a summary of critical feedback points provided by ACER’s Opinion 05-2024 on the TYNDP Scenarios 2024 is addressed in the Annex III. In the TYNDP 2026 scenario cycle, the ENTSOs further paid due attention to incorporating key comments from the European Commission, addressing the European Commission’s justification on the approval of the joint Scenarios Report for the 2024 TYNDP; this has been addressed to the greatest extent possible and is summarised in Annex IV.