accommodated by the existing network. This causes a
in specific areas.
major delays in projects to expand the electricity grid.
market.
for maintenance.
a growing logistical challenge and cost.
on maintenance.
experience capacity constraints.
pylons or theft of valuable materials (e.g. copper)
grid in the Netherlands.
together with regional electricity system operators.
first-come-first-served principle.
without sacrificing the pace of our work.
accelerate the speed and efficiency of maintenance.
partners.
commitments.
• Growing political support to reduce permitting time.
Regulatory risk Risk-mitigating actions
General
• The grid fees have increased significantly in the current years
(mainly due to high energy prices) and will further increase
because of the investments needed to facilitate the energy
transition.
• Inability to meet increasing efficiency targets over time as
imposed by incentive regulation, especially considering a
strongly growing company and the need for significant
investments in grid expansion, maintenance, operation as
well as innovation.
• Undercoverage of the regulatory CAPEX remuneration driven
by a non-reasonable return on invested capital and an
increasing investment portfolio which could lead to more
difficulties in financing and raising sufficient funding.
• Non-compliance with the current regulatory framework.
New regulatory and legal obligations have to be implemented.
The flow of information on new regulatory and legal
requirements must be ensured.
• TenneT aims to address the affordability issue by 1) being
transparent on the financial implications of the current plans
to the relevant stakeholders, 2) ensuring efficient roll-out
strategies of assets (i.e. 2 GW offshore program, hybrid
assets) and 3) working on efficient ancillary services markets.
• TenneT performs regular reviews of its processes and
organisational structure, introduced lean management and
carries out continuous improvement activities. TenneT also
prepares make-or-buy decisions in its investment process to
optimise value for money to society and conducts strategic
dialogues with regulators (ACM, BNetzA, ACER),
policymakers and industry partners/suppliers to co-shape its
future regulatory framework.
• TenneT’s strategy is to seek mutually acceptable results with
the regulator and further stakeholders. However, if needed to
protect pivotal strategic positions on solid legal grounds, legal
action may betaken.
• Onboarding of new employees on relevant topics.
Europe
• The ‘Clean Energy Package’ (CEP) entered into force.
Itrequires amongst others that TSOs provide 70% of the total
cross-border transmission capacity to the market, an amount
difficult to achieve without extensive and costly redispatch
activities.
The German government introduced an action plan
to gradually achieve this target by 31 December 2025. Delays
in fulfilment of this plan by TenneT could lead
to material financial penalties.
Similarly, the Dutch Ministry of Economic Affairs & Climate
Policy has issued an action plan to gradually achieve the 70%
target by 1 January 2026, which also contains derogations
forTenneT.
• In Germany TenneT keeps the capacity requirements along
the ‘trajectory’ as defined in the national ‘action plan’. This
means stepping up to full 70% using instruments such as
coordinated redispatch and countertrade.
• In the Netherlands, TenneT monitors compliance against the
action plan, with regard to the conditions of the derogation.
TenneT reports on issues to the ACM and the Ministry of
Economic Affairs & Climate Policy, if any.
The Netherlands
• ACM has performed a consultation for the new Regulatory
Period starting in 2027. ACM intends to revise the regulatory
method to better account for the implications of the energy
transition. The efficiency assessment and future estimations
of the OPEX development remain challenging topics.
• Increasing congestion in the TenneT grid puts pressure on
TenneT to open up any remaining grid capacity and propose
regulatory changes if needed.
• TenneT appreciates the open vision ACM has taken towards
the new regulatory period and will support the process by
preparing consultation responses that include implementable
regulatory improvements to the current challenges. In the
consultation process TenneT will address its main concerns
with the current method being: 1) Regulation of Operational &
IT Expenditure 2) The use of the international TSO benchmark
which does not provide sufficiently robust efficiency incentives
3) Regulation of innovations.
• TenneT asserted a pro-active role within the national action
plan on grid congestion and develops new options in
cooperation with stakeholders. Early results are a proposed
implementation of time-of-use tariffs and time dependent
transmission rights.
Germany
• Due to the rise of the financing costs on the capital markets
since 2022, the BNetzA intends to increase the return on
equity (RoE) in the 4th regulatory period compared to the
initial determination of 5.07% (before corporate tax). However,
adjustments are only planned for a minor part of TenneT’s
investments. The RoE of 5.07% will be applied to the
remaining investments. The reduction compared to a RoE of
6.91% in the 3rd regulatory period will have a significant
negative impact on TenneT's cash flow and revenues.
• Following the European Court of Justice decision on the
independence of the BNetzA, the energy industry law was
changed in 2023 to give more decision-making power to the
BNetzA. The previously relevant legal ordinances, will remain
in force for a transitional period until the end of 2028.
However, the BNetzA can already deviate from these.
Furthermore, BNetzA announced a broad consultation
on changes of the regulatory framework.
• TenneT challenges the concept of the BNetzA and will
examine legal steps to achieve an adjustment of the RoE for
all investments in the 4th regulatory period. TenneT
established an internal working group including colleagues
from its regulatory, legal and political departments to
accompany the political process. Amongst others, TenneT
engages in the German Association of Energy and Water
Industry (BDEW) to support profound analysis and advocacy
work within the network industry.
• TenneT actively participates in public and expert discussions
and positions itself as a competent partner and trustful
advisor to the regulators and policymakers.
Drive the energy transition
Risks Mitigating measures
• Accidental release of Sulphur hexafluoride (SF
6
), used as a
highly effective insulator and extinguisher in switching
installations, is extremely damaging for the environment.
• Market availability is tight, with limited options available that
can substitute the properties of SF
6
at the extra-high-voltage
level.
• Grid losses could increase in coming years as we transport
more electricity and over longer distances.
• From a regulatory perspective, TenneT is not reimbursed for
the costs related to greening our grid losses in Germany. With
high prices for guarantees of origin, this affects our ability to
green as much of our grid losses.
• An ageing grid could lead to a higher risk of more oil leakages
and environmental incidents.
• Firm emission reduction goals for 2030.
• Progress continues in devising a new circularity strategy and
increasingly implementing circularity requirements in our
tenders and our procurement strategies.
• Life Cycle Assessments (LCAs) to provide answers to
questions over the provenance of materials, where the biggest
CO
2
bottlenecks are along a supply chain, and how we can
work with suppliers to reduce them.
• Environmental Cost Indicator (ECI) to incentivise our suppliers
to reduce the environmental impact of the products and
services we buy from them.
• To improve the environmental impact of our usage of materials,
we are increasingly implementing circularity requirements in our
tenders and our procurement strategies.
Opportunities
• New technologies and European collaboration to foster for instance cross-border solutions, multi-hubs and sector coupling.
• We are investigating how copper from TenneT transformers could be used to create new ones.
• Sustainability criteria can also stimulate innovation.
Safeguard our fi nancial health
Risks Mitigating measures
• The total financing requirement (debt and equity) is increasing
because of growth of our CAPEX programme in the
Netherlands and Germany.
• Misalignment between the strategic view of TenneT and the
regulatory framework resulting in the situation that not all our
long-term investment costs and our operational costs might
be covered by regulatory reimbursements.
• The rising OPEX costs incurred might not be in sync with the
allowed OPEX revenues.
• The costs for ancillary services remain at a high level,
because of high congestion management costs following
the Russia-Ukraine war.
• Exposure to credit risks or write-offs if one or more of our
partners get into financial difficulties.
• Incorrect application of (new) laws and regulations could lead
to potential errors in our financial or non-financial reporting.
• Implementing a regulatory framework to support our strategy
and by delivering a return in line with what our capital providers
expect.
• Active cost control to strive for an efficient operation to lower
OPEX expenditure as far as reasonably possible.
• Raise required external financing.
• TenneT as a company is not seeking short-term profits.
We invest for periods of 20 to 40 years or more.
• Stress testing of hypothetical worst-case scenarios and to
address any potential high risk following from the analysis.
• Implementation and control effectiveness check of our internal
controls for the financial / non-financial reporting processes.
• Support by external consultants/specialists on CSRD topics
and implementation.
Opportunities
• Investments in green businesses and economies are increasingly favoured by large investors and banks (e.g. institutional).