CEER Finds National Legal Frameworks Still Unadapted as Rising Volumes of Renewables Exit Support Schemes

CEER published its latest (4th) report on unsupported RES installations, based on an autumn-2025 questionnaire to all national regulatory authorities (NRAs). The report updates prior 2021 and 2024 assessments and concludes that, compared with the last edition, no major changes have been made to legal frameworks or market models governing RES installations that have reached the end of their support period (EOS) or that never received support, even as the volume of such capacity is set to grow significantly through 2030.

A growing wave of RES capacity (notably onshore wind, with ~18 GW expected to exit support across reporting countries between end-2025 and end-2030, led by Spain with ~12 GW) is losing feed-in support and must integrate into ordinary market arrangements, including full balancing responsibility. CEER flags that legal frameworks largely do not yet distinguish supported from unsupported RES, that balancing responsibility is viewed as the major emerging challenge (especially for small producers), and that decommissioning remains a live risk if market/legal conditions are not adapted — directly affecting future liquidity, balancing costs and the number of active market participants in European electricity markets.

This CEER report is a monitoring/diagnostic output rather than a concrete rulemaking, but it signals an emerging structural market-design issue: a large and growing cohort of RES generators moving from supported, often balancing-exempt regimes into full market exposure. The report documents heterogeneous national responses — ranging from no change (most MCs) to targeted interventions (Czech Republic's RED III-driven overhaul of GO rules and 15-minute electricity-sharing framework, Germany's free-of-charge surplus offtake option for small PV, Hungary's 'brown premium' for biomass/biogas, Italy's minimum guaranteed prices, Poland's extended support duration, Portugal's aggregator-of-last-resort). The recurring theme — balancing responsibility becoming a binding constraint for small/variable generators — suggests downstream pressure for new flexibility products, aggregation models, and possibly dedicated balancing arrangements for EOS installations. Because CEER explicitly finds 'no major enacted or planned changes' at EU level, this should be tracked as a pre-regulatory problem-identification stage; any future EU-level harmonization effort (e.g., via ACER/Commission follow-up, or a subsequent CEER paper) would represent the next concrete design milestone.

National RES support legislation (FiT/FiP schemes), RED III transposition (e.g., Czech Energy Act No. 458/2000 Coll. and RES Act No. 165/2012 Coll. amendments), national balancing and dispatch rules

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