TenneT Publishes First Dutch Flexibility Needs Assessment (FNA) for 2030/2035 Under EU Electricity Market Design Reform

TenneT, acting as the Dutch designated entity under Article 19e of the recast Electricity Regulation (EU 2024/1747), together with the Dutch DSOs (Coteq, Enexis, Liander, RENDO, Stedin, Westland Infra), has completed and published the first biennial Dutch Flexibility Needs Assessment (FNA) report covering target years 2030 and 2035. The report applies the ACER-approved FNA methodology (adopted July 2025) and the VVT 'Delayed Transition' scenario to quantify system-level flexibility needs (RES integration, ramping, short-term), TSO network needs and DSO network needs, and to analyse market barriers to flexibility across balancing, congestion management and wholesale markets. ACM, as approving authority, is referenced via a related same-day publication on its approval of the report.

The FNA is a new EU-mandated analytical cornerstone that will determine whether the Netherlands introduces an indicative national non-fossil flexibility target and potentially a non-fossil flexibility support scheme under Articles 19f/19g. It quantifies significant uncovered TSO network flexibility needs (up to 13.8 TWh upward in 2030) despite no structural system-level shortfall, signalling that congestion-driven flexibility products, DSO-TSO coordination, and removal of market-access barriers for storage and demand response will become central to Dutch market design over the next investment cycle.

This is the foundational evidence base for subsequent Dutch flexibility market design interventions mandated by the EMDR. Because system-level needs are assessed as fully covered under the VVT scenario while network-level (especially TSO) needs remain large and location-specific, the report effectively shifts the Dutch flexibility policy debate from aggregate non-fossil flexibility targets toward grid-congestion-specific flexibility procurement design, DSO-TSO fine-tuning (Article 14 methodology), and barrier removal in balancing and congestion management products identified in Chapter 5. The explicit linkage to a possible capacity remuneration mechanism and non-fossil flexibility support schemes if market-based investment lags (e.g., in batteries, which the report flags as uncertain) indicates this FNA will directly shape the policy track for Dutch flexibility and adequacy market design over 2026-2028.

Regulation (EU) 2024/1747 amending Regulation (EU) 2019/943 (recast Electricity Regulation), Articles 19e, 19f and 19g; FNA methodology jointly developed by ENTSO-E and the EU DSO Entity and formally adopted by ACER in July 2025

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