TenneT reports on long-term methodologies and grid projects to resolve loop-flow-driven Article 16(8) derogation in the Netherlands

TenneT TSO B.V. submitted a report to ACM on 11 August 2026, as a mandatory condition of the derogation ACM granted on 9 December 2025 (Art. 16(9) of Regulation (EU) 2019/943) for 2026, detailing the methodologies and grid projects intended to structurally resolve loop-flow-driven operational security risks on Dutch cross-zonal network elements (CNECs) that prevent TenneT from meeting the 70% minimum cross-zonal capacity requirement of Article 16(8).

The report documents that TenneT still cannot reliably meet the EU-mandated 70% minimum cross-zonal capacity threshold because of uncoordinated loop flows originating in neighbouring bidding zones (notably Germany), and that the structural remedies (coordinated capacity-calculation and redispatch methodologies, grid investments, potential bidding-zone reconfiguration) will not be fully operational until 2029-2030. This sustains reduced cross-zonal trading capacity on Dutch borders for years, directly affecting day-ahead price convergence, congestion income, and cross-border redispatch coordination across the Core CCR.

This is a multi-year, multi-instrument regulatory compliance track combining (1) an annually renewed Article 16(9) derogation mechanism, (2) four interlocking coordinated methodologies under CACM/SOGL (Core DA CCM coordinated validation, SOGL Art.76, CACM Art.35, CACM Art.74) with staggered go-live dates through 2030, and (3) structural projects (grid reinforcement per the Dutch action plan, GOPACS redispatch platform, and the EU Bidding Zone Review recommending a German-Luxembourg bidding zone split). The report explicitly states TenneT expects to need a further derogation for 2027, signalling this is not a one-off event but a recurring annual regulatory cycle likely to continue at least through the end of the decade. The bidding zone reconfiguration option, while potentially the most effective structural fix for loop flows, carries significant market-design risk (reduced liquidity, price impacts) and is not expected before 2029, and is contingent on unanimous Member State agreement following the April 2025 Bidding Zone Review recommendation.

Regulation (EU) 2019/943 Articles 15, 16(8), 16(9); CACM Regulation (EU) 2015/1222 Articles 21, 35, 74; SOGL Regulation (EU) 2017/1485 Article 76

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