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EU consultation

Revision of the EU’s energy security framework

113 submissions from 113 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission lists 151 submissions on this file. Shown here: the 113 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.

Who showed up

91 submissions from industry — companies and their trade associations — against 10 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 9.1 industry submissions for every one from civil society.

Industry 91Civil society 10Public authorities, academia, other 12

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.

What the room declares

85 of 113
in the EU Register
392
full-time lobbying staff
€37.3M+
declared costs a year
301
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 13 Oct 2025 — it ran from 15 Sept 2025.

Policy area
Energy (DG ENER)
Where it stands
In planning
Adoption expected
30 Sept 2026 · in 31 days

How it got here

  1. Call for evidence · impact assessment13 Oct 2025

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Proposal for a regulation.

113 positions · showing 25

WM

www.marcobava.it

· · filed 13 Oct 2025 · source

The EU’s energy security architecture has identified a number of shortcomings. First, it is divided by sector and, second, as emerged during the energy crisis caused by Russia’s full-scale invasion of Ukraine, there are some gaps.

Filed in Italian · English published by the European Commission

LinkedInX
EP

Euroheat & Power

· · filed 13 Oct 2025 · source

PDF

Europes existing energy security rules were designed for a fossil-fuel-based system focused on gas and electricity. Todays challenges call for a more coherent and coordinated approach to energy security across sectors and levels of governance. Heating and cooling account for nearly half of EU energy use and 35% of gas demand, making this sector central to Europes resilience.

LinkedInX
LS

Lloyd's Market Association

· · filed 13 Oct 2025 · source

The Lloyds Market Association (LMA) represents the fifty-one managing agents who are responsible for managing underwriting syndicates at Lloyds of London, and also the members agents acting for thirdparty capital.

LinkedInX
FE

Fluence Energy GmbH

· · filed 13 Oct 2025 · source

Fluence welcomes the opportunity to respond to the European Commissions call for evidence on the EUs energy security framework. Fluence is a global market leader in energy storage products, services, and optimisation software for renewables and storage, having deployed or contracted over 41 GWh of battery-based storage systems worldwide.

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DG

Directorate General for Energy and Geology

· · filed 13 Oct 2025 · source

PDF

Portugal welcomes the European Unions initiative to revise the Energy Security Framework, recognising its strategic importance for strengthening the Unions resilience, autonomy, and solidarity in the face of growing geopolitical and climate-related challenges.

Filed in Portuguese · English published by the European Commission

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CC

CEWEP (Confederation of European Waste-to-Energy Plants)

· · filed 13 Oct 2025 · source

CEWEP represents around 500 Waste-to-Energy (WtE) facilities across Europe that safely treat about 100 million tonnes of non-recyclable waste each year while recovering energy and materials. These plants generate roughly 43 TWh of electricity and 99 TWh of heat annually, enough for about 37 million citizens, and in 2019 displaced around 13.8 billion m³ of natural gas, about 9% of Russian imports that year.

LinkedInX
B

Bundesnetzagentur

· · filed 13 Oct 2025 · source

PDF

BNetzA welcomes the initiative to revise the energy security framework, particularly with a focus on an integrated view on the energy system and a cross-sectoral transformation. Ensuring the highest possible European level of energy security - with all its dimensions - is in the interest of all European citizens.

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E

Eurochambres

· · filed 13 Oct 2025 · source

PDF

Access to secure and affordable energy is vital for Europes competitiveness and economic resilience. The 2022/23 energy crisis demonstrated the severe impact of volatile and high energy prices on all European businesses, especially SMEs. The revision of the EU energy security framework is an opportunity to build a more resilient and diversified energy system while ensuring access to energy at competitive prices.

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NV

N.V. Nederlandse Gasunie

· · filed 13 Oct 2025 · source

PDF

N.V. Nederlandse Gasunie is active in the transport, storage and terminals for natural gas in the Netherlands and Northern Germany. Additional measures for the security of supply of natural gas are necessary to ensure that industry can continue to function and homes remain heated, even in extreme cold combined with extreme supply disruptions.

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HE

H2eart for Europe Alliance

· · filed 13 Oct 2025 · source

H2eart for Europe is an alliance committed to accelerating the decarbonisation of the EU energy system through the deployment of underground hydrogen storage (UHS). Introduction The EU must continue to adapt its security of supply (SoS) architecture to reflect new realities, also taking into consideration long-term perspectives.

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O

Orlen

· · filed 13 Oct 2025 · source

PDF

The EU energy security framework requires strengthening in light of the geopolitical shifts caused by Russias full-scale invasion of Ukraine. While the existing energy market framework has facilitated market signals and supported increased alternative supply and reduced demand, this has come at a high cost due to neglecting the security dimension of energy supply.

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HE

Höegh Evi

· · filed 13 Oct 2025 · source

PDF

Höegh Evi appreciates the opportunity to contribute to the European Commissions review of the EU Energy Security Framework. As a provider of maritime energy infrastructure in Europe, Höegh Evi highlights the strategic role of floating infrastructure in ensuring long-term energy security.

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CA

Climate Action Network (CAN) Europe

· · filed 13 Oct 2025 · source

PDF

To read CAN Europe's detailed feedback on the revision of the Security of Supply Framework, including references and footnotes, please see the attached pdf file. The main objective of this feedback is to highlight the need for the revised Energy Security Framework to end fossil fuel dependence and build an integrated and climate-resilient energy system based on renewables, electrification, and long-term planning…

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BR

Bioenergia ry - the Bioenergy Association of Finland

· · filed 13 Oct 2025 · source

Bioenergia ry the Bioenergy Association of Finland welcomes the Commissions initiative to revise EUs energy security framework. We believe that in addition to the identified focus areas, it is also essential to consider the energy security of: (1) the heating system as a whole, not only electricity and gas supply, and (2) the transport system.

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TH

TenneT Holding

· · filed 13 Oct 2025 · source

As one of Europes leading cross-border transmission system operators (TSO), we welcome the European Commissions initiative to strengthen the resilience of Europes energy system amid growing risks to critical infrastructure.

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F

Fortum

· · filed 13 Oct 2025 · source

PDF

In todays complex geopolitical landscape, energy security has become a cornerstone of Europes resilience. Fortums contribution highlights how clean, reliable energy underpins economic stability, public safety, and national preparedness.

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EE

ENTSO-E

· · filed 13 Oct 2025 · source

ENTSO-E echoes the preliminary findings from the Energy Security Architecture Fitness Check. Specifically, we consider the EU energy security framework to be too fragmented across sectors to efficiently counter emerging threats. Option 1 Smart streamlining is necessary to tackle the gaps in the current security framework.

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FI

Fronius International GmbH

· · filed 13 Oct 2025 · source

To maximize European energy security and sovereignty, it is both important and urgent that we continue to accelerate the expansion of Europes renewable energy supply. However, it is equally critical to establish robust framework conditions to ensure that the sovereignty over remote control of the European electricity system remains exclusively in trustworthy hands.

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T

Tesla

· · filed 13 Oct 2025 · source

Tesla is a world leader in battery energy storage systems (battery storage), electric vehicles (EVs) and their charging infrastructure. As pioneering manufacturer of energy products and provider of grid flex services, including demand response, Tesla is driving the transition to sustainable abundance.

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ES

Enagás GTS

· · filed 13 Oct 2025 · source

PDF

Enagás GTS is the body responsible for ensuring the security of supply in the Spanish gas system, which involves guaranteeing its proper planning and operation. In carrying out its functions as Technical System Operator, Enagás GTS safeguards the continuous balance between supply and demand, coordinates the operation of gas infrastructures, and prepares preventive and emergency plans.

LinkedInX
EE

EERA - European Energy Research Alliance

· · filed 13 Oct 2025 · source

The European Energy Research Alliance (EERA) constitutes the largest low-carbon energy research community in Europe and beyond, bringing together over 250 leading organisations from more than 30 countries, with the mission of catalysing European energy research to achieve a climate-neutral society by 2050.

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C

Confindustria

· · filed 13 Oct 2025 · source

PDF

In its Position Paper on the revision of the EU Energy Security Framework, Confindustria calls for energy security to become a structural pillar of EU policy one that ensures stable, sustainable, and competitive energy supplies for businesses and citizens.

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ED

Environmental Defense Fund Europe

· · filed 13 Oct 2025 · source

PDF

Environmental Defense Fund Europes Response to the Call for Evidence on the EU Energy Security Framework (revision) 13 October 2025 Environmental Defense Fund Europe (EDFE) welcomes the European Commissions initiative to revise the EU energy security framework.

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CE

COGEN Europe

· · filed 13 Oct 2025 · source

PDF

COGEN Europe welcomes the opportunity to comment on the European Commission's initiative to revise the EU energy Security Framework. New energy security challenges are emerging in EU, including: 1) increased electrification of demand reflected in both higher average power demand and significantly higher peak demand, especially seasonal peak; 2) increased uptake of weather-dependent/variable renewable electricity…

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EE

EFIEES - European Federation of Intelligent Energy Efficiency Services

· · filed 13 Oct 2025 · source

PDF

EFIEES is the voice of private energy service companies (ESCOs) and their national associations across Europe. Our members represent over 100.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of district heating & cooling networks.

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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.