Revision of the Network Code on Requirements for Grid Connection of Generators

COGEN Europe welcomes the opportunity to provide feedback on the European Commissions Proposal for the Revision of Network code on requirements for grid connection of generators (NC RfG 2.0). Cogeneration solutions (also known as combined heat and power or CHP) are recognised throughout EU and national legislation as key for energy efficiency, decarbonisation, energy affordability and industrial competitiveness.

ASEALEN, the Spanish Energy Storage Association, is a non-profit association representing companies linked to the development, promotion, investment, manufacturing, integration and operation of energy storage projects.

Filed in Spanish · English published by the European Commission

The ZVEI welcomes the fact that, with this draft update to the Network Code on Requirements for Grid Connection of Generators (NC RfG (EU) 2016/631), the European Commission is defining harmonised and definitive requirements for grid-connected electric vehicles. This lays the foundation for a uniform, Europe-wide certification of vehicles.

Energy Storage NL (ESNL) welcomes the opportunity to provide feedback on the European Commissions proposed revision of the network code on requirements for grid connection of generators a.k.a. RfG. The revision comes at an important moment for the European electricity system.

Tesla supports the revision of the RfG. Europe would benefit from having a single set of grid connection rules for energy storage and for V2G. Harmonization is what makes mass-manufactured batteries and charging infrastructure affordable and scalable. It lowers cost for consumers and brings flexible, dispatchable capacity onto the grid when Europe needs it most. The Commission is pointing in the right direction.

Corsica Sole welcomes the opportunity to contribute to the public consultation on the proposed revision of the network code on requirements for grid connection of generators. Our detailed comments are set out in the document attached to this response.

Swedenergy supports the objective of RfG 2.0 to maintain system security and resilience, but the revised code must remain proportionate, predictable and based on clearly demonstrated system needs. Requirements should focus on capabilities that provide measurable benefits to system stability and should preserve long-term investment conditions for existing generation assets, including hydropower.

The draft regulation may have a significant impact on the costs, schedules and conditions for implementing new investments, as well as on the possibility of modernising and continuing the operation of existing assets.

I annexed EC HAVE YOUR SAY Network Code on Requirements for Grid Connection of Generators – Revision (RfG 2.0) Feedback from E-REDES August 2026 Page 1 of 6 CONTENTS 1 INTRODUCTION ............................................................................................................. 3 2 E-REDES FEEDBACK....................................................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Polish Energy Storage Association (PSME) commends the EC’s work on a new network code on connection requirements for generation units. In particular, we welcome the inclusion of energy storage as an essential element of the modern electricity system. This responds to the growing role of these resources in integrating RES, ensuring security of supply, and maintaining system stability and resilience.

Filed in Polish · English published by the European Commission

1 Feedback concerning requirements for grid connection of generators (RfG 2.0) Date 25th of August 2026 These comments are prepared from the German Solar Association (BSW-Solar) but the German Wind Energy Association BWE (Bundesverband WindEnergie e.V.) shares and supports the views presented in this submission. Grid Forming Since the roots for the RfG2.0’s requirements were set in 2022/2023, the world has moved on.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The French Renewable Energy Trade Association (SER) was established in 1993 to promote the interests of industrials and professionals in the sector to public authorities, parliament and all bodies in charge of energy, industry, employment, the environment and research.

The revision of the Network Code on Requirements for Grid Connection of Generators comes at an important moment for the European electricity system. The expansion of renewable generation, storage, electric mobility and distributed energy resources requires a framework that preserves system security while remaining proportionate and adaptable.

External Ref. Ares(2026)8157897 - 25/08/2026 Revision of network code on requirements for grid connection of generators Feedback from Zaptec Charger AS Zaptec Charger AS ("Zaptec") welcomes the revision of the network code on requirements for grid connection of generators and supports the inclusion of vehicle-to-grid capability within a clear European framework.

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Public consultation NC RfG (August 2026) Paragraph Whereas 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 TITLE I - General provisions Article 1 - Subject matter Article 1 Article 2 - Definitions 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 17 18 70 16 17 18 65 70 71 72 73 74 Amendment Proposal Mandate EN50549-1 and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EU DSO Entity welcomes the opportunity to contribute to the European Commission consultation on the revised Network Code on Requirements for Generators (NC RfG 2.0). We acknowledge the significant work undertaken in preparing the proposal and recognise the importance of ensuring a framework fit for a rapidly transforming electricity system.

FEBEG welcomes the launch of the public consultation process by the EC for the adoption of the revised network code on requirements for Generators (NC RfG) as new challenges emerge on the European electricity system triggering the needs on stable and clear regulatory frameworks to contribute to its stable and secure operation.

SolarPower Europes recommendations overview (please refer to the attached document): 1) Broaden the definition of existing generating modules to include projects under development that have concluded a final and binding main equipment procurement contract, rather than limiting the definition to already connected assets only (Article 45 and 55).

WEI Response to the European Commission’s Revised Network code on requirements for grid connection of generators 25/08/2026 Statkraft Internal Contents Introduction ..........................................................................................................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MAIN ISSUES 1. Grid Forming Requirements have to be differentiated between PV and ESM and should be simplified (Please find detailed proposal / reasoning in separate presentation SMAs GFM Proposals for RfG2.0 EU-Com Draft 2026-08_final.pdf) # Specific Inertia Provision should only be mandated from ESM, not other PPM (Articles 30, 31) # Additional Storage should not be mandatable by TSO/RSO (Article 31) # Transition…

vgbe energy welcomes the launch of the process for the adoption of the revised Delegated Regulation establishing a network code on requirements for generators (RfG), as new generation and storage capacity is entering the European electricity system at massive scale and needs to contribute to its stable and secure operation.

Dear, As ODE Vlaanderen we appreciate the initiative to involve the sector in the proposed changes to the requirements for generators. ODE (Organisation for Sustainable Energy) is the sector federation for renewable energy in Flanders and represents companies active in Solar Energy, Storage, Wind and CHP through its technology platforms PV-Vlaanderen, VWEA and Bio-energy-platform.

Eurelectric response on Network code on requirements for grid connection of generators – revision August 2026 Eurelectric welcomes the launch of the public consultation process by the EC for the adoption of the revised network code on requirements for Generators (NC RfG) as new challenges emerge on the European electricity system triggering the needs on stable and clear regulatory frameworks to contribute to its…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Energinet welcomes the European Commission (EC)s publication and Have your say of the draft Delegated Regulation establishing a revised Network Code on Re-quirements for Grid Connection of Generators (RfG), repealing Regulation (EU) 2016/631.

UFE, the association representing the French Electricity industry, thanks the Commission for the consultation of the draft Regulation. UFE fully supports the goals of enhancing system security, improving grid resilience, and integrating new technologies, however UFE considers that the version of the draft deeply alters the approach and balance of both the 2016 Regulation and the 2023 ACER recommendation, notably by…

EDF welcomes the launch of the comitology process for the adoption of the revised Delegated Regulation establishing network code on requirements for Generators (RfG) as new generation and storage capacity is massively entering the European electricity system and needs to contribute to its stable and secure operation. EDF though regrets this launch intervenes only now (i.e.

Network code on requirements for grid connection of generators – revision 1 Art. 6(11): Nachweis in beide Wirkleistungsrichtungen (ESM / V2G) Bezug: Art. 6(11) in Verbindung mit Art. 49, Art. 15, Art. 17, Art. 18 und Art. 22. 1. Problem Art. 6(11) verlangt, dass Speichersysteme (ESM) sowie V2G-Fahrzeuge und V2G-Ladestationen die Anforderungen sowohl beim Einspeisen als auch beim Laden erfüllen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached the VDMA Power Systems position paper on the revision of the Network Code Requirements for Generators (NC RfG 2.0). The paper Consolidates the contributions of the participating manufacturers and outlines the key industry recommendations regarding harmonisation, implementation timelines, grid-forming requirements, certification, compliance procedures and technology-neutral grid connection…

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Public Ref. Ares(2026)8153729 - 25/08/2026 RfG 2.0 Comments on EU consultation 25th August 2026 Thank you for the opportunity to comment on the RfG 2.0 Consultation which closes on the 25th August 2026. Our comments represent the views of the National Energy System Operator (NESO) who are the System Operator for Great Britain.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response of the Association for District Heating of the Czech Republic to the Network code on requirements for grid connection of generators – revision Prague, August 25, 2026 On 8 July 2026, the European Commission published the Draft delegated regulation "COMMISSION DELEGATED REGULATION (EU) …/...

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

APREN, the Portuguese Renewable Energy Association, supports the objective of adapting the Requirements for Generators Network Code to a power system with increasing shares of inverter-based generation, distributed renewable generation, hydropower, including pump-storage, energy storage and hybrid assets.

VDE FNN expressly welcomes the present draft of the Network Code Requirements for Generators (NC RfG) published by the European Commission. This new draft, which is largely based on ACERs proposal of December 2023, was subject to public consultation from 8 July to 25 August 2026.

Brussels, 25 August 2026 BDEW Bundesverband der Energie- und Wasserwirtschaft e.V. (German Association of Energy and Water Industries) BDEW Representation at the EU Avenue de Cortenbergh 52 1000 Brussels Position Paper Belgium www.bdew.de Review of the Network Code on requirements for grid connection of generators (NC RfG 2.0) with remarks on plans to repeal Annex B of Regulation (EU) 838/2010 („ITC Regulation“)…

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Feedback on the public consultation on the revision of the network code on requirements for grid connection of generators August 2026 smartEn, the European business association representing the Flexible Demand Management Industry, welcomes the European Commission’s work to modernise Europe’s electricity market framework and unlock the system value of distributed energy resources.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German Energy Storage Systems Association (BVES e. V.) welcomes the Commissions objective to update the Network Code on Requirements for Grid Connection of Generators (NC RfG 2.0) and, in particular, the explicit inclusion of electricity storage modules.

E.ON welcomes the overall objectives of the proposed NC RfG 2.0 revision and support the development of harmonized, future-proof technical requirements that strengthen system stability while enabling the continued integration of renewable generation, storage and electrified demand.

The Association of Dutch system operators Netbeheer Nederland welcomes the opportunity to provide feedback and comments regarding the new requirements for generators regulation. Please see the attachment for more details. We are open to answering any questions and providing further explanations if necessary.

Uniper welcomes the opportunity to respond to the public consultation on the European Commissions proposal for a revision of the EU Network Code on requirements for grid connection of generators (RfG 2.0). Our detailed response is provided in the attachment.

The Danish Energy Agency welcomes the opportunity to provide feedback on the draft revision of the Requirements for Generators Network Code. Overall, the Danish Energy Agency supports the need to update the RfG in light of the significant developments in the European energy system and finds it positive that relevant lessons learned from recent system disturbances such as the Iberian blackout are taken into account.

The Czech Energy Union (SECR) supports the objective of modernising European rules on the connection of generators to the electricity system, but draws attention to the need to maintain technological neutrality, legal certainty and the economic proportionality of the new requirements. We consider the issue of the transition period to be crucial.

Filed in Czech · English published by the European Commission

PSE highly appreciates the European Commissions initiative to revise the network codes on requirements for the grid connection of generators. The proposed revision is an important step towards ensuring system security and the efficient operation of the electricity network.

Vattenfall welcomes the opportunity to comment on the draft proposal: 1) Vattenfall welcomes the overall direction of RfG 2.0 and its ambition to support a more resilient electricity system through a harmonised and future-oriented connection framework. 2) Our primary concern relates to the treatment of existing assets (Art. 4 par. 3 as well as Art. 45).

Asociación Empresarial Eólica (AEE) is the voice of the wind energy sector in Spain. With more than 350 member companies, AEE represents over 90% of the sector in Spain, including project developers, wind turbine and component manufacturers, national and regional associations, sector-related organizations, consultants, financial institutions, and insurance companies, among others.

EUGINE, the European Engine Power Plant Association, welcomes the European Commission proposal for the revision of the Network Code Requirements for Generators (NC RfG), which is an important opportunity to ensure that grid connection requirements remain fit for purpose in a rapidly changing electricity system.

nucleareurope welcomes the revision of the Requirements for Generators Regulation (RfG) and supports harmonised technical requirements where they are technically and economically justified and contribute to the secure and stable operation of the European electricity system.

CSRES, the Czech Association of Regulated Electricity Companies, applies feedback on the revision of Commission Delegated Regulation establishing a network code on requirements for grid connection of generators and repealing Regulation (EU) 2016/631. See attached file.

Enedis, French DSO operating LV & MV networks with 40M customers & > 1M with generation modules, welcomes the revision of RfG to match the changed & future energy system: clearer & updated requirements & encompassing storage & EV. A secure electricity system relies on 2 equally important objectives: a)Protect people & assets through effective network protections.

Public consultation NC RfG (August 2026) Paragraph Amendment Proposal Reasoning Relation to other provisions Article 52 - Common provisions on equipment certificates 3 Problem: Conflict with Annex III article 2.1, 2.2, 2.3, Annex III article 2.1, 2.2, 2.3 The Annex III / 2 is defining scope of applicability of the family for V2G EV Proposal 1: Modify Text: "The scope of applicability of the PGU family and component…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ENTSO-E welcomes the ECs publication of the draft Delegated Regulation establishing a revised NC RfG, repealing Regulation (EU) 2016/631, which is considered necessary in view of the ongoing transformation of the European power system.

Annex Section 6.1 requires that active islanding detection be performed by the AC V2G EVSE. This requirement unnecessarily limits the architecture options. In particular, it excludes the possibility of performing active detection in the OBC, even though the OBC serves as the systems inverter and this architecture is comparable to one that has been proven on a large scale in the photovoltaic sector.

Comments on RfG 2.0 EC July 2026 – OE position Article Alternative legal text proposal Comment Article 2 ‘maximum capacity’ or ‘Pmax’ means the maximum continuous active power which a power-generating module can produce, less any demand or losses associated solely with facilitating the operation of that power-generating module as specified in the connection agreement or as provided by the equipment certificate when…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The four German Transmission System Operators welcome the opportunity to contribute to the European Commissions consultation on the new NC RfG 2.0. Please find attached our comments on the current draft. We support the introduction and consideration of the latest technological developments, such as grid-forming requirements.

Statkraft supports updating generator connection requirements to reflect an electricity system with increasing shares of renewable generation, storage and other inverter-based technologies. The revised framework must, however, reflect operational experience and preserve investment certainty for continued renewables expansion.

The Czech Ministry of Industry and Trade (MPO) welcomes the opportunity to contribute to the public consultation on the draft RfG 2.0 Regulation and supports its overall objectives of modernising grid connection requirements, strengthening system security and resilience, and enabling the integration of new technologies such as electricity storage and V2G electric vehicles.

The network codes on requirements for grid connection of generators and on demand connection are binding rules governing connection requirements to the electricity grid. They are crucial for ensuring the safety of system operation and the efficiency of the EU power grid.

Filed in Italian · English published by the European Commission

Response to the Public Consultation on the Revision of the Net work Code on Requirements for Generators (NC RfG 2.0) Axpo welcomes the opportunity to provide comments on the revision of the Network Code on Requirements for Generators (NC RfG 2.0).

The Danish Utility Regulator (DUR) welcomes the opportunity to provide comments on the proposed revised Requirements for Generators (RfG). Unfortunately 4000 characters is not enough for all our comments, so please see the attached document for our full feedback.

That APPA Renovables supports the objective of updating the Union framework for grid connection requirements so that it remains fit for a power system characterised by a rapidly increasing share of inverter-based renewable generation, electricity storage, hybrid configurations, electric mobility and new sources of flexibility.

In general, the revised regulation establishing a network code on requirements for grid connection of generators is a step in the right direction to ensure reliability and security of supply. Malta has no specific technical issues of concern.

Razom We Stand, the Ukrainian international civil society organisation advocating for a secure, resilient and sustainable energy system and a clean energy transition, welcomes the revision of the RfG as an opportunity to adapt EU grid connection rules to the rapid growth of decentralised renewables, storage and flexible generation.

E-Mobility Europe supports the European Commissions forward-looking approach to integrating V2G technologies into the European grid connection framework. This work is essential to ensuring the safe and reliable integration of V2G technologies into the electricity system and enabling bidirectional charging to realise its full potential as a source of flexibility in the internal electricity market.

EUTurbines, the European Association of Gas and Steam Turbines Manufacturers, welcomes the European Commission proposal for the revision of the Network Code Requirements for Generators (NC RfG), which is an important opportunity to ensure that grid connection requirements remain fit for purpose in a rapidly changing electricity system.

The revised Network Code for Generators (RfG 2.0) represents a genuine advance to a framework suited to a decentralised, storage-driven system; even so, Energy Storage Europe considers that its implementation for bidirectional storage assets requires further clarification before it can offer the sector the technical certainty it needs.

Elli is a brand of the Volkswagen Group. The company has been driving the topic of electromobility for many years and has set itself the goal of offering its customers not only innovative electric vehicles, but also the associated products relating to the charging experience from a single source. This decision marked the birth of the Elli brand. Since then, our credo has been: empowering electric life.

Lubin, 25 sierpnia 2026 KGHM Polska Miedź S.A. position on the proposed NC RfG Revision Introduction KGHM Polska Miedź S.A., as one of the largest European producers of copper and silver, plays a key role in the supply chains for critical and strategic raw materials.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Polish Chamber of Industrial Energetics and Energy Consumers (IEPiOE) is a business self-government organization based in Warsaw, Poland, bringing together enterprises involved in the generation, transmission, trading, and consumption of electricity and heat, as well as the largest industrial consumers in particular those from energy-intensive sectors.

Public consultation NC RfG (August 2026) Paragraph Amendment Proposal Article 15 - Active power regulation and LFSM-O When activating LFSM-O, the following response parameters shall apply: 5 Reasoning Such fast response times for active power decrease are not technically reasonable.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European Energy A/S Gyngemose Parkvej 50 2860 Søborg [phone removed] [email removed] www.europeanenergy.com The European Commission 21 August 2026 European Energy response to the public consultation on the revision of the Network Code on Requirements for Grid Connection of Generators (RfG 2.0) European Energy welcomes the European Commission's efforts to modernize the network code Requirements for Generators (NC…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

RWE welcomes the opportunity to provide feedback on the initiative to update the existing network code and prepare the EU power grid for the future by reflecting key developments such as the increasing deployment of renewable energy and battery storage. Our detailed comments and recommendations can be found in the attached document.

ChargeUp Europe welcomes the revision of the Network Code on Requirements for Grid Connection of Generators (RfG) as an important step towards enabling the integration of mobility and energy systems and unlocking the potential of electric vehicles as flexible energy assets. Please find attached our full feedback.

Svenska kraftnät, the Swedish TSO, thanks the EC for this opportunity to leave feedback on the proposal for updating RfG. Svenska kraftnät works intimately with this NC, and the update is well received and welcome. Svenska kraftnät is happy to expand on the below feedback and answer any questions.

The E.ON German DSOs, in the following E.ON, welcome the overall objectives of the proposed NC RfG 2.0 revision and supports the development of harmonised, future-proof technical requirements that strengthen system stability while enabling the continued integration of renewable generation, storage and electrified demand.

Terna, as the Italian Transmission System Operator, welcomes the opportunity to comment on the draft Commission Delegated Regulation establishing a Network Code on requirements for grid connection of generators (RfG Network Code), repealing Regulation (EU) 2016/631.

Statnett, the Norwegian TSO, welcomes the opportunity to respond to the public consultation on the draft revised Network Code on Requirements for Generators (NC RfG). As a member of ENTSO-E, we support the inputs from ENTSO-E and would like to stress the following input given in the attachement.

Public consultation NC RfG (August 2026) Siemens Energy AG Ref. Ares(2026)8117150 - 24/08/2026 Feedback form Datum: Statement on the draft: 8/24/2026 Draft delegated regulation - Ares(2026)6819642.pdf No. Name of Titel the company giving the statement Siemens 1 Energy TITLE I - General provisions Siemens 2 Energy TITLE I - General provisions Siemens 3 Energy Siemens 4 Energy TITLE I - General provisions TITLE I -…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ElaadNL welcomes the revision of the Network Code on Requirements for Generators, recognizing it as a significant advancement for integrating Vehicle-to-Grid (V2G) and other storage technologies in the European electricity system. Please find attached our detailed response.

EDP welcomes the revision of the Network Code on Requirements for Grid Connection of Generators, recognizing the need to adapt to the evolving European electricity system, which now includes more inverter-based generation, storage, and new grid-connected assets. EDP supports updating the technical framework, provided it ensures proportionality, certainty, and system security.

EUROPGEN welcomes the modernization of the EU Network Codes and the opportunity to provide stakeholder input. Please find attached our comments and proposed modifications. We look forward to seeing the final legal text, and remain available to answer any questions arising.

Slovenské elektrárne, a.s. appreciates the opportunity to provide feedback on the published draft of the revised network code on requirements for Generators (NC RfG 2.0). At a time when the EU urgently needs to accelerate investments in new generation capacities and flexibility, regulatory changes should support, rather than hinder, the development and operation of such assets.

Agora Think Tanks supports modernising the network code on requirements for generators and welcomes the opportunity to provide feedback. A detailed version of our comments, with specific drafting suggestions, is annexed to this note. In summary, we make four recommendations: 1. Grid forming obligations for Type C and D power park modules should not bypass the needs assessment.

Iberdrola welcomes the Commission's initiative to revise the Network Code on Requirements for Generators, recognising the challenge of adapting connection requirements to a system shaped by renewable generation, storage, electric vehicles and new stability needs.

ACCIONA response to the European Commission “Have Your Say” Consultation Revision of the Network Code on Requirements for Generators (NC RfG 2.0) 1. GRID-FORMING (GFM) CAPABILITIES. • A clear and harmonised definition of grid-forming capability should be established across all Member States: There is a need for a common, clear and harmonised definition of grid-forming capability and the functionalities it…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Equinor welcomes the opportunity to respond to the public consultation on the draft revised Network Code on Requirements for Generators (NC RfG). We support the objective of strengthening power system stability while preserving the flexibility required to ensure the safe operation of the entire power system including generation assets, transmission and distribution networks, and connected customers.

Lubin, 24 sierpnia 2026 KGHM Polska Miedź S.A. position on the proposed NC RfG Revision The proposed changes could impose additional new obligations on small distribution system operators (DSOs), especially in the industrial sector, requiring organizational, technical, and financial resources comparable to those available to larger, professional DSOs.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ECOS welcomes the proposed revision of the Network Code on Requirements for Generators (RfG). It will improve the large-scale integration of electric vehicles (EV) and EV chargers capable of reverse power transfer (a.k.a. vehicle-to-grid, or V2G), as well as other low-power, mass-market products such as storage.

IFIEC Europe answer to the European Commissions Have Your Say on the Network Code Requirements for Generators 2.0 Please see the attached document for the position of IFIEC Europe. IFIEC Europe represents the interests of industrial energy users in Europe for whom energy and climate policies are significant components of production costs and a key factor of competitiveness in their activities in both Europe and…

The ZVEI welcomes the fact that, with this draft update to the Network Code on Requirements for Grid Connection of Generators (NC RfG – (EU) 2016/631), the European Commission is defining harmonised and definitive requirements for grid-connected electric vehicles. This lays the foundation for a uniform, Europe-wide certification of vehicles.

Filed in German · English published by the European Commission

Green Power Denmark welcomes the launch of the public consultation process by the EC for the adoption of the revised network code on requirements for Generators (NC RfG). Green Power Denmark, however, finds that several of the changes introduced since ACERs final proposal will have a negative impact on future grid connections. Please see our concerns and suggestions in the attached document.

Public consultation NC RfG (August 2026) European Federation of Associations of Certification Bodies/ VAZ - Verband akkreditierter Zertifizierungsgesellschaften e.V. Paragraph Amendment Proposal Reasoning Whereas 4 Amend Whereas (4): According to definition 62 ESM form a subset to PGM. Also, V2G EV and EVSE form a Energy storage plays a key and expanding role in the system and has a subset to ESM.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurowind Energy – answer to public consultation on RfG 2.0 Below is feedback from Eurowind Energy on the Commission's consultation on the draft act RfG 2.0. Eurowind Energy is available for further information. 1. GRID-FORMING CAPABILITY Articles: 5(3), 29, 30(3–4), 31(4), 32(3–4) Timeline Risk: Manufacturers have 24 months to develop and certify grid-forming products.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Repsol welcomes the opportunity to provide comments on the proposed revision of the Network Code on Requirements for Generators (RfG). We support the objective of strengthening system resilience and enabling the efficient integration of new technologies.

The European Association of Motorcycle Manufacturers (ACEM) welcomes the possibility of submitting written feedback to the public Have your say consultation, due on the 25th of August 2026, regarding the revision of the DA 2016/631 Requirement for Generators. The motorcycle industry remains available to collaborate closely with the European Commission and the Stakeholders.

WindEurope welcomes the opportunity to provide feedback on the revision of the NC RfG. Please refer to the attached document for full reasoning along with our suggested amendments. A summary of the key recommendations is as below: 1.

Hager welcomes the revision of the Network Codes on Requirements for Generators as an important step for the integration of distributed energy resources into the European electricity system. Hager supports safe, interoperable and predictable V2G operation. The European framework should nevertheless remain technologically neutral, proportionate, standards-aligned and affordable for mass-market AC V2G products.

VDA-Position on the Revision of Network Codes on Requirements for Generators (RfG 2.0) The Association of the German Automotive Industry (VDA) welcomes the revision of the Network Codes on Requirements for Generators (RfG) as an important step towards supporting the integration of electrified transport and distributed energy resources into the European electricity system.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Red Eléctrica welcomes the proposed revision of the Network Code on Requirements for Generators (RfG) and fully supports the European Commissions objective of ensuring that the regulatory framework remains fit for purpose in an evolving power system. The revision is both necessary and timely given the profound transformation of the European electricity system since the RfG entered into force in 2016.

aelēc welcomes the launch of this consultation as new challenges emerge on the European electricity system triggering the needs on stable and clear regulatory frameworks to contribute to its stable and secure operation.

Dear Members of the European Commission, Enel Group, an international power company, highly appreciates the possibility to provide feedback on Network code on requirements for grid connection of generators revision. For further details on our position, please refer to the document attached to this feedback. Best Regards.

Network code on requirements for grid connection of generators – revision Have your say - Public Consultations and Feedback Published initiatives Feedback by CEI Comitato Elettrotecnico Italiano on “The Commission would like to hear your views” 7 August 2026 Introduction CEI – the Italian Electrotechnical Committee is a private, non-profit Association operating at national level, for technical standardisation in the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The purpose of this public consultation is to gather comments on the proposed Regulation establishing a new Network Code on Requirements for Generators (RfG II), which will replace the current Commission Regulation (EU) 2016/631.

The Federation of Electrotechnical Commerce commented on the European Commission’s proposal to amend the network codes as follows: We support reforms: The amendment contributes to the safety, reliability and resilience of the electricity system by also setting requirements for the smallest Type A devices to operate in the event of a failure of the electricity system.

Filed in Finnish · English published by the European Commission

CharIN welcomes the opportunity to respond to the Commissions proposal and appreciates its thorough, forward-looking approach to integrating storage and V2G technologies into the European grid connection framework.

It is considered that the draft Regulation should be supplemented by considering the following: 1.We do not agree with the governance model, according to which the Member States play an irrelevant role in the process of approving and implementing requirements. Article 7 (1) provides that the designated entity shall be the regulatory authority unless otherwise provided by the Member State.

Filed in Spanish · English published by the European Commission

Regarding this document, we believe it is necessary to distinguish between bidirectional AC and DC charging stations: For bidirectional DC charging stations, we have no objections to this document. When the vehicle feeds AC power directly back into the grid, the vehicle must comply with the specifications set out in this document.

Filed in French · English published by the European Commission

Dear Madam, Sir, CENELEC welcomes the draft Network code RfG and supports its publication and coming into force. However due to the significant delay since the ACER draft in December 2023 it might be necessary that further technical items need to be modified.

- Article 15(5)(b)(i):The requirement for 8s response is very demanding for steam turbine units. The limit should not be set explicitly in this document but it should be rather mutually agreed in the connection agreement with the system operator. Following risks cannot be avoided: 1. Plant aux. equipment would trip within such abrupt load change leading to subsequent trip of STG. It might be e.g.

KIWA PRIMARA GmbH - accredited testing and certification body (EN ISO/IEC 17065). Kiwa Primara welcomes the revision of the NC RfG, in particular the strengthened autonomous capabilities, the inclusion of storage and V2G, and the response to the lessons of the Iberian blackout of April 2025.

The Open Charge Alliance would like to thank the European Commission for its continued leadership, commitment and constructive engagement in advancing a secure, resilient and well-integrated European electricity system. This ongoing work is instrumental in accommodating the growing penetration of renewable generation, electricity storage and vehicle-to-grid (V2G) technologies within the internal electricity market.

The review of the electricity grid connection network codes is welcomed as an important step in supporting the energy transition while maintaining the security and reliability of the European electricity system.

This submission supports the draft's strengthened autonomous capabilities (fault-ride-through, LFSM, grid-forming) and their extension to Type A units and V2G, which address the loss of system inertia and the lessons of the 28 April 2025 Iberian blackout. For distribution-level stress, however, the draft legislates only one tier mandatory capability with binding operator instruction (Art.

1. Executive Summary: The Kinetic Risk of Software-Defined Grid Controls The draft delegated regulation rightly identifies that the mass-market proliferation of distributed energy resources, energy storage modules, and vehicle-to-grid (V2G) electric vehicles demands rigorous technical harmonization to protect grid stability.