Enel SpA

Enel, a multinational power company and the largest EU renewable private player, has long embraced the digitalisation of electricity networks, transforming them into Smart Grids and integrating advanced digital technologies to accelerate the deployment of renewable energy.

Enel, a leading multinational energy company, supports the European Commissions Digital Omnibus Package initiative aimed at simplifying EU digital legislation while safeguarding fundamental rights and enhancing digital resilience. The response outlines Enels positions and recommendations across four key areas: I.

Enel welcomes the Commission initiative to develop an EU Circular Economy Act as a key element for a sustainable energy transition, recognizing its central role in accelerating the transition to a more sustainable, resilient, and competitive European economic model.

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on Commission Adoption of the Industrial Accelerator Act. For further details on our position, please refer to the document attached to this feedback. Best Regards.

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on the Industrial Decarbonisation Accelerator Act Consultation. For further details on our position, please refer to the document attached to this feedback. Best Regards.

INTERNAL Ref. Ares(2021)7112260 - 18/11/2021 Enel’s Positioning on the Revision on Renewable Energy Directive II General view Enel welcomes the reach of the Commission’s proposals of the “Fit-for-55” package, which is an important steppingstone for the full decarbonization of the European economy and the recent Glasgow Climate Pact.

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

INTERNAL Ref. Ares(2021)7105187 - 18/11/2021 Enel’s Positioning on the Revision on Renewable Energy Directive II General view Enel welcomes the reach of the Commission’s proposals of the “Fit-for-55” package, which is an important steppingstone for the full decarbonization of the European economy and the recent Glasgow Climate Pact.

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

Enel welcomes the Commission’s Inception Impact Assessment (IIA) initiative to revise the Renewable Energy Directive, in order to support the renewed and higher EU climate ambition and implement the transition towards a more integrated energy system.

Enel welcomes the European Commissions initiative to review the EU Taxonomy Delegated Acts and appreciates the opportunity to contribute to the public consultation. Our recommendations aim to including renewable energy sales as eligible under the EU Taxonomy activities to complete the renewable energy value chain.

Enel welcomes the EU Energy Performance of Buildings recast proposal, as part of the Fit for 55 package. Energy efficiency is one of the most cost-effective ways of addressing the EU’s strategic policy objectives of carbon neutrality by 2050, ensuring security of energy supply and enhancing competitiveness.

Enel warmly welcomes the Commission Inception Impact Assessment to review the Directive 2010/31/EU and amending Directive 2018/844/EU on Energy Performance of Buildings, as the “Energy Efficiency First” principle constitutes one of the main pillars of the EU’s fight against climate change and a successful and sustainable energy transition.

October/November 2025 ENEL’S POSITION ON THE NEXT MFF 2028-2034 Views of the Enel Group on the next MFF 2028-2034 in response to the European Commission’s 2nd phase consultations of October/November 2025. This document presents Enel’s views on the European Commission's proposal on the next MFF, answering the 2nd phase consultation. Enel has already provided an answer to the 1st phase consultation in May 2025.

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

October/November 2025 ENEL’S POSITION ON THE NEXT MFF 2028-2034 Views of the Enel Group on the next MFF 2028-2034 in response to the European Commission’s 2nd phase consultations of October/November 2025. This document presents Enel’s views on the European Commission's proposal on the next MFF, answering the 2nd phase consultation. Enel has already provided an answer to the 1st phase consultation in May 2025.

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

• Enel fully supports the EU’s efforts to increase its 2030 climate ambition • Enel welcomes the proposed Regulation on European Climate Law (ECL) enshrining the climate change challenge at the core of the European Green Deal (EGD) • Enel welcomes the framework for the irreversible and gradual reduction of emissions and the binding EU target of net climate neutrality by 2050 set by the ECL • The importance of…

• The European Union as a whole, including individual citizens, institutions, associations, economic operators and all other stakeholders, can be proud of what has been achieved in terms of climate change and environmental-related objectives.

Dear Members of DG CNECT A.2, Enel SpA, a multinational company in the energy sector, highly appreciates the EC proposal for a regulation aimed to create the conditions for an ecosystem of trust for Artificial Intelligence products and services, on the EU market. To provide feedback on the EC proposal, Enel wrote its views in the enclosed document for your kind consideration.

Dear Members of DG CNECT .A.2, Enel SpA, a multinational company in the energy sector, highly appreciates the EC proposal for a legal act laying down requirements for Artificial Intelligence. At Enel, we use Artificial Intelligence and technology to make the energy and power systems more efficient, more predictable and more sustainable, making easier for our customers to interact with us and to play a more active…

A circular approach to waste is crucial to reach an absolute decoupling of waste generation and resource depletion from EU economic growth. Overall waste generation has increased the last decade and only limited decoupling has been achieved. Member States seem not to be on track to meet their 2025 EU targets on the preparation for re-use and recycling, especially for municipal waste.

The Enel Group believes the EU ETS has demonstrated to be a key and market-oriented component of the EUs energy transition, delivering real emissions reductions for the environment and important price signals for investments. In light of recent developments as well as reviews planned within existing legislation a number of regulatory changes are being explored.

Corporate fleets are key to accelerating the shift to zero-emission mobility. Corporate vehicles are replaced more frequently than private vehicles, making them a major driver of both emissions reduction and the expansion of the second-hand market for zero-emission vehicles (ZEVs, including battery electric vehicles).

Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to ensure a competitive, circular, sustainable and safe value chain for all products placed on the Union market. Please find attached the response of the Enel Group on the sustainable products initiative.

The Enel Group fully welcomes the Proposed Carbon Border Adjustment Mechanism (CBAM) as a mean to strengthen the EU’s carbon leakage management system and therefore safeguard the competitiveness of EU’s industry.

• The European Union should continue to lead the way in the global fight against climate change, both with domestic action and leading negotiations at international level. The EU should pursue an ambitious implementation of the European Green Deal, including the goal of climate neutrality by 2050 and a package of enhanced policies and measures to accelerate the transition to a low carbon economy.

Enel welcomes the EU Energy Efficiency Directive’s “Fit for 55” recast proposal. The proposed increase of the EU target to reduce energy consumption by at least 9% by 2030 compared to the projections of the 2020 Reference Scenario baseline seems appropriate to reach the 55% GHG emissions reduction target by 2030.

Enel strongly welcomes the Commission combined Evaluation Roadmap and Inception Impact Assessment for the review of Directive 2012/27/EU and amending Directive 2018/2002 on Energy Efficiency, as the “Energy Efficiency First” principle constitutes one of the main pillars of the EU’s fight against climate change and a successful and sustainable energy transition.

Please, find below a synthesis of Enel’s view on EU ETS revision proposal. For further details, please see the attached document. Enel welcomes the EU ETS Directive’s “Fit for 55” proposal of reform as it fits with the increased EU climate ambition and will help provide stable and predictable carbon price signals.

•Enel welcomes the approach of the legislative initiative, aimed at strengthening the EU ETS, and the ambitious package of policies and measures to accelerate the just transition to a low-carbon economy. It is critical for the EC to adopt a holistic approach enhancing carbon pricing alongside complementary policies and measures.

The Enel Group, a multinational energy company, welcomes the revision of the Cybersecurity Act (EU) 2019/881 and considers the revision of the Cybersecurity Act (CSA 2.0) as a strategic step towards strengthening the European Unions cyber resilience.

I. INTRODUCTION On April 11, 2025, the European Commission initiated a public consultation to support the revision of the EU Cybersecurity Act (Regulation (EU) 2019/881). The proposed updates aim to clarify ENISAs role, improve the European Cybersecurity Certification Framework, and ensure that cybersecurity measures are better aligned with the evolving digital ecosystem and legal framework.

The Enel Group strongly welcomes the proposed review of the Energy Taxation Directive. Such review has been long due. There is an increasingly urgent need to align EU energy taxation with enhanced climate and environmental objectives and take into account current and projected energy technologies’ development.

• All EU policies, actions and strategies should be consistent and deliver upon both the climate objectives and the sustainable development goals across the full set of their environmental, economic and social dimensions.

Dear members of the EU Commission DG CNECT, The Enel Group is a multinational company and a leading operator in the power and renewables markets of Europe and worldwide. The Enel Group welcome the Act as a positive step towards a Europe fit for the digital age, and see some possibilities to improve the holistic, practical, executional side of the Data Act, below summarized and fully explained at the position paper…

Dear Members of DG CNECT G.1, Enel SpA, a multinational company in the energy sector, highly appreciates the EC proposal for a regulation aimed to create fairness in the data economy by addressing the difficulties of access to and use of data. Enel especially welcomes the willingness to establish more competitive markets for cloud computing services.

The successive policies applied in the EU to prevent pollutants emissions from the production of energy in large combustion plants have demonstrated to be significantly successful. According to the EEA data, the EU Public electricity and heat production reduced SO2 emissions by 65% over the period 2000-2010, mostly due to the IPPC directive.

February 2021 ENEL VIEWS ON THE PROPOSAL FOR A BATTERIES REGULATION Dear Members of DG ENV. Unit B3 – Waste Management & Secondary Materials, Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to build a th sustainable, competitive and innovative battery value chain in Europe publishing on the 10 of December a proposal for a new Regulation on batteries and waste batteries…

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

Dear Members of DG ENV.Unit B3 – Waste Management & Secondary Materials Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to ensure a competitive, circular, sustainable, and safe value chain for all batteries placed on the Union market.

Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to support the creation of a European data economy promoted by data sharing across sectors and Member States. The Enel Group appreciates that in the proposal data sharing remains a choice and considers that sharing privately-held data should remain voluntary.

Enel welcomes the European Commissions Simplification of administrative burdens in environmental legislation legislative package to reduce the legal burden on business, citizens and administrations through faster and more predictable environmental authorizations procedures.

Enel Group welcomes the Regulation proposal presented by the EU Commission on Fluorinated Greenhouse Gases in April 2022. As Enel Group, we are strongly committed to the objectives of the Paris Agreement and the achievement of a 2050 zero emission goal, alongside an ambitious science based certified reduction target by 2030.

Enel Group welcomes European Commission initiative for the review of Fluorinated Greenhouse Gases rules. Enel is strongly committed to the objectives of the Paris Agreement and the achievement of a 2050 zero-emission goal, alongside an ambitious science based certified reduction target by 2030.

Enel SpA, a multinational company in the energy sector and active in the e-mobility value chain, highly appreciates the EC initiative to revise the Directive 2000/53/EC on end-of-life vehicles (ELV) to prevent waste from vehicles, promote reuse, recycling and other forms of recovery of ELVs and their components so as to reduce the disposal of waste and improve the environmental performance of all economic operators…

Dear Members of the EU Commission, The Enel Group, a multinational company and a leading operator in the power and renewables markets of Europe and worldwide, welcomes the Act as a positive step towards a Europe fit for the digital age, and see some possibilities to improve the holistic, practical, executive side of the Data Act, summarised below: 1. Enhanced interplay with EU legislation.

The Enel Group, a multinational company and a leading operator in the power and renewables markets of Europe, welcome the public consultation on the possibilities to build up a holistic European Cyber Resilience Act. Please find attached the complete response to the consultation, while below you may find a brief overview of their recommendations on how to improve cyber resilience in Europe: I.

Since 1990, emissions from road transport have increased significantly and as of today account for almost a fifth of EU's GHG emissions. The next years are critical for curbing CO2 emission. If action is insufficient in the short-medium term, it will likely be impossible to make up for the deficit later, this requires a substantial decrease in CO2 emissions in the transport sector.

Enel strongly believes that the completion of the decarbonization of the power sector and the electrification of final uses, such as transport, heating and cooling and industry, along with energy efficiency, are the key levers to trigger for a clean and cost-efficient transition. These measures have the lowest CO2 abatement cost to tackle the largest part of emitting activities.

Enel strongly believes that the completion of the decarbonization of the power sector and the electrification of final uses, such as transport, heating and cooling and industry, along with energy efficiency, are the key levers to trigger for a clean and cost-efficient transition. These measures have the lowest CO2 abatement cost to tackle the largest part of emitting activities.

Enel Group welcomes the proposal of a European Grid Package to address the sector's most pressing challenges. In particular, the Commission has identified some of the key problems, namely the gap between needed grid expansions and the current grid development, slow implementation of projects, increasing congestion issues at the transmission level, and queues for connection requests.

The ‘Fit for 55’ package paves the way for the implementation of the EU Green Deal, this set of legislative revisions represents a unique opportunity for Europe to take a step forward and win the climate race. That is why now it is the time to show steadfast commitment and prioritize the most efficient, sustainable and cost-effective pathways to decarbonize the economy.

The current directive fails to mitigate the environmental impact of transport, since many of the alternative fuels currently allowed emit CO2 since some of them are pure or derivate fossil fuels. The current directive does not set the adequate framework to achieve long-term EU CO2 emissions reduction objective, as it does not adequately support the deployment of zero emission mobility.

Enel welcomes the inclusion of the EU Electrification Action Plan (EAP) as one of the key actions from this European Commission to ensure that all Europeans have access to affordable energy and the opportunity brought to all stakeholders to provide timely feedback to the action plan.

Enel strongly welcomes the European Commissions commitment to develop a comprehensive revised Heating & Cooling Strategy, recognizing it as a crucial step to deliver on EU policy goals and to ensure a secure, clean, competitive and affordable energy supply for all European citizens and businesses.

TEN-E’s priorities and eligibility criteria have been defined in 2013 and so the current regulation is no longer fully in line with the evolution of the energy system and with the new policy priorities. TEN-E networks should not only reflect the energy transmission but also the distribution and energy customer solutions landscape of tomorrow, including smart grids for distributed energy resources (i.e.

Enel welcomes the Commission proposal on a Regulation on methane emissions reduction in the energy sector as a first step to tackle the significant contribution of methane to GHG emissions, but greater efforts are needed if the EU wants to lead global methane emissions reductions.

Enel welcomes the Commission communication on an EU Methane Strategy and the further proceedings on a legislative proposal to reduce EU-related methane emissions from fossil fuels, as both acknowledge methane as a relevant contributor to GHG emissions. Methane emissions contribute with a relevant share (approx. 15%) to global GHG emissions.

Dear Members of European Commission, DG CNECT Unit H.2; Enel SpA, a multinational company in the energy sector highly appreciates the EC prompt revision of the Directive on the security of network and information systems (EU) 2016/1148. Please find the Enel Group feedback in the attachment.

Dear Members of DG CNECT H2, Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to review the Directive (EU) 2016/1148. The first suggestion to revise the future legislation relates to the provisions allowing Member States to define essential services and identify operators of essential services in their territories.

Dear Members of DG CNECT, The Enel Group, a multinational company of the energy sector, welcomes the opportunity to provide comments to the initiative of the European Commission regarding the availability of “high-value” datasets (HVDS) held by the public sector.

• We welcome the proposed EU LULUCF Revision, alongside the ambitious package of enhanced policies and measures to accelerate the energy transition to a low-carbon economy. We support the European Commission’s approach to consider a emission reduction contribution from all sectors, providing the right policy mix, ensuring cost efficiency across all sectors, but also guaranteeing a clear transition pathway in all…

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on the Guidance on designating renewables acceleration areas. Enel believes that this initiative can be an important tool to help unblock the obstacles preventing the advance of renewable sources, enabling the achievement of the objectives of the EU Green Deal and REPowerEU.

Enel welcomes the EC’s legislative initiative on empowering consumers in the green transition, as a very relevant piece of the Circular Economy Action Plan and European Green Deal agenda. Improving and promoting the environmental sustainability of products and services should be a strategic priority for both private sector and institutions.

INTERNAL Ref. Ares(2023)3543871 - 22/05/2023 Enel views on the proposal to reform the European electricity market On 14 March, the European Commission published the proposal to revise the electricity market design.

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

The Enel Group welcomes the European Commissions review of the Governance Regulation and the opportunity to contribute to the reflection on how EU governance can effectively support the delivery of the 2030 objectives and the design of the post2030 climate and energy framework.

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on the public consultation for the upcoming revision of the EU energy security framework. For further details on our position, please refer to the document attached to this feedback. Best Regards.

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.

Maritime sector is a large and growing source of greenhouse gas emissions and related emissions are projected to increase significantly if mitigation measures are not put in place swiftly. Shipping emissions could increase between 50% and 250% by 2050 under a business-as-usual scenario, undermining the objectives of the Paris Agreement [Third IMO Greenhouse Gas Study 2014].

The Enel Group welcomes the European Commissions consultation on the design of the post2030 national climate targets framework and the opportunity to contribute to the reflection on how national frameworks can effectively support the delivery of the EU 2040 climate objective.

Enel strongly welcomes the Commissions proposal for the revision of the Ambient Air Quality Directives, as air quality is the number one environmental and health problem in Europe and the quality of air Europeans breathe is still far from complying with European or international standards.

Air quality in Europe is still far from complying with European or international standards. Especially in urban areas, air quality limits in Europe are widely exceeded for the three main pollutants (particulate matter or PM, ozone and nitrogen oxides or NOx).

The Enel Group, a leading energy company with extensive experience in electricity networks, considers this consultation highly important in view of the rapidly growing impact of data centres and AI on the European power system. In this context, Enel highly appreciates the opportunity to provide feedback to this consultation; and recommends to: 1.

The Enel Group welcomes the proposal to amend the current Measuring Instrument Directive-MID to cover the evolving needs of the energy sector in line with the objectives of the European Green Deal. Our company would like to share some improvements to the current text to increase regulatory certainty.

The need of a transport infrastructure policy at EU level is paramount, it allows closing gaps, removing bottlenecks and eliminating technical barriers that exist between the transport networks of EU Member States, strengthening the social, economic and territorial cohesion of the Union and contributing to the creation of a single European transport area.

Enel welcomes the European Commission proposal on a Regulation and Directive on the internal markets for renewable and natural gases and hydrogen, as a necessary step to align the regulatory and policy framework of the gas sector to the 2030 and 2050 EU climate ambition.

A paramount issue to Electric Vehicles charging pertains to the classification of the charging transaction for VAT purposes especially, but not limited to, public recharging point. The recharging activity entails a large number of services far beyond the mere supply of electricity (e.g.

Dear Members of the European Commission, The Enel Group, a multinational company and a leading operator in the power and renewables markets of Europe, welcome the public consultation on the possibilities to build up a holistic European Cyber Resilience Act. Please find attached the complete response to the consultation. Best regards, [name removed]

Enel supports the CBAM as a necessary complement to the EU ETS to address carbon leakage, preserve a level playing field between EU and non-EU producers, and safeguard industrial competitiveness, while maintaining a strong and predictable carbon price signal.

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on EU Fusion Strategy Consultation. For further details on our position, please refer to the document attached to this feedback.

We are grateful for the opportunity to provide the European Commission with feedback on the revision of the data reporting rules under REMIT. While we welcome the Commissions engagement with stakeholders, we believe the draft requires further amendments to prevent market participants from facing an excessive reporting burden.

The Enel Group welcomes the revision of the EU ETS and its implementing provisions as a further step in increasing the effectiveness and efficiency of the EU ETS in reducing GHG emissions and fighting climate change.

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on the consultation on Public procurement of clean technologies minimum requirements on environmental sustainability. For further details on our position, please refer to the document attached to this feedback. Best Regards.

Enel Group welcomes the Commission’s initiative and the intent to intensify the pace of the measures to enhance the protection and resilience of critical infrastructure through the establishment of a more comprehensive legislative framework.

Dear Members of DG Connect (European Commission, Units D and B), Enel SpA, a multinational company in the energy sector highly appreciates the EC binding Decision establishing the 2030 Policy Program “Path to the Digital Decade”, as it legally reinforces the importance of achieving a digital transformation of the European Union by 2030.

The Directive 2014/94/EU was adopted at a time when the market of alternative fuel vehicles was still an emerging market. In 2018, a major milestone was reached as Europe accounted for its first million electric vehicles on the road and the future market outlook is promising.

Enels comments on the Call for Evidence with a view to adopt Guidelines on the application of Article 102 TFEU to exclusionary conduct The Enel Group (Enel) warmly welcomes this initiative of the European Commission (EC), not only because there are no Guidelines in place clarifying the application of Article 102 TFEU, but mainly considering that the existing EU case law will be also reflected into such Guidelines.

Enel Group welcomes the proposal of an Implementing Regulation (IR) on access to data for switching electricity suppliers to harmonize procedures and facilitate full interoperability of energy services within the EU.

Enel supports the EU Ecodesign and energy labelling policies and agrees with the need to keep the legislation up-to-date and in line with the latest technological developments, with cost-effectiveness and proportionality criteria in mind.

New and major threats are being experienced by the continental gas sector and a coordinated action at European level is needed. Enel therefore welcomes the intention of the European Commission to revise the Regulation (EU) 2017/1938, which aims to improve the resiliency of the gas sector and ensure that security of gas supply is fit to the current challenges.

As a multinational integrated operator in the electricity and gas sectors, Enel Group reaffirms the key role of sustainable, high performing and efficiently interconnected network infrastructures at European level to promote growth and competitiveness in the fields of energy, transport and digitalization.

ENEL Group appreciates the opportunity to provide feedback to the European Commission's call for evidence regarding the interim evaluation of the Fusion for Energy (F4E) Joint Undertaking. As a group closely monitoring advancements in nuclear technology, including Small and Advanced Modular Reactors (SMRs and AMRs) as well as nuclear fusion, ENEL Group firmly believes in the importance of continued research and…