SNE-GV Consultation: System Suitability of Battery Storage Systems in Austria

On 27 February 2026, E-Control published its two-step market consultation on the System Usage Charge Principles’ Regulation (Systemnutzungsentgelte-Grundsatzverordnung or SNE-GV). Participation in the consultation is possible until 20 March 2026. The new charges are scheduled to enter into force on 1 January 2027.

E-Control must set forth principles for the determination of system usage charges in an ordinance. On this basis it shall determine the amount of such network usage charges regularly, namely annually, report their development and produce 10-year forecasts.

E-Control is currently conducting the mandatory consultation process on this principles’ regulation. Part 1 of the two-part consultation document contains general aspects relating to two of the five system usage charges, namely the network usage fee and the grid connection fee. Part 2 specifies the criteria for the ‘system-friendly operation’ of storage, generation and consumption facilities.

The system usage charges must also include incentives for other users to behave in a system-friendly way. E-Control distinguishes between storage facilities that are beneficial to the system, generation plants that are beneficial to the system, storage facilities contracted by the grid operator that are beneficial to that grid, plants of all kinds with permanently flexible grid access, users with time-variable fees or with interruptible and controllable output, and reduced fees for consumption when providing flexibility services.

We provide you with a summary of the key points of the consultation draft.

"System-Beneficial Storage" – The Key Category for BESS Projects

The category of “system-beneficial storage” is particularly relevant for battery storage project developers because storage facilities can be completely exempted from grid usage and grid loss charges when being charged from the grid – and for a fixed period of 20 years from commissioning. System friendliness depends on the specific type of operation of the storage facility, and the principles’ regulation must define the criteria for this. 

The E-Control proposal raises the question of the award and ranking criteria for competitive tenders as suggested in the consultation and thus also whether it makes sense that all criteria have to be met cumulatively in all scenarios. This is particularly relevant in light of the fact that grid operators can impose additional requirements on system utility in the course of tenders.

• The storage facility must first have a bottleneck capacity of at least 1 MW and be connected to a grid connection point that has been designated in the transmission system operator's grid development plan or in the distribution grid development plan as a suitable location for system-beneficial operation. The location alone is not yet sufficient for an exemption.
• In addition, a valid contract must be concluded with the control zone manager APG for the provision of flexibility services as part of congestion management.
• The storage operator must participate in public tenders.
• The grid operator, in turn, must have the right to impose requirements on the storage operator regarding the permissible operating range (grid-connected power in terms of consumption and feed-in) and for reactive power. Requirements regarding the operating range are to be specified in the tender and defined in 15-minute slots on a day-ahead basis. The connection network operator's specifications regarding reactive power behaviour must be complied with without compensation for disadvantages. The grid operator may also define additional requirements as part of the tender.

Co-Located Storage and Hybrid Facilities

Good news for hybrid projects: Energy storage systems can also be classified as “system-beneficial” if they form part of the same customer installation as power generation plants (“co-located storage”). The prerequisite is that the storage system's grid consumption is metered and can be distinguished from any own consumption of power generation plants. E-Control is required to publish standard metering concepts for hybrid power generation plants and customer installations with storage systems in the first half of 2026.

However, if an energy storage facility is co-located with consumption equipment, it cannot be classified as “system beneficial.”

Implications in Practice

What does this mean in practice? From a practical perspective, the draft regulation must be viewed in a nuanced manner: on the one hand, it creates for the first time a concrete regulatory framework which, enables long-term planning if the requirements are met. On the other hand, the requirements are stricter than those stipulated by the ElWG. Details, particularly regarding tenders, are still unclear, e.g. how long the contracts awarded will run. The 20-year exemption from the ElWG for storage facilities could therefore quickly shrink. It will be difficult to coordinate the long lead time between grid connection and participation in the tender during project development. The E-Control draft also leaves open whether all criteria must be met cumulatively, e.g. whether the provision of control energy services also requires compliance with the specifications of the connection network operator. Suggestions can be made on this in the review process. 

Upside

• Legal and planning certainty: The 20-year term of the grid fee exemption from commissioning offers a high degree of legal and planning certainty if the requirements for system-beneficial operation are met - a key factor for project financing and the valuation of BESS projects.
• Co-located storage and hybrid plants can be operated in a system-beneficial manner: Co-located storage facilities can be classified as system-beneficial together with power generation plants, enabling flexible project structures.
• Remuneration for flexibility services: Flexibility services provided as part of congestion management are remunerated in exchange for compensation for economic disadvantages and costs.

Downside and Risks

• Location dependency: The designation of sites in the grid development plans creates a significant dependency on the specific regulatory classification. For transactions, this means that target companies with BESS projects require careful due diligence regarding site designation and its permanence.
• Operating range requirements and reactive power requirements: The obligation to comply with operating range requirements set by the grid operator, and the grid operator's ability to restrict the operating range, represent operational risks. The actual impact on revenues remains market-dependent and may affect the financial viability of projects. In addition, the storage facility must comply with the connection grid operator's requirements regarding reactive power behaviour, without any entitlement to compensation.
• Public tender competition: The competitive tendering process for grid connection capacities creates uncertainty, not only regarding the award of contracts, but also with regard to the specific tendering criteria of the grid operator, as well as an economic burden for projects in addition to the costs of system-friendly operation. There is a risk that competition in the tendering process will drive up costs (which are therefore not solely subject to the causing pays principle).
• No connection to consumption systems: The explicit exclusion of storage systems in customer installations with consumption systems is likely to restrict certain business models. This provision is a bit of a surprise because facilities consuming electricity can perfectly well be operated in a system-friendly manner. For industrial prosumer concepts, this means that a strict separation between storage and consumption infrastructure is required. The impact on the operation of swarm storage systems will need to be discussed in detail.

E-Control will thoroughly review the feedback received during the consultation process. It is therefore in the interest of all market participants - project developers, investors, grid operators, and financiers alike - to actively use this opportunity to help shape a framework that meets the requirements of the Austrian market and opens practical implementation options.

If you have any questions about your specific projects or about participating in the consultation process, please do not hesitate to contact: