SupergridEurope response to the European Commission's proposed revision of the TEN-E Regulation
SupergridEurope has published a position paper outlining our response to the European Commission's proposal to revise the TEN-E Regulation, presented on 10 December 2025 as part of the EU Grids Package.
The paper sets out our position on two key questions: how Europe should govern and plan its cross-border energy infrastructure, and how it should finance it. On both, we argue that the status quo is inadequate and that the Commission's proposals, if strengthened and properly supported, represent a genuine opportunity for reform.
"The current bottom-up approach will delay the Energy Union, continue to restrict the free flow of electricity across Europe's borders while maintaining our economic and security exposure to global fossil fuel supply disruption," said Christian Kjaer, Executive Director of SupergridEurope.
On planning, SupergridEurope strongly supports the Commission's proposed common scenario. Today's bottom-up, TSO-led approach produces fragmented national plans that systematically underbuild grid capacity.
As the paper notes, "the TYNDP scenario planning in its current form functions largely as a wish list established as a compromise solution agreed by national TSOs."
A common scenario would not replace national planning, but would provide the coordinated, pan-European reference point that today's system lacks. SupergridEurope also recommends adding a mid-term 2035 milestone alongside the existing 2050 horizon.
On offshore and technology, SupergridEurope calls for offshore and onshore grid planning to be fully integrated and based on the common scenario. Offshore Network Development Plans are currently developed in isolation, limiting system-wide optimisation.
SupergridEurope also highlights the need to update regulatory definitions to ensure advanced grid technologies, including superconducting cables and innovative conductors, are not inadvertently excluded by the regulation's existing voltage-based thresholds.
On financing, the EU is already saving consumers €34 billion every year through interconnection, with the potential to reach €40–43 billion per year by 2030. Delivering that requires investment at scale, and no single instrument will be sufficient.
Our position paper sets out a blended approach combining expanded EU loans and guarantees, private capital mobilisation through cap-and-floor regimes, green bonds, ring-fenced CEF-Energy funding, and better use of congestion revenues. Transmission system operators alone lack the balance sheet required, underscoring the need to attract long-term institutional investors such as pension funds.
On cost allocation, SupergridEurope supports the Commission's proposed reforms, including the principle that all Member States benefiting significantly from a project should contribute to its costs.
Read SupergridEurope's full response to the TEN-E consultation here.
Read the European Commission's TEN-E revision proposal here.
For further information, please contact: Aoife Cronin, Communications Officer – aoifecronin@supergrideurope.eu | +353 85 283 7150