The post-2030 revision of the Energy Efficiency and Renewable Energy Directives is a generational opportunity. The rules are already there. The Electricity Market Design (EMD), the Energy Efficiency Directive (EED), and the Renewable Energy Directive (RED) all promote flexible demand. What’s missing is implementation.
In this letter, smartEn calls on the Commission to:
- Energy Efficiency First, operationalised. Before approving costly grid expansion, regulators should demonstrate that demand-side flexibility was properly assessed as the default alternative.
- Indicators that make progress visible. KPIs on activated flexible demand by grid zone and by sector, and on how efficiently existing networks are used.
- Energy audits that see flexibility. Embed flexibility assessments into mandatory audits for large enterprises, building on EN 16247-1.
- Public funding that rewards activation, not just deployment. Support solutions that are both efficient and ready to flex.
- Curtailment turned into consumption. A dedicated RED indicator measuring the renewable energy saved from curtailment through flexible demand.
The technologies exist. What is missing is systemic precision: measurable indicators, enforceable planning obligations, and funding that rewards activation alongside deployment.
