ACER calls for stronger coordination and consistency across EU electricity, gas and hydrogen planning

Today, ACER publishes its Opinion on the Integrated Model report for EU electricity, gas and hydrogen infrastructure planning, submitted in October 2025 by the European Network of Transmission System Operators for Electricity (ENTSO-E) and for Gas (ENTSOG) and prepared with support from the European Network of Network Operators for Hydrogen (ENNOH).

The Trans-European Energy Infrastructure (TEN-E) Regulation requires ENTSO-E and ENTSOG to jointly develop a consistent and progressively integrated model to support coordinated infrastructure planning across the three sectors (electricity, gas and hydrogen), and underpin future EU-level Ten-Year Network Development Plans (TYNDPs).

Why is an integrated modelling framework needed for EU energy infrastructure planning?

Europe’s energy transition is increasingly blurring the boundaries between electricity, gas and hydrogen systems. Decisions in one sector directly affect infrastructure needs and costs in the others. To address this, EU law requires a shift from isolated, single-sector planning towards more coherent sectoral integration of the modelling governance, processes, tools and data used in electricity, gas and hydrogen network planning.

Such an integrated modelling framework aims to ensure that EU infrastructure plans are based on consistent assumptions, aligned methodologies and comparable cross-sector assessments. It should future-proof planning and inform project-level investment decisions from a system-wide perspective.

What does ACER say about the proposed integrated modelling framework for energy infrastructure planning?

ACER’s Opinion assesses whether the ENTSOs’ submission provides a sufficiently robust basis for more coherent, cross-sector infrastructure planning at EU level.

The report is a useful starting point, with some progress beyond joint scenario development, including the creation of a dedicated cross-sector working group with balanced representation across the three sectors.

However, ACER finds the report does not clarify how the integrated modelling framework will contribute to greater consistency and integration of EU infrastructure planning through concrete milestones. The report falls short in the following areas:

• Cross-sector integration requirements are unclear, leaving implementation discretionary.
• Key integration steps are deferred to a long-term roadmap with vague timelines and under-ambitious actions.
• Stakeholder consultation was limited, with key elements excluded (draft report and roadmap).

As a result, it remains unclear whether the proposed framework will deliver practical improvements in infrastructure needs assessments, investment decision-making or system-wide cost optimisation.

What does ACER recommend?

For better EU infrastructure planning, ACER calls on ENTSO-E and ENTSOG, together with ENNOH, to be more ambitious in their approach to integrated modelling:

• Clearly define assumptions, data and methodologies to be applied consistently across sectors.
• Identify which planning steps require joint cross-sector assessment and which can remain sector-specific.
• Apply shared reference networks and indicators in project-level cost-benefit analyses (CBAs).
• Strengthen consistency in identifying infrastructure gaps.
• Ensure cross-sector needs assessments and harmonised CBA pilots are conducted within the TYNDP 2028 cycle.
• Update the roadmap with more ambitious actions and firmer timelines.
• Conduct a more thorough public consultation on the revised model and roadmap.

ACER expects that consistency in input, assumptions and methodology is already applied in TYNDP 2028, even if some deliverables remain sector-specific.

What are the next steps?

ACER expects ENTSO-E and ENTSOG to implement these recommendations before submitting the report to the European Commission for approval. ACER calls for early and meaningful stakeholder engagement as the integrated modelling framework evolves.