Key data
| Regulation | Council Decision (EU) 2026/2237, of 24 September 2026 |
|---|---|
| Publication | 5 October 2026 |
| Entry into force | Not specified in the regulation |
| Affected parties | Energy network operators, traders and companies with cross-border activity in the EEA |
| Category | Energy |
| Geographic scope | European Economic Area (EU + Norway, Iceland and Liechtenstein) |
| Technical instrument | Network code on interoperability and data exchange (Annex IV of the EEA Agreement) |
If your company operates electrical or gas networks, trades energy or manages cross-border flows within the European Economic Area, this decision affects you directly. Council Decision (EU) 2026/2237, adopted on 24 September 2026 and published on 5 October, sets the official position of the EU to amend Annex IV (Energy) of the EEA Agreement and incorporate the Network Code on interoperability and data exchange.
In practical terms: the technical standards for communication between energy systems that were already mandatory in the 27 EU member states now become enforceable in Norway, Iceland and Liechtenstein as well. The European energy market takes another step towards real integration on a continental scale.
What does this regulation establish?
The decision operates on two simultaneous levels:
- Political level: It establishes the position that the EU will adopt before the EEA Joint Committee, the parity body that manages the implementation of the EEA Agreement. In other words, the EU votes in favour of incorporating the Network Code into the EEA legal framework.
- Technical level: It amends Annex IV (Energy) of the EEA Agreement to include the Network Code on interoperability standards and data exchange, which defines the common communication standards between energy system operators.
The affected Network Code specifically regulates:
- Communication standards between electricity and gas network operators
- Data exchange protocols between energy systems in different countries
- Technical compatibility requirements for coordinated network management on a continental scale
- Information formats and procedures between traders and operators in cross-border operations
Before this decision, non-EU EEA countries (Norway, Iceland and Liechtenstein) were not required to apply this specific Network Code. With incorporation into Annex IV, they are now subject to the same technical requirements as operators in the 27 EU member states.
Economic and operational impact
The regulation does not set specific sanctions or financial amounts in its text, but the operational implications for affected companies are significant:
| Area of impact | Concrete description |
|---|---|
| IT systems | Adaptation of IT platforms to the communication standards of the Network Code |
| Data protocols | Review and update of information exchange formats with counterparties in the EEA |
| Cross-border operations | Data flows between operators in different EEA countries must comply with harmonised requirements |
| Network management | Coordination of electrical and gas networks on a continental scale requires full technical compatibility |
| Relations with Norwegian, Icelandic and Liechtenstein counterparties | These partners are now subject to the same standards, which facilitates integration but requires verification of mutual compliance |
The cost of adaptation will depend on the degree of technological maturity of each company and the volume of cross-border operations. Companies that already operate under the Network Code in the EU will have an advantage: their systems already comply with the required standards. The effort will mainly fall on verifying whether non-EU EEA counterparties also comply.
Who does it affect?
- Electricity transmission system operators (TSOs) with interconnections or data exchanges with Norway, Iceland or Liechtenstein
- Distribution system operators (DSOs) with activity in border areas of the EEA
- Gas network operators with cross-border flows within the EEA
- Energy traders operating in markets in several EEA countries
- Industrial companies with cross-border energy supply contracts that exchange data with network operators
- Technology and IT system providers that develop solutions for the energy sector in the EEA
- Advisors and consultants in the energy sector that manage regulatory compliance for operators in the EEA
Practical example
Imagine a Spanish electricity trader that buys energy in the Norwegian market (NordPool) and manages supply contracts with industrial customers in several EEA countries. Until now, data exchange with the Norwegian network operator could be carried out with proprietary protocols or with standards not harmonised with those of the European internal market.
With the incorporation of the Network Code into Annex IV of the EEA Agreement, the Norwegian network operator is required to apply the same communication and data exchange standards as Spanish, German or French operators. This means that the Spanish trader can require its Norwegian counterparty to ensure that data messages, supplier change notifications and measurement reports follow the harmonised formats of the Network Code. The benefit is real: fewer operational frictions, fewer system integration errors and greater speed in managing cross-border contracts.
The immediate work for this company is to verify that its IT systems already comply with the Network Code standards in its operations with non-EU EEA countries and to update service contracts with its counterparties to include the requirement to comply with the Code.
What should companies do now?
- Identify if you have cross-border operations in non-EU EEA: Review whether your company exchanges data or energy with counterparties in Norway, Iceland or Liechtenstein. If so, this regulation affects you directly.
- Audit current compliance of your IT systems: Verify that your data exchange platforms already comply with the standards of the Network Code on interoperability. If you operate exclusively in the EU, you probably already comply; if you have operations with non-EU EEA countries, review the status of your counterparties.
- Contact your counterparties in Norway, Iceland and Liechtenstein: Request confirmation that their systems are being adapted to the Network Code. Interoperability is bidirectional: if your counterparty does not comply, data exchange will not work correctly.
- Update contracts and data exchange agreements: Include Network Code compliance clauses in contracts with operators and traders in non-EU EEA.
- Monitor the entry into force date: The regulation does not specify a concrete date of application. Designate a person responsible for regulatory monitoring to detect when the EEA Joint Committee formalises the modification of Annex IV and what transition periods are established.
- Consult with your legal advisor specialising in European energy law: Given that the entry into force is not determined, it is essential to have an alert system to act when the EEA Joint Committee act is published.
Frequently asked questions
What is the Network Code on interoperability and data exchange?
It is the set of technical rules that establishes common communication and data format standards between energy network operators (electricity and gas) in Europe. It defines how data should be exchanged between systems in different countries to ensure compatibility and coordinated network management on a continental scale. Until now it was mandatory in the 27 EU member states; with this decision it is extended to Norway, Iceland and Liechtenstein.
When does this regulation enter into force for companies?
The Council Decision was adopted on 24 September 2026 and published on 5 October 2026, but the regulation does not specify a concrete entry into force date or adaptation period. The modification of Annex IV of the EEA Agreement must be formalised by the EEA Joint Committee, which is the body that manages the implementation of the Agreement. It is essential to monitor the publications of the Joint Committee to know the exact timeline.
Does this regulation affect companies that only operate within Spain or the EU?
Not directly. If your company operates exclusively in Spain or other EU member states, you are already subject to the Network Code and there are no changes to your current obligations. This decision mainly affects companies with cross-border operations that include Norway, Iceland or Liechtenstein, and those that exchange data with operators in those countries.
What IT systems need to be adapted?
According to the regulation, companies must adapt their IT systems and information exchange protocols to the harmonised requirements of the Network Code. This includes measurement data management platforms, supplier change notification systems, communication tools with network operators and any data exchange interface with non-EU EEA counterparties.
What happens if a company does not adapt its systems to the Network Code?
The regulation does not specify concrete sanctions in its text. However, failure to comply with interoperability standards can generate serious operational problems: inability to exchange data with network operators, blockages in cross-border contract management and potential contractual breaches with counterparties. The specific regulatory consequences will depend on the national legislation of each EEA country and on the implementing acts that are published.
Official source
Consult the complete regulation in official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602237
