Gas Balance Network Code in the EEA: what changes for operators and traders in 2026

Key data

Gas traders and transmission system operators with operations in cross-border markets of the European Economic Area face new obligations. The Council Decision (EU) 2026/2255, published on 7 October 2026, sets the EU's position to amend Annex IV (Energy) of the EEA Agreement and incorporate the Gas Balance Network Code for transmission networks.

The objective is to harmonize equilibrium rules between transmission system operators (TSO) and network users across the entire EEA space, which includes not only the 27 EU member states, but also Norway, Iceland and Liechtenstein. For energy companies with activity in these geographies, the regulation is not optional: it requires reviewing contracts, measurement systems and settlement processes.

What does this regulation establish?

The decision does not create the Network Code from scratch, but extends its application to the EEA scope through the EEA Joint Committee, the body that manages the incorporation of European regulations to non-EU countries in the agreement.

The key elements established by the Gas Balance Network Code are:

• Daily gas imbalance management mechanisms for transmission system operators (TSO).
• Balancing platforms where TSOs can acquire or transfer gas to correct real-time deviations.
• Price signals that incentivize network users to maintain equilibrium between gas injections and withdrawals.
• Notification obligations for network users regarding their balance positions.
• Imbalance settlement procedures when users do not balance at the end of the day.

Economic and operational impact

For affected companies, the impact translates into three concrete fronts:

1. Contractual adaptation. Contracts with TSOs and counterparties in cross-border markets must be reviewed to incorporate the new balance clauses, notification and imbalance settlement procedures required by the Network Code.

2. Measurement systems and technology. Balancing platforms require real-time reporting capacity. Operators without measurement and communication systems compatible with the Network Code requirements will need to update their technological infrastructure.

3. Imbalance risk management. Price signals associated with daily imbalances can generate additional costs if the company does not actively manage its balance position. A systematic deviation at the end of the day implies economic settlements that can erode margins in gas trading operations.

For companies based in Spain, the direct impact is limited unless they operate with active international interconnections (for example, with France or with infrastructure connected to the northern European corridor). Purely domestic companies are not affected by this decision.

Who does it affect?

• Gas Transmission System Operators (TSO) with operations in the EEA, including non-EU countries in the agreement (Norway, Iceland, Liechtenstein).
• Gas traders active in cross-border markets within the EEA.
• Gas operators with international interconnections that must report balance positions to EEA TSOs.
• Spanish energy companies with activity in gas markets in northern or central Europe.
• Gas traders operating on EEA balancing platforms.

Energy companies exclusively domestic (without cross-border activity in the EEA) are not directly affected by this decision.

Practical example

A Spanish gas trader operating in the wholesale market with physical deliveries in France or Germany is subject to the balance rules of the TSOs in those countries. With the incorporation of the Network Code into the EEA Agreement, the rules are extended and harmonized also towards Norway.

If that trader has supply contracts with Norwegian counterparties or uses transport infrastructure that crosses the expanded EEA, it must:

• Review its contracts with the affected TSOs to incorporate the balance and imbalance settlement clauses of the new Code.
• Ensure that its measurement and reporting systems are compatible with the requirements of the EEA balancing platforms.
• Establish an internal process for daily monitoring of its balance position to avoid imbalance settlements at the close of each gas trading day.

If it does not adapt its processes, it may incur imbalance settlement costs that directly impact the margin of its cross-border trading operations.

What should companies do now?

1. Identify if you operate in cross-border EEA markets. If you have supply, transport or gas trading contracts involving Norway, Iceland, Liechtenstein or any other EEA country, this regulation directly affects you.
2. Review contracts with EEA TSOs. Check that balance clauses, notification of positions and imbalance settlement clauses comply with the requirements of the new Network Code. Coordinate with your legal advisor the update of affected contracts.
3. Audit measurement and reporting systems. Verify that your technological infrastructure is compatible with the requirements of EEA balancing platforms. If there are gaps, plan the update before effective entry into force.
4. Establish a daily balance monitoring process. The Code's price signals penalize deviations at the end of the day. Implement an internal process for monitoring balance position to minimize the risk of unforeseen settlements.
5. Monitor the entry into force date. The regulation does not specify a specific application date. Keep track of EEA Joint Committee decisions to know when the amendment to Annex IV enters into force.

Official source

Consult full regulation at 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=CELEX:32026D2255