New Gas Network Code in the EEA: what transport operators must change in 2026

Key data

Gas transport network operators operating in Europe have a new regulatory framework to comply with. The Council Decision (EU) 2026/2223, published on 2 October 2026, sets the EU's position for incorporating the Network Code on capacity allocation mechanisms in gas transport networks into the European Economic Area (EEA) Agreement. The direct consequence: the rules for accessing and using gas transport capacity are unified across Europe, including Norway, Iceland and Liechtenstein.

This is not a procedural regulation. It affects how capacity rights in transport pipelines are contracted, auctioned and allocated. Any company that operates or uses gas transport infrastructure within the EEA must review its internal processes.

What does this regulation establish?

The Decision amends Annex IV (Energy) of the EEA Agreement to incorporate the Network Code Regulation on capacity allocation mechanisms in gas transport networks. In practical terms, this means three things:

• Harmonization of access rules: The conditions for accessing gas transport capacity become common across all EEA countries, eliminating national differences that hindered cross-border operations.
• Standardized auction procedures: Network operators must apply capacity auction and allocation mechanisms that are homologated at European level, rather than procedures specific to each country or company.
• Extension to the entire EEA: The rules already in force in the EU are formally extended to Norway, Iceland and Liechtenstein, creating a unified regulatory space for gas transport.

Economic and operational impact

The impact is not only regulatory: it has direct consequences for the operations and costs of gas sector companies.

• Contract review: Contracts for access and use of transport capacity will need to be reviewed to verify compliance with the new standardized procedures. Those that do not comply with the Network Code will require renegotiation or adaptation.
• Adaptation of technological platforms: Capacity reservation platforms must be updated to support harmonized auction mechanisms. This may involve investment in IT systems and team training.
• Internal operational procedures: The operations, legal and commercial departments of network operators will need to update their internal procedures to align with the new common requirements.
• Market opportunity: Harmonization facilitates cross-border access to transport capacity, which can open new business opportunities for companies operating in several EEA countries.
• Supply security: Market integration strengthens supply security across the entire EEA, reducing risks of capacity cuts or restrictions in situations of energy stress.

Who does it affect?

• Gas transport network operators (TSO) in any EU Member State or in Norway, Iceland and Liechtenstein.
• Gas trading and distribution companies that contract transport capacity in cross-border networks.
• Industrial companies with gas transport contracts that access the transport network directly.
• Legal and compliance departments of energy groups with presence in the EEA.
• CFOs and operations directors of gas companies that must budget for the adaptation of contracts and systems.
• Advisors and consultants in the energy sector who support operators in adapting to the new regulation.

Practical example

A gas transport network operator with pipelines connecting Spain with France and Portugal currently has capacity contracts signed under the current national procedures. With the entry into force of the new harmonized Network Code in the EEA, this operator must:

1. Review all its cross-border capacity contracts to identify clauses that do not comply with the standardized auction procedures required by the Network Code.
2. Update its capacity reservation platform so that auction mechanisms comply with the new common European standards.
3. Adapt its internal operational procedures for capacity allocation, training the teams responsible for contract management and network operations.

If this same operator has agreements with counterparties in Norway (an EEA country but not an EU member), Decision 2026/2223 ensures that the rules applied in that commercial relationship are now the same as in the rest of the European market, simplifying cross-border operations and reducing legal uncertainty.

What should companies do now?

1. Identify if you are a network operator or user of gas transport capacity in the EEA. If your company operates transport pipelines or contracts capacity in them, this regulation affects you directly.
2. Review current capacity contracts. Analyze whether current contracts for access and use of transport capacity comply with the standardized procedures of the new Network Code. Prioritize cross-border contracts and those involving counterparties in Norway, Iceland or Liechtenstein.
3. Audit capacity reservation platforms. Verify that technological systems for capacity reservation and auction comply with the new harmonized standards. If not, plan the update.
4. Update internal operational procedures. The operations, legal and commercial teams must know and apply the new capacity allocation mechanisms. Plan the necessary training.
5. Monitor the entry into force date. The Decision does not specify a specific application date. Assign a responsible person to monitor the publication of the effective date in the EEA Official Journal to avoid non-compliance due to lack of monitoring.
6. Consult with advisors specialized in energy regulation. Given the technical and legal complexity of the Network Code, it is advisable to have expert support for contract review and operational adaptation.

Official source

Consult full 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_202602223