Austria 

Previously, collective self-consumption was introduced in 2017 within the Small Green Electricity Amendment (2017). The act supports private and commercial CSC (in e.g., multi-apartment buildings), including electricity sharing, which previously was hardly possible. 

Energy communities (ECs) in Austria are very organized. Both Renewable Energy Community (REC) and Citizen Energy Community (CEC) are well defined and developed. In July 2021, Austria established a comprehensive national framework for ECs with the passing of the “Renewable Energy Act” (No. 150/2021) or “Erneuerbaren-Ausbau-Gesetz” or EAG that created a framework for REC and CEC.  The Austrian Ministry of Climate Protection also set up a federal Coordination Office for Energy Communities (COEC) or Österreichische Koordinationsstelle Für Energiegemeinschaften which works in implementation of the provisions and support of EC development, including mapping existing ECs in the country. Together with the public advisory institutions in the federal states, it will ensure that energy communities in Austria can be set up and operated easily and become an indispensable part of the energy market in Austria. RECs and CECs are required to register with their network operators, who must then pass on the information to E-Control (the government regulator for electricity and natural gas markets in Austria). Most ECs in Austria are run within a family or a small group of people. 

Key takeaways

• Austria is one of the most advanced EU countries in developing ECs with a comprehensive legal framework that covers the rights, obligations, and activities of ECs. 
• Austria has three kinds of energy sharing: Renewable Energy Community, Citizen Energy Community and Community Generation Plant.  
• REC is designated as strong EC; CEC as broad by proximity, size, and energy scope; Community Generation Plant as broad by legal form; and Energy Cooperatives is broad by structure of ownership and by benefit focus. 
• Official data of RECs and CECs is collected by Österreichische Koordinationsstelle Für Energiegemeinschaft, however, there is no exact number for Community Generation Plants. 

Belgium

The implementation status of EU Directives related to Energy Communities varies between the three regions in Belgium: Brussels Capital Region, Flanders, and Wallonia, since they have different legal transpositions. Brussels is a small city, unlike the Flanders, they don’t have a lot of energy communities. Even though The Brussels Capital Region has transposed the EU definitions of Communauté d’énergie renouvelable (REC) and Communauté d’énergie citoyenne (CEC), the active energy communities are still registered as Local Energy Communities (LECs) to adapt to the regional context of Brussels which is about the possibility of utilising already-existing installations or calling upon the involvement of a third party with ownership in an environment where numerous rooftops are shared. In Brussels there are three kinds of energy sharing, they are La communauté d’énergie locale (Local energy community), Le partage d’énergie dans un même bâtiment (Energy sharing in a same building), and Le partage d’énergie de pair à pair (Peer-to-peer energy sharing). Energy sharing entities and LECs are obligated to register themselves to The Brussels DSO Sibelga. 

The Flemish Government also has transposed EU Directives related to Energy Communities. The region has two local definitions: Hernieuwbare-energiegemeenschap (REC) and Energiegemeenschap van burgers (CEC). The Energy Regulator or VREG is the actor responsible in facilitating ECs in Flanders.  However, there are several energy cooperatives established in the region pre-dating the Clean Energy Package in the country, which most of them are already registered as ECs.  

The Wallonian government adopted a framework for collective self-consumers in 2018 and followed by adoption of a decree defining Renewable Energy Communities in 2019. However, there is no registered EC in the region yet.  

Key takeaways

• Belgium is quite advanced in developing ECs, but the three main regions have different maturity levels: Brussels and Flanders have transposed the EU directives and have operating ECs while Wallonia has transposed them with no operating EC. 
• Brussels has six different local definitions (three kinds of energy sharing) and Flanders have two local definitions of ECs. 
• La communauté d’énergie locale (Local energy community), Communauté d’énergie renouvelable (REC) in Brussels and Hernieuwbare-energiegemeenschap (HEG) in Flanders are strong EC. 
• Communauté d’énergie citoyenne (CEC) and Energiegemeenschap van burgers (EGB) are considered broad by membership, energy sector, and proximity, while Le partage d’énergie dans un même bâtiment (Energy sharing in a same building) and Le partage d’énergie de pair à pair (Peer-to-peer energy sharing) are broad by legal form and membership. 
• EC database in Brussels has not yet been centralised. Sibelga is the entity that’s responsible for Brussels and VREG for Flanders. 
• Due to its history, active energy communities in Brussels are registered as LECs, not REC or CEC. While Flanders already differentiated its EC registry to RECs and CECs. 

Bulgaria

Bulgaria has not transposed the EU directives which means it is legally impossible to set up an EC. There is one project named IZGREI BG which is considered as an EC, but they only produce energy but not share it with other households since it is not possible due to the current legal framework. As it is still early development phase, it aims to build 4kW solar PV installation for self-consumption of the community and any excess will be sold to the grid. In addition, they are involved in renovation of a building, and they will share this model with others once completed. The second EC in the country was just launched in October with the cooperation of Municipality of Gabrovo. It is still under development, but it is expected to develop its renewable energy plant with an investment of BGN 180,000. Individuals, local authorities, including municipalities, non-governmental organizations and small and medium-sized enterprises are eligible to participate in the project. 

Key takeaways

• Bulgaria is still in the very early stage of EC development. It just amended its Law on Energy from Renewable Sources in December 2023. 
• The new law defines renewable energy communities (RECs) and ‘civil energy communities’ (CECs), but currently there is no practical example or details of both definitions. 
• Izgrei Energy community is an energy community that is broad by openness to ownership, voluntary membership, main activity; while the new EC that is established by Municipality of Gabrovo is Broad by ownership.

Croatia

Croatia has transposed the EU Directives, but the definitions of REC & CEC are copy paste from the EU definitions. The current national law doesn’t explain in detail any of the elements of the enabling and supporting frameworks. However, Croatia has 8 active energy cooperatives which are recorded by Nacionalni Portal Energetske Učinkovitosti. Energy cooperatives are defined as associations of individuals, companies, public institutions, local self-governments linked by location key that jointly develop projects of renewable energy sources. Although they are very similar to ECs, the regulatory framework does not recognize cooperatives as legal entities that can establish a citizen energy community, which is contrary to the European Union’s (EU) Directive 2019/944 on common rules for the internal electricity market.  The Croatian Ministry of Economy and Sustainable Development stated that energy cooperative does not meet the requirements for setting up an energy community, mainly because their members are individuals, and they cannot include local communities and other actors. This issue is still an ongoing debate in the country. 

Key takeaways

• There is currently no registered EC in Croatia as the country is still developing the official enabling frameworks for it. 
• The new law transposed EU’s definitions of REC and CEC but they are just copy paste without practical details. 
• Energy cooperative is a similar entity that exists in Croatia and it is designed broad by the dimensions of structure of ownership and distribution of benefit. 
• There are 8 registered energy cooperatives in Croatia which are recorded by from Nacionalni Portal Energetske Učinkovitosti or Croatian National Energy Efficiency Portal but there might me a few more that are not yet registered. 
• However, the Croatian regulatory framework does not recognize cooperatives as legal entities that can establish a citizen energy community due to their membership criteria. 

Cyprus

Cyprus does not have EC established. The country has transposed the EU legislation in 2021 and legitimised the concept of REC and CEC in the electricity law of Cyprus where the definitions are direct copies. It is still developing the framework for how the EC will work in practice and the authorities are planning to get the framework ready by April 2024. The laws also include details about the responsibilities of the Cyprus Energy Regulatory Authority (CERA) to issue a regulatory decision about the rights and obligations for RECs and CECs and will have the responsibility for the implementation of RECs and CECs at national level in the future. Besides that, they will issue the enabling framework for ECs, however, it is not specified if CERA is the responsible authority to check whether RECs/CECs comply with the national legislation. 

Key takeaways

• Cyprus has transposed the EU directives for REC and CEC but the definitions are just copy paste. 
• Currently there is no EC or any entity similar that is established in Cyprus. 

Czechia

Czechia is one of the few EU countries that has no legal framework that mentions upon ECs issue. The country is still developing the draft legislation. Nevertheless, Czechia has energy cooperatives that have been running for years. These cooperatives are called ENERKOM which are promoting building renovation and renewable energy. According to Veřejný rejstřík or Czechia Federal registry, there are around 19 active ENERKOM in the country. Following our interviewee, ENERKOMs can be considered as energy communities without a formal legal form taken. As  the new legislation for EC has been approved by government recently, these cooperatives may officially change their legal form as energy communities soon. 

Key takeaways

• Czechia has not transposed the EU directives nor has have legal framework that touches upon ECs. 
• However, Czechia has ENERKOM which is energy cooperative that basically meets all the features of RECs in other countries.  
• ENERKOM is designated as strong EC based on our analysis. 
• Veřejný rejstřík or Czechia Federal registry is the one responsible in collecting database for ENERKOM in the country. 
• ENERKOMs are waiting for the new regulation to be official so they can be officially registered as ECs. 

Denmark

Denmark is one of the leading countries in developing energy communities in the EU as they have a long history of wind farms as one of their forms of energy sharing. It has adopted the provisions of REC and CEC from the EU directives, and the definitions go into some detail that elaborates effective control of the members. Denmark has the most number of ECs compared to other Nordic countries and most of the them have legal form taken as cooperatives. However, as they already have these initiatives before the adoption of RED, thus, they are not registered as ECs but as either wind, solar turbine, or district heating cooperatives. Cooperatives are structured as general partnerships. The partnerships are contractual relationships among many partners, which allow people to pool resources and directly own a project. The partnerships in Denmark sell the power to the local utility.  The designated authorities that are responsible in regulating and supervising the Danish energy market are the Danish energy agency (DEA) and the Danish Utility Regulator (DUR), both answering to the Ministry of Climate, Energy and Utilities. Nevertheless, it should be noted that they don’t have official registry of existing ECs or energy cooperatives in Denmark. It should be noted that there should be more types of energy sharing in Denmark that are also not registered, such as eco-villages and housing cooperatives who set up PV or heat pumps and share their energy together. It is not clear if they are counted as ECs in the acquired number of ECs that we put in our analysis below as they are just approximation. 

Key takeaways

• Denmark is one of the leading EU countries in developing ECs as they have a long history of wind farms as one of their forms of energy sharing. 
• Denmark has adopted both REC & CEC definitions with both having similar features, with main differences in effective control rule and the proximity criterion. Another type of energy sharing that exists it eco village. 
• REC is designated as strong EC. While CEC is broad by proximity and Eco-villages are broad by main activity and legal form. 
• There is no official database that records any of these initiatives in Denmark. 

Estonia

Estonia has transposed the EU directives and has implemented provisions on energy communities into two different concepts: Energy Communities (ECs) and Renewable Energy Communities (RECs). The country has 2 definitions of EC: REC and EC (instead of CEC).  Both definitions copy-paste of the EU definition. It is currently possible to set up an EC in the country, however, it not known how many that are operating now since there is no enabling framework for ECs. According to the available data online, there is only 1 energy community in Estonia right now under the name of Energia Ühistu which is considered as CEC. Besides that, apartment or housing associations may divide and sell electricity to apartments. In fact, this type of energy sharing is very common in the country. 

Key takeaways

• Estonia has transposed the EU directives with two definitions of ECs: Energy Community and Renewable Energy Community (REC) but no operating entity fits either definition. 
• Energiaühistu is an example of operating EC in the country which is a cooperative with purpose to build renewable energy parks across Estonia. EC in Estonian laws can be considered as broad by legal form, mobilisation, distribution of benefit, and structure of ownership. 
• According to a research in 2014, there should be 4 energy cooperatives in Estonia and these can be considered as strong EC. 
• Housing association is more common in Estonia, and they can be designated as broad ECs by size, distribution of benefit, and structure of ownership.  
• Official data for EC cannot be found online, the numbers that we used for analysis are from different research. 

Finland

The establishment of energy communities has become possible on December 22, 2021, when the regulations related to the EU’s electricity market reform were brought into force in Finland as well. Nevertheless, prior to this, Finland has introduced the notion of local energy communities (LECs) through the Decree 2020/1133. of EC which is Local energy community (LEC) which is the closest to REC. LEC is defined as a collaborative activity, enhanced energy system in production, consumption and energy sharing of individuals, households, and small businesses. In Finland two most common examples of community energy initiatives are joint acquisitions of solar panels by private citizens and small towns and a campaign started by an NGO to promote community participation in energy production.  

According to a study by Nordic Energy Research, LECs in Finland are still in early development phase in terms as legal entities and practical realities. Besides LECs, Finland also introduced the concept of CEC in March 2023 in the legislation. They also appointed Energy Agency to monitor the barriers to their development. Finland through Fingrid and CGI develop Datahub to support new energy communities. The exact number of active ECs is not monitored but according to Datahub, there are more than 100 operating ones in the country. Our interviewee also has similar opinion where he said there are approximately 150 ECs in Finland right now.  

Key takeaways

• The Finnish Government only adopted CEC definition from the EU directives and the country has their local type of EC named Local Energy Community (LEC). In practice, LECs are still considered in early development phase with some issues and questions yet to be answered.  
• LEC is defined as a collaborative activity, enhanced energy system in production, consumption and energy sharing of individuals, households, and small businesses. 
• Based on our analysis, LEC is designated as a strong EC as it meets all our criteria. 
• Datahub is a government entity that is responsible in enabling and promoting the development of LECs, but they don’t have an official registry of how many LECs that exist in the country. 

France

France has a long a long history of energy sharing. It has adopted the EU provisions on REC and CEC in an Ordinance no 2021-236 of 3 March 2021. The energy community concept unites nearby consumers and PV energy producers into a single self-consumption entity which all already existed before the adoption of the directives. In March 2023, it also modified the definitions and rules on access to support schemes by the law no 2023-175. Besides the two EU definition, we also analysed other entities similar to ECs in France that we based on a research paper by our interviewee. The information of these entities are still limited as the terms are not very commonly used anywhere else. Unfortunately, there is no centralised datahub that records and monitors the development of EC in France. Thus, our numbers here are based on various sources that we found online. It is also unclear which authority that is responsible in overseeing EC development in the country. 

Key takeaways

• France a long a long history of energy sharing. It has adopted the EU provisions on REC and CEC in an Ordinance no 2021-236 of 3 March 2021 
• Officially, there are only two definitions of EC: REC & CEC, but in this report we would use our interviewee’s models of ECs.  
• LIES are local distribution companies that didn’t merge with the newly created national champion EDF; CSC is a kind of energy sharing typically in housing association; NES is a model developed by project developers or energy suppliers or a combination of both.; CEP is basically REC; and CES is energy cooperative or can be CEC. 
• LIES is broad by local community focus, openness to ownership, size, legal form, distribution of benefits, and structure of ownership; CSC is broad by distribution of benefits; NES is broad by local community focus, size, and distribution of benefits; CEP is strong EC; and CES is broad by proximity. 
• It is not clear which authority is responsible in overseeing the development of ECs in France but Énergie Partagée tracks and maps RECs and CECs in the country.

Germany

Germany is the country with most numbers of ECs in the EU with a long history of energy cooperatives. Nonetheless, there is only one definition of EC which is quite broad and includes different legal models, associated actors, and business model. Germany adopted definition of EC named ‘Citizen Energy Company’ which has elements of the EU directives’ REC definition, such as proximity requirement, autonomy, and effective control. This definition is the only that is introduced in national legislation, however, there are several hundred energy cooperatives that were established prior to the adoption of Clean Energy Package.  Energy communities in Germany are regulated by the federal government and EU-bodies (and the respective laws, guidelines, and regulations) as well as the federal grid agency (“Bundesnetzagentur”) on an implementation level. Federal states are not relevant for the regulation. However, these authorities do not monitor or track the development of ECs in Germany. ECs usually take legal form as cooperatives  (‘Genossenschaften’) or as limited liability companies (GmbH/UG & Co. KG) and they all have their own associations who track their operating entities. Another way to acquire exact numbers of energy cooperatives is by contacting DSOs which is almost impossible to do as Germany has too many of them.

Key takeaways 

• Germany has a long tradition of the collaborative organisation of energy supply. It is one of leading countries in EU in terms of having most number of operating ECs or energy cooperatives. 
• There is no one clear definition of EC. There is, however, a local term named ‘Citizen Energy Company’ which transposes the elements of the REC definition from the Renewable Energy Directive.  
• EC in Germany usually take legal form as cooperatives  (‘Genossenschaften’) or as limited liability companies (GmbH/UG & Co. KG), with many differences in its features making it hard to categorise which is strong or broad. Meanwhile Citizen Energy Company is designated as strong as it follows the principles of Energy Cooperatives. 
• There is no centralised database for ECs in Germany due to its different legal form. The only way to acquire the numbers is by contacting all DSOs in the country 

Greece

Before the adoption of RED II, Greece already had many energy cooperatives that they consider as energy communities. After the adoption, all those entities then registered themselves as ECs since the laws are very broad and not strict. The definition of ECs are civil cooperatives that are active in the energy sector, with a particular interest in Renewable Energy Sources (RES). Citizens can use this tool to produce clean energy collectively and promote energy democracy, and, therefore, have an active role in the energy transition. Greece already adopted the EU directives and currently have three definitions of ECs which are REC, CEC, and energy communities established under the Law 4513/2018 whereas most of the existing ECs in the country fits the last category. Energy communities as defined by the previous law can’t be registered anymore. As reported by The Green Tank, there were 1,677 energy communities registered and no RECs or CECs projects are recorded based on available data in Greece until August 2023. Despite this, our interviewees think that there should be around 50-100 ECs that could fit the EU’s criteria of REC even though there is no official registry for this.  

According to our interviewees, most of the ECs that were established by prior law cannot be treated as “real” energy communities. The reason behind this is that they pursue financial gains such as commercial projects as according to the Greek legislation, the old energy cooperatives can be non-profit and for-profit. Most of them are for-profit, commercial projects. There is no limitation for the number of the members and families can be an EC in which as small as 5 people in one house can set up a PV and be counted as an EC. Membership is also open to everyone including big companies.  

Key takeaways 

• Greece has recently adopted the EU provisions of REC & CEC, but prior to this, they already have their own definition of EC under the Law 4513/2018. 
• The Greek local definition of EC, which is just “energy community”, incorporated a lot of the elements included in the EU definitions, such as the open and voluntary membership, the democratic governance and effective control, the requirement of proximity but it can pursue financial profits as its main focus. It is also usually developed by private investors and big companies, not citizens. REC & CEC are defined clearly with specific details and elaborations of principles of EU criteria. 
• The Greek local definition of EC is considered broad by membership, local community focus, mobilisation, distribution of benefits, and structure of ownership; REC is designated as strong, and; CEC is broad by proximity. 
• The General Commercial Register (GEMI) and the Hellenic Electricity Distribution Network Operator (HEDNO) are the two authorities responsible for the development of EC in the country. Yet, NGO named The Green Tank is the one that monitors and tracks the number of ECs in the country. 
• It is not known how many “real” ECs that do not pursue commercial gains among the 1,677 existing ECs in Greece. 

Hungary

Just like the other Eastern European Countries, Hungary is still at an early stage of developing EC. It established a framework for EC, through amendment of The Electricity Act LXXXVI  in 2021. It, however, combined REC and CEC as one definition under the name “energy community.” REC is adopted as a sub-category of EC and is restricted to the electricity market only which means it is granted rights and obligations in the electricity sector, such as production, storage, consumption, provision of distribution flexibility services, electricity distribution, aggregation, provision of electromobility services and operation of electric charging equipment from renewable energy sources. The definition excludes heating and cooling, which is against the EU provisions that allow RECs to be active in renewable energy sources in general and not just electricity. As the law is still not clear, there are only two ECs that are operating in the country at the moment. 

Key takeaways 

• Hungary established a framework for EC, through amendment of The Electricity Act LXXXVI in 2021 but it combined both REC and CEC together in one definition that is energy community. REC is seen as subset of EC. 
• Energy community is defined as legal entity which takes a legal form of a cooperative or non-profit business company with a primary purpose to provide environmental, economic, and social benefits to its members and its area rather than financial profit. REC is a subset of EC that produces electricity from RES, consumes, stores, and sells it. Both are restricted to the electricity market. 
• Based on our analysis Hungarian’s EC definition is broad by proximity, energy scope, openness to ownership, voluntary participation, distribution of benefit, and structure of ownership. REC is broad by openness to ownership, voluntary participation, distribution of benefit, and structure of ownership. 
• The National Regulatory Authority (NRA) in Hungary and the Hungarian Energy and Public Utility Regulatory (MEKH) are the designated authorities who are responsible to monitor the development of ECs in the country. 

Ireland

Ireland is still considered in the early stage of developing ECs, even though they have an official website that monitor and record them. Currently, there is only one local definition for EC which is Sustainable energy community (SEC) that was developed already before the Clean Energy Package and was introduced by the Sustainable Energy Authority of Ireland (SEAI). It can be regarded as a broader concept of REC as it acknowledges much looser collaborative partnership approaches by local community actors on various local actions focused on energy efficiency and renewable energy. According to our interviewee, since the legal form is very flexible and the size can be small, any other entity similar to SEC can also registered as one. For instance: Energy cooperative. There are approximately five energy cooperatives that exist in Ireland but they are also registered as SECs. The number of existing SECs is registered by SEAI. Aside from that, The Irish Renewables Support Scheme (RESS) has also introduced REC definition covering details about purpose, autonomy, and openness but right now there is no operating REC in the country yet. 

Key takeaways 

• Ireland is still at an early stage of adopting the EU directive provisions on energy communities.  
• Prior to the Clean Energy Package provisions, Ireland already has a pre-existing concept of Sustainable Energy Communities (SEC) that was introduced by the Sustainable Energy Authority of Ireland (SEAI).  
• SEC is quite broad as it may have a mix of activities and sectors in the community, not only energy production, consumption, and efficiency. Most of SECs are also very small with as few as 5 community members. 
• The Sustainable Energy Authority of Ireland (SEAI) is the one responsible in monitoring and developing SECs in the country. 
• While the number of SECs in Ireland is quite high, it is currently unknown how many of them are “strong” EC with main focus of energy production. 

Italy

The Italian Government is quite advanced in developing energy sharing system, including energy communities in their country. Italy has transposed the REC definition with legislative decree 199/08. 11.2021 and the CEC definition with the legislative decree 210/08.11.2021. Both definitions give specific details about elaboration of principles contained in EU criteria, while the purpose is just copy paste. Both definitions are similar, but RECs are solely working with renewable energy sources, while CECs can only engage in electricity sharing. The current enabling framework is currently reserved for RECs.  The official number of existing RECs and collective self-consumption group (gruppi di autoconsumo collettivo) is recorded by Gestore dei Servizi Energetici (GSE) or Italian Energy System Manager. Nevertheless, there is also a local environmental NGO named Legambiente that works in mapping ECs in Italy. GSE recorded there was 21 RECs in 2022, while Legambiente recorded 35 operating ones in 2023. The difference of numbers might be due to newly ECs that just recently got approved. Besides GSE, ARERA (Independent Energy Authority) is the official body responsible to assess the development of RECs and CECs in Italy. 

Key takeaways 

• Italy advanced in developing EC as it has transposed the REC definition with legislative decree 199/08. 11.2021 and the CEC definition with the legislative decree 210/08.11.2021. It has official registry and report of the operating RECs and CSCs that are available publicly and online. 
• Officially Italy has two types of energy sharing, they are Comunità energetiche rinnovabili (Renewable Energy community) and Gruppi di autoconsumo collettivo (Collective self-consumption group). 
• Comunità energetiche rinnovabili (Renewable Energy community) definition refers to most of the criteria contained in the RED II. It matches all our criteria for a strong EC. 
• Gruppi di autoconsumo collettivo (Collective self-consumption group) or CSC is a type of energy sharing of a set of at least two self-consumers who are in the same condominium or building. It is very close to a REC but in different legal form, which is a housing association or condominium. Besides that, CSC is a broad EC by distribution of benefits. 
• Gestore dei Servizi Energetici (GSE) or Italian Energy System Manager is responsible of recording RECs and CSCs. Another data collector for REC is a local environmental NGO named Legambiente. 
• Although Italy has transposed CEC definition but there is no record of any operating in the country right now. 

Latvia

Currently there is no existing EC in Latvia as it is not possible to set up an EC in Latvia since the country is still in the process of creating the enabling framework. The Latvian Parliament adopted the general legislative framework for energy communities with amendments to the Law on Energy and the Electricity Market Law on 14 July 2022. They both came into force on the 1st of January 2023. The Amendments on the Law of Energy introduce 2 kinds of ECs; Renewable Energy Communities (RECs) and Electricity Energy Communities which is the local term for citizen energy communities (CECs). However, while the basic definitions and rights are set, more specific organisational and technical provisions are still in progress. 

Key takeaways 

• Latvia has transposed EU provisions on REC & CEC, but it is still developing the enabling framework which means it is still not possible to set up an EC in Latvia. 
• The concept of EC is new in the country, and it has no pre-existing similar concept. 
• It has two definitions of ECs: Renewable Energy Community and Electricity Energy Community or EEC (elektroenerģijas kopiena) which is the local definition of CEC that only operates in electricity sector. 
• REC is broad by distribution of benefits and structure of ownership. EEC is broad by proximity, energy scope, distribution of benefits, and structure of ownership. 

Lithuania

Regulations on energy communities in Lithuania entered into force in 2019, but their potential has not yet been realised. The Lithuanian government wants to enable municipalities to set up RES energy banks and finance socially vulnerable groups such as large families and low-income earners. A new law on renewable energy has been approved which allows the establishment of RECs in Lithuania in 2020. However, currently there is not a single community created around RES installations in Lithuania. The national legislation includes provision of REC and CEC, and it specifies CEC can’t be a REC at the same time. There are a few communities that are formed outside the legal framework of EC, and their focus is mostly social or educational activities, even though they might have some projects energy-related such as putting PV onto their community shelter’s roofs or doing refurbishments of their childcare facilities. They are mostly based on religious or small rural communities like schools, but they are not prosumers or pilot projects. 

Key takeaways 

• Lithuania has transposed the EU provision on REC and CEC with details about autonomy and effective control for REC. Nevertheless, there is no operating EC in the country.  
• Both REC and CEC have definitions that are more or less the same as EU’s one but with great details in geographical proximity and effective control and autonomy for REC as CEC has no reference to geographical proximity and effective control. 
• REC meets all our criteria for strong EC while CEC is considered as broad EC by proximity and energy scope. 
• The State Energy Regulatory Board will inspect, supervise, and control the compliance of RECs and CECs in the future. 

Luxembourg

Luxembourg developed a framework for RECs in February 2021, and it has transposed the REC definition into the national law but leaving out EU criteria for openness and autonomy. Compared to an EC, the legal structure and the aims are different, but the actors are the same. Prior to REC, the country already has a pre-existing energy cooperative (E-coops) that engage in PV projects. Some e-coops promised financial income such as 2% of investment paid each year, and some did as their aim was to further the energy transition and empower the people. They emerge on a voluntary basis, finding other volunteers, creating a legal structure, and getting new members in the future. The people doing the e-coop’s administrative voluntarily as they do not get paid because it would be too much of a financial burden for the e-coop. Only the technical suppliers doing the installations, as well as an accountant, receive the pay. During the decision-making, each member has 1 vote regardless of the share.  Local governments are never part of energy cooperatives; however, they are involved with them (on their initiative). For example, providing municipal buildings’ roof space for PV installations free of charge. 

Key takeaways 

• Luxembourg has transposed REC definition into the national law but no definition about CEC. The country currently has no operating REC yet but has several energy cooperatives that were established prior to the adoption of EU provisions. 
• REC definition is just a copy-paste of the EU definition that does not specify any requirements other than eligibility. 
• Energy cooperative is a pre-existing entity similar to EC with a focus to contribute to the energy transition by implementing and developing projects for the production, purchase, sale and distribution of renewable energy. 
• According to our analysis, Luxembourg’s definition of REC is considered as broad EC by size, openness to ownership, structure of ownership, and size. Energy cooperative, on the other hand, is designated as strong EC. 
• RECs must notify their creation, dissolution, and changes in composition, to the regulator and grid operator, although there is no requirement to comply with the participation requirements. 
• We acquired our data for energy cooperatives from BiBe which is a platform for transition projects in Luxembourg that is in cooperation with the government. 

Malta

Previously, Malta’s National Energy and Climate Plan (NECP) explicitly rejects the development of energy communities in the draft version of the NECP 2021-2030 energy communities are referenced mentioning that the legal framework originally established for cooperatives also lends itself for REC. However, Malta finally transposed the EU provisions for RECs and CECs in Subsidiary Legislation 545.35 and it specifies that it shall apply without prejudice to Malta’s right to exercise the derogations granted pursuant to Article 66 of Directive (EU) 2019/944 of the European Parliament and of the Council of 5 June 2019 on common rules for the internal market for electricity and amending Directive 2012/27/EU (recast)(article 24(8)). Nonetheless, the provisions are just a copy paste from the EU directives without any further details such as autonomy. In fact, there is not a single operating EC or anything similar in the country. 

Key takeaways 

• Malta has transposed the EU provisions on REC and CEC. However, there is no existing EC or any entity similar in the country. 
• REC and CEC are almost a copy paste from the EU definitions. 
• Based on our analysis, REC is broad by size, legal form, distribution of benefit, and structure of ownership. CEC is broad by size, legal form, proximity, energy scope, distribution of benefit, and structure of ownership. 
• The national legislation does not specify any authority responsible to oversee the implementation of EC in Malta. 

Netherlands

Netherlands is one of the leading countries in the EU in developing energy communities. However, ECs are currently not yet regulated in Dutch law. They will be included in the amended Energy Act. A bill for this was published in early 2021 and REC & CEC definitions were transposed in Energy Law 2022. However, it merged the two definitions into one under the term ‘energy community’. Energy community is actually a new term that is being used in the Netherlands. The country has a long history of energy sharing (Energiecollectieven) and almost, if not all, of them are energy cooperatives. According to our interviewee, the framework for EC is very different to energy cooperative, and other similar initiatives. They all exist but the distinction is still debated between scholars. A clear distinction must be made between energy communities and other forms of citizen participation in the energy market. The number of energy cooperatives or energy initiatives in the country keeps growing annually. In 2022, it was recorded that there was 1% growth than the previous year.

Key takeaways 

• The Netherlands is one of the forerunners in developing energy sharing faremwork in the EU. It however only has one definition of energy community that emerged the EU’s definition of REC and CEC. 
• Energy cooperative is the most common type of energy sharing in the country which can also be considered as an energy community. A local energy initiative or energy cooperative is a group of residents of a municipality who want to green their village or city together. 
• Both Energy Community and Energy Cooperative are designated as strong as they fit all criteria in our framework. 
• There is no designated authority that monitor the development of ECs, but HIER and Energie Samen are the one who are mapping existing energy cooperatives. 

Poland

EC is not common in Poland.  Some of the biggest challenges in establishing an EC is obtaining the license and connecting to the grid. In Poland, cooperatives are not allowed to sell energy, so surplus production must be fed into the grid. The cooperative is allowed to use 60% of the amount fed in over the next 12 months – the remaining 40% the grid operator keeps for free. Poland has only partially transposed the EU provisions on energy communities and currently there is no clear definition for energy community. When the government transposes them appropriately, the conditions for community energy will be more favourable. However, the country’s legislation for cooperative is also outdated, making energy sharing a challenge in the country.  

Key takeaways 

• Poland has not fully transposed the EU provisions on REC and CEC and there is no clear definition of EC. It, however, has a few energy cooperatives that are operating. 
• Energy cooperative is more or less an EC with same features but not legally registered as EC. It is a legal entity with the purpose to produce electricity, biogas, or heat from renewable sources. There is also another type of energy sharing, named Energy cluster. It is controlled by private companies for the use of their business or for their commercial purposes.  
• According to our analysis, EC and Energy cooperative are designated as strong. Energy cluster is broad by distribution of benefit and structure of ownership. 
• We acquired the number for energy cooperative from a registry by the Polish Director General of the National Agriculture Support Centre. While the number for energy cluster is from research in 2020. 

Portugal

Portugal transposed established a framework for self-consumption of renewable energy on individual and collective level and by renewable energy communities with the Decree 162/2019. The 2019 decree law adopts the major lines of the EU REDII in terms of membership, possible activities etc. and the need to form a legal person. Later in 2022, the country introduced provisions for REC and CEC with the Decree 15/2022. Yet, both definitions are essentially copy pastes from the EU definitions. According to our desk research, there is one operating Solar Energy Community named CleanWatts. Portugal also has Collective self-consumption (CSC) entities in a form of housing associations and Electrical Cooperatives which are more common than EC. However, information about these two kinds of energy sharing is limited and there is no official registry for them. 

Key takeaways 

• Portugal has transposed both REC and CEC, but currently there is only one EC (which we considered as CEC) operating in the country under the name CleanWatts. 
• REC and CEC definitions are basically copy pastes from EU definitions. Besides them, there are Electrical cooperative which is Coopérnico and Collective self-consumption that is a group of at least two self-consumers organised in condominiums who produce and consume energy together. 
• REC is considered as strong EC; CEC is broad by proximity and energy scope; Electrical cooperative is strong; and CSC is broad by distribution of benefit. 
• The Directorate-General for Energy (DGEG) monitors the number of CSCs in Portugal, but there is no registry for ECs or electrical cooperatives. In fact, there is no designated authority to oversee the development of EC mentioned in the legislation. 

Romania

Romania introduced the concept of Renewable Energy Communities (RECs) through the emergency ordinance 163/2022 published in the official monitor no 1165 of December 6, 2022. Citizen Energy Communities (CECs) were introduced through the emergency ordinance 143/2021 published in the official monitor no 1259 of December 31, 2021, which amends the Electricity and Natural Gas Law no. 123/2012. Both definitions are copy paste of the EU directives with no clearly defined purpose and elaboration of principles such as autonomy, openness, and voluntary. Without more clarity to its definition and practice, it is not possible to set up an EC. While according to Energy Communities Repository’s research, there was no pre-existing concept of EC in Romania there is an energy cooperative named Cooperativa de Energie (CdE) which claims to be the first Romanian energy community. It was launched in October 2019, by 15 members, controlled and owned directly by citizens participating in the local energy transition. 

Key takeaways 

• Romania is still at the early stage in developing ECs. It has transposed the EU directives for REC and CEC but leaving out details about autonomy, openness, voluntary, and legal form. 
• REC & CEC definitions are just copy paste of the EU directive. 
• REC is considered broad by legal form and distribution of benefit as the law doesn’t specify about the legal form or how benefit is distributed among the members. 
• CEC is broad by legal form and distribution of benefit with the same reasons as REC, but also broad by proximity and energy scope. 
• ANRE is said to be responsible for developing further regulations to operationalise the energy community concept in Romania but since there is just one EC in the country right now, there is no official registry yet. 

Slovakia

EC is still a new phenomenon in Slovakia. The regulations are still being developed and they provide no specific technical instructions on how to set up an EC in the country. The act 256/2022 of 22 June 2022 has amended Act 251/2012 on Energy to define EC and Communities Producing Energy from Renewable Sources (CPERS). The legal regulation of energy communities and communities producing energy from RES is still relatively framework. Several fundamental matters are left to the ÚRSO decree, which should enter into force in the coming months. Electricity sharing itself is currently not feasible. A prerequisite for the proper sharing of electricity within the energy community, the community producing energy from RES or by active consumers is primarily a functional electronic system displaying individual data, i.e. the Energy Data Centre (EDC). The launch of the Energy Data Centre is currently planned in two phases. According to the operator of the EDC, which is supposed to be OKTE, as, the launch of the first phase is expected at the end of June 2023, and at the beginning of July, the basic functionality should be operational to enable new market participants to participate in electricity sharing and providing flexibility. 

Key takeaways 

• Slovakia is in the early stage in developing ECs. 
• Slovakian legal framework defined two types of ECs: Energy Community, which is similar to CEC in other countries; and Community Producing Energy from Renewable Sources (CPERS), which may be considered as REC. 
• CPERS can be considered as strong EC, while EC is broad by energy scope. 
• There is no framework for promoting and facilitating development of ECs. 
• The first CPERS in Slovakia is Local action group Dolný Liptov that is still under development. 

Slovenia

Slovenia has transposed EU provisions on REC and CEC. Some criteria are a copy paste from the EU directives and need further elaboration such as the autonomy criterion. Slovenia started developing the framework for ECs in 2021 then replaced the previous framework on community self-care which regulated collective self-consumption (CSC) that was set up in 2019. Prior to the adoption of EC, Slovenia already had operating energy cooperatives which are more focused on district heating rather than electricity. The country also had some pilot projects in the past, including COMPILE pilot site Luče which many considered as an EC. The Luče Energy Community is part of Horizon2020 project that ended in 2022. It did not have the legal framework as an EC. While it seems that the country has quite community focused initiatives and legal framework ready to support the development of ECs, there is not a specified designated authority to support and monitor ECs in the law. There is also no official registry for existing energy cooperatives in Slovenia. 

Key takeaways 

• Slovenia already has pre-existing energy cooperatives prior to the adoption of the EU directives. These energy cooperatives also can be considered as energy communities.  
• There are REC and CEC that are copy paste from EU definition. No local definition for energy cooperative or pilot project, but they have principles of ECs, like the autonomy and voluntary. 
• REC and Energy cooperatives are designated as strong as they share the same features, in fact REC’s legal form is cooperative according to the law. CEC is broad by proximity and energy scope; and pilot project is broad by legal form and size. 
• There is no official database for energy cooperatives or similar initiatives in Slovenia as it is not specified which authority to oversee that monitors the development of them. 

Spain

Spain has only transposed REC definition through Royal Decree-Law 23/2020. The definition is also a copy paste of the EU definition without any elaboration on the principles. There is no transposition for CEC yet by the time this report is published. The decree does not provide other important details, including legal entities allowed for ECs and designated authority that is responsible for the development of ECs in Spain. Nevertheless, we managed to find more information on the official website of Institute for Energy Diversification and Saving or Instituto para la Diversificación y Ahorro de la Energía (IDAE). According to IDEA, almost half of ECs in Spain take a legal form as cooperatives (32), followed by association (27), cooperation (5), and the 5 take other forms that would be explained in later section. More than 85% members of these ECs are natural persons and followed by SMEs around 14%, the rest is not listed on the website. There are around 337 operating projects by the 69 ECs in Spain.  

Key takeaways 

• Spain has only transposed the provision of REC, and the definition is basically a copy paste without elaboration on the principles. There is no definition of CEC yet. 
• There is no information about allowed legal form for ECs in Spain, but most take forms as cooperatives, followed by association, company, and others.  
• RECs in cooperative and association form are designated as strong EC while ones in company and other forms are broad by legal form. 
• Institute for Energy Diversification and Saving or Instituto para la Diversificación y Ahorro de la Energía (IDAE) has a map and information about operating ECs in Spain. 

Sweden

Sweden has yet to fully transposed the EU directives. There is only one definition used which is energy community. EC is described as initiatives run by civil society actors such as charities, not-for-profit organizations, voluntary neighbourhood networks and co-operatives which develop either or both energy saving and renewable energy generation measures. However, Sweden already has pre-existing community initiatives that are similar to EC. These variants are not adhering to EU’s definitions of REC or CEC. There is also no existing official database that record these initiatives. A study by our interviewee tried to map energy communities that is approximately around 140 now. The mapping indicated that the most common forms of initiatives in Sweden were Wind cooperatives, Solar cooperatives, and eco-villages. ECs generally take legal forms as incorporated associations, non-profit organisations (samfällighet), and tenant-owned apartments associations (bostadsrättsföreningar). Another type of grass-rot initiative like EC is Eco Village which shares several features with EC’s principles. The implementation of EC in Sweden is regulated by The Swedish Energy Agency and EU bodies.

Key takeaways 

• Sweden has yet to transpose the EU directives on REC and CEC, however, it already has pre-existing grass-root initiatives that are like EC.  
• Wind cooperatives, Solar cooperatives, and Eco-villages are the most common models of ECs in Sweden. 
• The first model of EC is Wind cooperative where members buy shares in a wind turbine to produce energy, thereby bearing the investment cost together. Another model is solar cooperative where tenant-owned apartments associations (bostadsrättsöreningar) are investing in solar panels on their apartment buildings for their internal consumption.  
• Eco-village is a community focusing on social, ecological, and economic sustainability-sufficiency. 
• Energy community (wind and solar cooperatives) are designated as strong EC and Eco-village is broad by main activity and legal form. 
• There is no official database that records any of these initiatives in Sweden.