Independent Aggregators (IAs) have the potential to provide an additional means of accessing the market for small producers and end consumers, including prosumers, small-scale RES producers and DSR flexibility providers. Independent aggregators can be relevant for the further unlocking of incentive-based (explicit) demand response, bundling smaller amounts of flexibility into larger amounts that are dispatchable and which can be traded on European coupled wholesale and/or in local flexibility markets. They can also indirectly overcome market entry barriers (such as minimum bid sizes, complexity and costs for settlement and clearing, communication requirements, regulatory complexity, etc.) for smaller companies and individuals that wish to be ‘prosumers’ or flexible regarding their energy use but which individually are too small to handle daily requirements in a secure and profitable way. Enabling independent aggregation is therefore an important step in further unlocking the potential of demand-side flexibility resources in Europe.
The Clean Energy Package has formalised independent aggregation for the first time at EU level, mandating Member States to recognise and enable this type of market participant. Independent aggregators no longer need any prior consent from suppliers to enter the market and can provide specialised, innovative services to consumers, leveraging detailed knowledge of energy markets. However, a set of framework rules for aggregation is still missing in many Member States and regulatory barriers or uncertainties for aggregators and parties affected by their actions remain. On the one hand, full implementation of the Clean Energy Package (CEP) is needed, including, for example, legal recognition of independent aggregators, their ability to enter the market without supplier consent and wider requirements such as full access to energy wholesale markets, including balancing and ancillary services, data access etc. On the other hand, additional EU level guidance on CEP implementation is needed in two important areas, as explained in the full paper below.