The ongoing recast of the CACM Guidelines comes at a decisive moment for the EU’s Internal Electricity Market. As one of the central regulatory pillars for short-term electricity trading, the Guidelines must align with the Union’s broader political and strategic direction. This paper concludes that the current proposal does not sufficiently reflect the EU’s mandates. The current version fails across key dimensions like simplification, legal coherence, regulatory predictability, SME participation, competitiveness, investment, resilience and democratic governance.
