Energinet changes the rules of the game: maturity and grid value are expected to be decisive for access to the electricity grid

Energinet has published a new model for processing electricity grid connection applications. The model is Energinet’s attempt to respond to the sharp increase in the number of projects seeking access to the transmission grid and, according to Energinet, is intended to ensure more efficient use of the limited grid capacity.

The initiative includes both stricter maturity requirements and a new prioritisation model that places greater weight on project maturity and their contribution to efficient grid utilisation.

Stricter maturity requirements throughout the project lifecycle

Energinet is introducing a phased “stage-gate” model with three maturity gates that projects must pass to progress in the grid connection process.

The new requirements include, among other things:

• Documentation of control over the project site and the planning basis already at the screening stage.
• Payment of a start-up deposit of DKK 500,000.
• Requirement for technical documentation and a draft guarantee before the maturation phase.
• Documentation of an approved local plan or clarified planning conditions before a grid connection agreement can be concluded.

The purpose is to ensure that only projects with a genuine likelihood of being realised take up capacity and case-processing resources in the grid.

The new requirements will not only apply to new projects, but will also affect a number of projects already submitted, depending on their current phase.

New prioritisation model for projects in the queue

Energinet is also changing the way projects are prioritised in the screening phase.

Going forward, projects will, among other things, be prioritised based on:

• Whether the project uses already reserved capacity.
• Whether the project constitutes expected organic growth for existing customers.
• Whether the project can be connected without significant grid expansions.
• Whether the project contributes to a better balance between production and consumption in the grid.

Notably, so-called “grid-relieving” projects will be given higher priority. This means, for example, that new electricity consumption facilities in production-dominated areas – including electrolyser plants, PtX plants or other large consumers – may be processed before new generation facilities in the same area.

The model therefore marks a shift away from a purely queue-based approach towards prioritisation based on overall value to the electricity system.

Criticism from business organisations

However, the new model has been met with considerable scepticism from several business organisations.

The criticism is primarily that the model does not address the fundamental challenge: a lack of transmission capacity.

Several stakeholders have pointed out that changed prioritisation rules do not in themselves create more grid capacity, and that companies still lack clarity on when specific projects can be expected to be connected. At the same time, concerns have been raised that uncertainty about grid access may delay investments in electrification, green industry, data centres, PtX plants and renewable energy projects.

The criticism should also be seen in light of the broader debate about the pace of expansion of the Danish transmission grid, where both industry organisations and public authorities in recent years have pointed to significant challenges in delivering grid expansions.

What does this mean for project developers?

For project developers in renewable energy, batteries, PtX and large electricity consumption, the model means that the timing of project submission will become less decisive than before.

Instead, there will be increased focus on:

• documented project maturity,
• clarified planning conditions,
• realistic development timelines,
• the project’s impact on the local grid balance, and
• the project’s overall contribution to efficient use of existing grid capacity.

Early clarification of land matters, municipal planning and the project’s technical prerequisites therefore becomes even more important in the development phase.

The Danish Utility Regulator’s role

On 8 June 2026, the Danish Utility Regulator announced that it has initiated a supervisory review of Energinet’s announced prioritisation model. The purpose of the review is to clarify whether Energinet may apply the prioritisation model without the Danish Utility Regulator’s prior approval.

Under the Danish Electricity Supply Act, the Danish Utility Regulator generally approves the general terms and conditions for access to the transmission and distribution network. This is done based on principles of transparency, non-discrimination, reasonableness and objectivity.

Our comments

Energinet’s model follows the principles set out by the Danish Energy Agency in its guidance on prioritising grid connection requests from February 2026, and reflects a general European trend towards more active management of scarce grid resources.

At the same time, the model raises interesting legal questions. Whereas grid connection has historically largely been characterised by objective queue principles, the new model introduces a more dynamic and discretionary prioritisation based on maturity and system benefit.

In the longer term, this may raise questions about transparency, equal treatment and documentation of the prioritisation decisions made. In particular, projects that find themselves deprioritised compared with competing projects may have an interest in testing the basis for Energinet’s assessments.

The new model will therefore not only affect project development and investment decisions, but may also form the basis for a new practice regarding the scope of Energinet’s discretion when administering access to the Danish transmission grid.

SAAF advises on energy projects

SAAF has continuously advised on the challenges of grid connection for energy projects within both offshore wind and other renewable energy, and we follow developments in the area closely. We have strong relationships with both the relevant authorities and commercial project developers, and can advise on both the legal and commercial terms for the projects.