Earlier this year, DG Competition released a roadmap laying out its intentions for how it plans to carry out a 'Regulatory Fitness Check' of the existing State aid rules. We responded to this Roadmap, indicating the main issues DG Competition should be taking into account as it assesses the existing Energy and Environmental Aid Guidelines (EEAG) and their impact on citizens and renewable energy communities, which are now officially recognised and supported under the EU's recently finalised Clean Energy for All Europeans package.

We expect DG Competition to look closely at the role RECs play in the market, their potential to contribute to EU climate and energy policy objectives, and the unique challenges that they face in participating in auctions and tenders, based on the characteristics that differentiate them from traditional commercial undertakings.

The EEAG need to support delivery of the EU’s climate and energy objectives, as well as the Energy Union's aim to put citizens at the core.The existing EEAG will need to be amended to fit the new context of the CEP, including its intent to ensure citizens can participate both individually and collectively through energy communities across the energy market. In particular, the revisions of the EEAG will need to support and reinforce the national enabling frameworks that Member States will be required to put in place for renewable energy communities, as well as ensure that Member States can put in place proper support schemes that allow renewable energy communities to participate on a level playing field with other market actors.

DG Competition has now opened a consultation and questionnaire on the existing State aid guidelines. You can participate here: https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-6623981/public-consultation_en