Public consultation on the Proposal for Amendment to the T&C BSP mFRR

Context

In the context of the balancing incentive on BSP Faster Settlement formulated by CREG in the Decision (B)658E/89, ELIA reviewed the settlement and invoicing processes for Balancing Service Providers to ensure faster payments for their service, positively impacting their required working capital, contributing to a faster feedback loop on the service and overall creates efficiencies in operating the processes. The advantage of faster payment to the BSPs will consequently help to remunerate their downstream grid users. Furthermore, by reducing payment timings, this improvement facilitates market access for new BSPs by lowering entry barriers and helps to increase competition among them. The historical approach for settlement several months after delivery merits an update. This revision enables the transition to more digitalization and contemporary functionalities like self-billing, where ELIA proposes to issue invoices and credit notes, in the name of and on behalf of the BSP.

The proposed changes have been discussed with stakeholders during 3 workshops, that took place on 05/12/2024, 13/02/2025 and 02/04/2025.

The changes in the settlement and invoicing process are common to the three balancing products: FCR, aFRR and mFRR, and require certain amendments to the terms and conditions. Therefore, ELIA is organizing simultaneously a public consultation on amendment proposals for each of the balancing products. Any comment or suggestion from the stakeholders on the common changes in the settlement and invoicing process will be considered for the three products if applicable.

Next to the amendments relative to settlement and invoicing process, this proposal for amendment to the T&C BSP mFRR also contains:

• Amendments relative to the Participation of Low-Voltage Delivery Points via DSO’s Headmeters. In the context of the ongoing opening of the mFRR market segment to Delivery Points connected at low-voltage level. Considering this opening and the resulting possibly very high number of individual low-voltage Delivery Points that could participate to the mFRR Service in the future, the proposal for amendment aims to facilitate the operational bidding process for BSPs and to reduce the impact on the involved IT tools;
• Amendments relative to the roll-out of aFRR/mFRR combinations. Following the study “Analysis of the possibility to offer different types of balancing products on DPPG” published on 20th October 2022, Elia would like to remove any remaining contractual obstacle to the aFRR/mFRR combo in activation (the contractual combo on different quarter-hours is already allowed). Indeed, based on the answers to a survey carried out in May 2022, there is a high interest from market parties for this combo. Therefore, the current proposal of amendments of the T&C BSP mFRR integrates the necessary modification to allow the simultaneous activation (“combo activation”) of aFRR and mFRR using the same DPPG.
• Amendments relative to the digital update of the Contact Details for the BSP. With the development of the EPIC digital customer portal, BSPs will be able to update their list of contacts through the EPIC portal, instead of by exchanging e-mails. In addition, ELIA proposes to update the list of roles to include in the contact details list.
• Amendments relative to the reduction of the time window for a prequalification test. Elia proposes to reduce the time window during which the prequalification test can be triggered from 24h to 4h. In this way, Elia aims to facilitate the prequalification process.
• Clarification with respect to the applicability of the bidding obligation. Pursuant to article 18(7)b of the EBGL, each connecting TSO may include “a requirement for balancing service providers to offer the unused generation capacity or other balancing resources through balancing energy bids or integrated scheduling process bids in the balancing markets after day ahead market gate closure time”.  This was already declined in the T&C BSP aFRR Art. II.3.8. The article is revised to further clarify the bidding obligation. 
• Clarification with respect to the rules for defining Delivery Points in case of a Technical Facility. In an effort to clarify the definitions of Delivery Points used in its different products, ELIA proposes to add a rule on the definition of Delivery Points depending on the type of the concerned Technical Facility, for DPSU, as it is already precised in the Terms & Conditions for Outage Planning Agent (OPA) and Scheduling Agent (SA). The addition of this rule aims at defining a clear guideline on the definition of Delivery Points, and avoid incoherences in the definition of Delivery Points between Balancing Services and SA/OPA Services that may lead to operational inefficiencies.
  
  A more extensive overview of the amendments and the context in which the amendments are proposed can be found in the explanatory note available on this website.

Consultation Period

Elia invites all stakeholders to submit any comments and suggestions they may have on the document submitted for consultation.

The consultation period runs from 28 May 2025 to 30 June 2025.

After the consultation period, Elia collects all comments and feedback from the market parties. Elia will analyse these comments and integrate them into a consultation report together with Elia’s responses. In addition to the consultation report, Elia will publish the reactions of the market parties (including names) on the website, unless it is explicitly stated that the contribution is to be considered confidential.