Public consultation on the amendment of the Belgian Multi NEMOs Arrangement (MNA)

Context

In accordance with the regulation 2015/1222, establishing guidelines on capacity allocation and congestion management, arrangements have been proposed by Elia in case more than one NEMO is designated and/or offers trading services in the Belgian bidding zone. The Multi-NEMO Arrangements (MNA) has been approved by the CREG in 2016.

According to Decision No 08/2025 of 17 September 2025, The European Commission and the European Union Agency for the Cooperation of Energy Regulators (ACER) have highlighted the need to harmonize the rules applicable to bidding zones in the event of market decoupling, in configurations where multiple Nominated Electricity Market Operators (NEMOs) operate within the same bidding zone. By consequence, all Transmission System Operators (TSOs) and national regulatory authorities are encouraged to review their national legislation and the procedures applicable to bidding zones in case of decoupling.

The aim is to ensure that each Multi-NEMO Arrangement (MNA) includes transparent rules for the provision of a single day-ahead reference price in case of partial decoupling. Where necessary, this may require an amendment to the MNA in accordance with Article 9(13) of the CACM Regulation (EU) 2015/1222.

In this context, the present document proposes an amendment to the Belgian MNA, which has been prepared in collaboration with the Belgian NEMOS, following the article 45/57 of the Regulation (EU) 2015/1222 to:

• Simplify the decoupling scenarios of the MNA by including, under the “partial decoupling” category, situations where only a subset of Belgian NEMOs remains coupled;
• Clarify that in such partial decoupling situations, the Single Day-Ahead Price calculated by the NEMO(s) still participating in the market coupling is the sole relevant price for the Belgian bidding zone;
• Specify that a decoupled NEMO must not operate a local (i.e. proprietary) day-ahead auction using day-ahead products or products with the same characteristics during the day-ahead timeframe.

These amendments align the Belgian MNA with Regulation (EU) 2024/1747 of the European Parliament and of the Council of 13 June 2024, which introduced a new point (ca) in Article 7(2)(c) of Regulation (EU) 2019/943. This provision stipulates that, from one hour before the day-ahead gate closure time until the latest point in time where day-ahead trading is allowed, NEMOs must submit all orders for day-ahead products to the Single Day-Ahead Coupling and must not organise trading with similar products outside of it.

Finally, this update also reflects recent developments in the European electricity market design that did not exist at the time of the original MNA in 2016, such as the introduction of Intraday Auctions and new coupling configurations.

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 21 November 2025 to 19 December 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.

The consulted document and the consultation report will be annexed to the letter with the derogation request, to be submitted to the CREG for approval.