Structure of the EU electricity system Rules governing the EU electricity system cover the regulation of both: • the physical infrastructure for electricity generation, transport, and use (referred to as either the electricity network or grid), and • electricity markets (ie the flow of money) Electricity flows through the EU electricity network broadly as follows: • Generation—the production of electricity using, for example, fossil fuels, solar, wind, nuclear, or geothermal sources • Transport—the movement of electricity through the network (or grid). The transport system is typically subdivided as follows: ◦ Transmission—the long-distance transport of electricity on the extra high-voltage and high-voltage interconnected system with a view to its delivery to final customers or to distributors ◦ Distribution—the transport of electricity from the transmission networks and distribution of that electricity to consumers. Electricity from smaller renewable sources, such as solar and wind, is generally fed into the distribution networks • Supply—the sale (including resale) of electricity to wholesale customers (who purchase electricity for the purposes of resale) and final customers (who purchase electricity for their

Structure of the EU electricity system Rules governing the EU electricity system cover the regulation of both: • the physical infrastructure for electricity generation, transport, and use (referred to as either the electricity network or grid), and • electricity markets (ie the flow of money) Electricity flows through the EU electricity network broadly as follows: • Generation—the production of electricity using, for example, fossil fuels, solar, wind, nuclear, or geothermal sources • Transport—the movement of electricity through the network. The transport system is typically subdivided as follows: ◦ Transmission—the long-distance transport of electricity on the extra high-voltage and high-voltage interconnected system with a view to its delivery to final customers or to distributors ◦ Distribution—the transport of electricity from the transmission networks and distribution of that electricity to consumers. Electricity from smaller renewable sources, such as solar and wind, is generally fed into the distribution networks • Supply—the sale (including resale) of electricity to wholesale customers (who purchase electricity for the purposes of resale) and final customers (who purchase electricity for their own

Structure of the EU electricity system Rules governing the EU electricity system cover the regulation of both: • the physical infrastructure for electricity generation, transport, and use (referred to as either the electricity network or grid), and • electricity markets (ie the flow of money) ‘Electricity markets’, as defined in the Electricity Directive, are markets for electricity, including over-the-counter markets and electricity exchanges, markets for the trading of energy, capacity, balancing and ancillary services in all timeframes, including forward, day-ahead and intraday markets. The EU electricity market is divided as follows: • wholesale, or production, markets comprises the flow of electricity and underlying transactions between generators and retailers. Generators, suppliers and some large industrial consumers participate in wholesale markets, and • retail markets for the supply of electricity to final consumers Directive (EU) 2019/944 (the Electricity Directive) primarily contains rules on retail markets, whereas wholesale markets are primarily governed by Regulation (EU) 2019/943 (the Electricity Regulation), along with supplemental Regulations (referred to as guidelines). This Practice Note focuses on retail markets

This Practice Note provides an introduction to the framework of EU legislation governing the physical infrastructure for electricity generation, transport, and use in the EU, and EU wholesale and retail electricity markets. It covers the evolution of EU electricity system regulation, from the first liberalisation of European energy markets in the 1990s to the Fifth Energy Package, as adopted in 2024 to revise the Electricity Directive (Directive (EU) 2019/944) and Electricity Regulation (Regulation (EU) 2019/943) in line with the EU’s decarbonisation goals. This Practice Note also sets out the key actors in the EU electricity system, and outlines their primary roles and obligations, including detail on the cross-border role of the European Agency for the Cooperation of Energy Regulators (ACER). Structure of the EU electricity system Rules governing the EU electricity system cover the regulation of both: • the physical infrastructure for electricity generation, transport, and use (referred to as either the electricity network or grid), and • electricity markets (ie the flow of money) Physical infrastructure Electricity flows through the EU electricity

Structure of the EU electricity system Rules governing the EU electricity system cover the regulation of both: • the physical infrastructure for electricity generation, transport, and use (referred to as either the electricity network or grid), and • electricity markets (ie the flow of money) ‘Electricity markets’, as defined in the Electricity Directive (Directive (EU) 2019/944), are markets for electricity, including over-the-counter markets and electricity exchanges, markets for the trading of energy, capacity, balancing and ancillary services in all timeframes, including forward, day-ahead and intraday markets. The EU electricity market is divided as follows: • wholesale or production markets comprising the flow of electricity and underlying transactions between generators and retailers, and • retail markets for the supply of electricity to final consumers The electricity generated at a power plant is frequently bought and sold a number of times in the wholesale market, often by means of a power or energy exchange, before reaching the final consumer. Natural gas is traded in a similar manner. Currently, several hundred companies are involved in wholesale electricity

Background—the First to Fifth Energy Packages Under Article 194 of the Treaty on the Functioning of the European Union (TFEU), Member States have (among many other things) conferred to the EU competence to ensure the functioning of the energy market, ensure security of energy supply, promote energy efficiency and energy saving and the development of new and renewable forms of energy, and promote the interconnection of national energy networks. Article 194 goes on to require the European Parliament and Council to establish the measures necessary to achieve these objectives. As a result, a series of legislative packages have been adopted since the 1990s to establish a common framework of EU-level rules to open up national energy markets. These packages are outlined below: • First Energy Package—adopted between 1996 and 1998, to introduce the first liberalisation of national energy markets • Second Energy Package—adopted in 2003, to allow industrial and domestic consumers to choose their own energy suppliers from a wider range of competitors • Third Energy Package—adopted in 2009, to introduce the following: ◦ rules on the separation

ARCHIVED: This Practice Note has been archived and is not maintained. This EU employment and social policy tracker covers key cases from 2024 to 2025 under the following topics: • working conditions—working hours, part-time and fixed-term work, posting of workers • informing and consulting workers about collective redundancies and transfer of companies • equal treatment and discrimination at work, and • social policy rules, social security coordination 2025 Cases Case Judgment date Key facts/analysis Case C-485/24, Locatrans Sàrl v ES, ECLI:EU:C:2025:955 11 December 2025: Judgment Applicable law in the event of a change in the habitual place of work The Court of Justice held that where an employee's habitual place of work changes during employment, the most recent place intended to become the new habitual place should be considered under the ‘more closely connected’ test in the last limb of Article 6(2) of the Rome Convention when determining applicable law absent party choice. The case concerned a Luxembourg transport company employee whose contract specified Luxembourg law

ARCHIVED: This Practice Note has been archived and is not maintained. This EU employment and social policy tracker covers key cases from 2021 to 2023 under the following topics: • working conditions—working hours, part-time and fixed-term work, posting of workers • informing and consulting workers about collective redundancies and transfer of companies • equal treatment and discrimination at work, and • social policy rules, social security coordination 2023 Cases Case Judgement date Key facts/analysis Case C‑148/22, OP v Commune d’Ans 28 November 2023 The Court of Justice ruled on the prohibition on workers wearing any visible sign which might reveal their ideological or philosophical affiliation or political or religious beliefs The Court ruled that Article 2(2)(a) of Council Directive 2000/78/EC establishing a general framework for equal treatment in employment and occupation must be interpreted as meaning that an internal rule of a municipal authority prohibiting, in a general and indiscriminate manner, the members of that authority’s staff from visibly wearing in the workplace any sign revealing, in particular, philosophical

This Practice Note is a horizon scanner tracking key future developments in EU employment and social policy. It provides details of key dates for your diary (including forecasted dates where possible) and relevant commentary in relation to legislation-in-progress, legislation subject to future application dates or transposition deadlines, and new consultations and calls for evidence. This horizon scanner is divided into the following sections: • Legislation in progress • Key upcoming legislative transposition deadlines and dates of application • Consultations and calls for evidence (open initiatives) This horizon scanner does not cover past developments. For details of past developments in EU employment and social policy including case law decided in the current year, see Practice Note: EU employment and social policy—key developments tracker. As a matter of priority, the 2024–2029 Commission is trying to tackle what it deems as overlapping, unnecessary, or disproportionate rules that overburden EU businesses and which may therefore inhibit growth and prevent development. To achieve this, it has set out a plan for various cross-sector omnibus packages of legislation.

This Practice Note tracks key past developments in EU employment and social policy. It provides details of key events and relevant commentary relating to finalised legislation, legislative initiatives which have been abandoned, other key developments, including EU-level strategies and action plans, and case law decided in the current year. This tracker is divided into the following sections: • Legislation published in the Official Journal with a past application date/transposition deadline • Abandoned legislative initiatives • Key non-legislative material • Key EU case law decided in the current year This tracker does not cover emerging or expected future developments, such as legislation-in-progress or open consultations. For details of future developments in EU employment and social policy, see Practice Note: EU employment and social policy—horizon scanner. For past EU judgments, see Practice Notes: EU employment and social policy tracker—cases tracker (2024–2025) [Archived] and EU employment and social policy—cases tracker (2021–2023) [Archived]. Legislation published in the Official Journal with a past application date/transposition deadline What’s happening? When? What’s the impact? Find out more Directive

This Practice Note sets out a summary of key employment-related EU legislation, covering employment and social policy, labour law (including the protection of specific categories of worker), working conditions, protection against discrimination, equal treatment and work-life balance. The status of EU law in the UK Before the UK ceased to be an EU Member State on exit day (31 January 2020), EU law took effect in the UK through ECA 1972. This was repealed by the European Union (Withdrawal) Act 2018 (EU(W)A 2018) on exit day, but subject to savings introduced by the European Union (Withdrawal Agreement) Act 2020 (EU(WA)A 2020), in order to give effect to the implementation period. Broadly speaking, for the purpose of legal continuity, EU(W)A 2018 (as amended) aimed to preserve the legal position immediately before 11pm on 31 December 2020 (a moment defined in EU(WA)A 2020 and referred to in UK legislation as ‘IP completion day’). It did so by taking a ‘snapshot’ of EU-derived laws applicable in the UK at that point and preserving them within the UK’s domestic legal framework

The EU has long been committed to ensuring fairness and equality in the workplace. Over the years, significant strides have been made to tackle the persistent issue of equal treatment and gender pay disparity, which remains a key area of concern. In this regard, Directive (EU) 2023/970, the EU Pay Transparency Directive or EU PTD is a critical piece of legislation that aims to reduce the gender pay gap, enhance transparency in pay structures and provide effective remedies for discrimination. This Practice Note explores the EU legislative framework on equal treatment and equal pay, focusing on the evolution of the key measures introduced since the late 1970s, the changes brought about by the EU Pay Transparency Directive and its implications for both businesses and employees. Principles of equality in the EU Treaties The principle of equality is a cornerstone of the EU legal framework and societal values, firmly established in the EU Treaties. Specifically, Articles 2 and 3(3) of the Treaty on European Union (TEU) identify