How can a VPP or battery aggregator become its own BRP in Europe?
Short answer: Under Regulation (EU) 2019/943, article 5, all market participants are responsible for the imbalances they cause and either are balance responsible parties or delegate that responsibility to a BRP of their choice. Becoming your own BRP is a national process: each TSO's terms and conditions for BRPs, set up under the electricity balancing guideline, define the requirements, the financial responsibility and the settlement. For an aggregator that means an agreement with each TSO you operate under, collateral, a connection to that TSO's data exchange and a daily operation. The Netherlands, Germany and Sweden each do it differently.
What EU law says
- Balance responsibility is universal. Regulation 2019/943, article 5(1): all market participants shall be responsible for the imbalances they cause in the system; to that end, they shall either be balance responsible parties or contractually delegate their responsibility to a balance responsible party of their choice. Each BRP shall be financially responsible for its imbalances and shall strive to be balanced or help the electricity system to be balanced.
- The settlement period is 15 minutes. Article 8(4): by 1 January 2021 the imbalance settlement period is 15 minutes in all scheduling areas, unless a regulatory authority granted a derogation or an exemption; derogations could run only until 31 December 2024. An aggregator's position is settled per quarter hour.
- The detail is national. The electricity balancing guideline (Regulation 2017/2195), article 17(1): in real time, each BRP shall strive to be balanced or help the power system to be balanced; the detailed requirements are in the terms and conditions related to balancing under article 18. Article 18(6) says what those terms must contain for BRPs: the definition of balance responsibility for each connection, without gaps or overlaps between market participants serving that connection; the requirements for becoming a BRP; and the requirement that every BRP is financially responsible for its imbalances and that they are settled.
- Aggregation is recognised. Article 18(5) of the guideline requires the terms for balancing service providers to contain the rules for aggregating demand facilities, energy storage facilities and power generating facilities to become a BSP. Directive 2019/944, article 17, obliges Member States to allow market participation through aggregation.
BRP and BSP are two roles
As a VPP you may sell flexibility to the TSO as a balancing service provider (BSP) and carry the imbalance of your portfolio as a BRP. The guideline keeps the roles apart: a BSP qualifies with the TSO (article 16); a BRP signs the balancing terms (articles 17 and 18). Many aggregators start as a BSP under another company's BRP and take on balance responsibility later, when the portfolio is large enough to carry collateral and a daily operation.
What becoming your own BRP takes, in every country
- A legal entity the TSO contracts with, and in some countries a national registration.
- The TSO's BRP agreement, and where the codes require it, a recognition and an entry in a register.
- Financial security, sized from your expected imbalance.
- Identifiers for the data exchange: EIC, GLN or national codes.
- A connection to the TSO's data exchange for nominations, metering or allocation data and settlement.
- A daily operation, seven days a week.
Three countries
Netherlands | Germany | Sweden | |
|---|---|---|---|
| Who you contract with | TenneT: recognition and the BRP register (Systeemcode elektriciteit 2026) | One of four TSOs per control area: a Bilanzkreisvertrag with each | Svenska kraftnät for the balance agreement, eSett for imbalance settlement |
| Nomination | Energy programme before 14:30 for the next day | Schedules (Fahrpläne) per quarter hour to each TSO | Bilateral trades to eSett, gate 45 minutes before the period |
| Settlement | Daily imbalance overviews, weekly invoice, reconciliation in month M+5 | Monthly balancing group settlement under MaBiS, with Ausgleichsenergie per quarter hour | Preliminary settlement daily, final after the metering updates, weekly invoice |
| Data exchange | XML over TenneT's MMC-hub | EDIFACT over AS4, with format versions each April and October | Ediel and ECP/EDX with Svenska kraftnät, eSett's channels for settlement |
| Guide | Become a BRP in the Netherlands | Bilanzkreisverantwortlicher werden (German) | Become a BRP in Sweden |
Own BRP or BRP as a service?
Your own BRP gives you the trading and the portfolio decisions, and it costs collateral, a connection to each TSO and people on duty every day. A BRP as a service puts your portfolio into another company's balancing group, in Germany often as a sub-balancing group, and you keep trading within its rules. The service route is faster, and many aggregators use it as a step until the portfolio carries a BRP of its own. The German trade-off is set out in Bilanzkreisverantwortlicher werden (in German); in the Netherlands, an IT carrier takes the data exchange off your plate while you stay the BRP, see what an IT carrier is.
How Engrate does it
Engrate is the platform under a BRP: nominations, market communication and settlement data per country through one API, for your own balancing group or in a service model. It is live in Germany and the Netherlands and built in Stockholm. More on the product: Energy Market Communication.
Sources
- Regulation (EU) 2019/943 on the internal market for electricity, articles 5 and 8
- Regulation (EU) 2017/2195 establishing a guideline on electricity balancing, articles 16 to 18
- Directive (EU) 2019/944 on common rules for the internal market for electricity, article 17
- ENTSO-E, Requirements for BSPs and BRPs across Europe