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How Europe Does Private Wires

Ten EU member states plus Britain run some working version of private wires or shared local networks. Ireland has authorised none in twenty-seven years.

The short version

Across Europe the wire itself is the easy part. Countries regulate the network and the supply relationship, in proportion to who is being served. Ireland is the only mature market that has never let the wire be built at all. On a 30-state Direct Line Openness Index compiled by ZETA, 29 states score between 6 and 12 out of 12. Ireland scores 0.

This page summarises research by ZETA (Zero Emissions Traders Alliance): the Reference Paper v1.1 (September 2026), the Research Paper (draft, August 2026) and the Europe briefing note (August 2026). The papers are available on our Downloads page.

The EU baseline every country shares

Since 2003, three successive electricity directives have required member states to enable direct lines (private wires) on objective, non-discriminatory criteria. This is now Article 7 of Directive (EU) 2019/944. The same Directive offers a closed distribution system category for industrial parks and campuses (Article 38). The renewables directive adds self-consumers and energy communities with the right to share energy (RED II, Articles 21 and 22), and the 2024 market reform added a right for households and SMEs to share self-generated electricity (Article 15a), due in national law by 17 July 2026.

Direct lines

A cable from a generator straight to a user, without passing through the public grid. Article 7.

Closed distribution systems

Industrial parks, ports and campuses run their own internal network under light regulation. Article 38.

Energy sharing

Neighbours and community members allocate self-generated power between them. RED II Arts. 21–22; Art. 15a.

The scoreboard

CountryHow a direct line gets builtDifficultySignature example
GermanyNo energy-law permit needed; ordinary planning and property law. Industrial parks run closed networks (§ 110 EnWG)EasiestRhine chemical parks; Mieterstrom
NetherlandsNotify the regulator (ACM), go on a public register, operate it yourselfA formChemelot; cable pooling
Belgium (Flanders)Notify on your own site; regulator (VREG) only if you cross a public roadNotify / permitKristal Solar Park to Nyrstar smelter
Great BritainLicensed independent network companies, charges capped at incumbent parityLicensed competition~3m connections; OFTO regime
FranceCollective self-consumption within a ~2 km perimeter, settled by smart meterRegister a schemeThousands of operations
Spain / PortugalDirect lines in statute; collective self-consumption with allocation keysStatutoryNational-scale neighbourhood solar
AustriaEnergy communities with reduced grid tariffs for local sharingCommunity routeDiscount for local sharing
ItalyLegacy closed systems plus a premium tariff for shared energy (2024)RewardedState pays you to share locally
SwedenInternal networks exempt from concession by category (IKN)List-based exemptionPorts, industrial sites, housing blocks
DenmarkRegulatory sandbox for an industrial park with its own internal gridSandboxedGreenLab Skive
IrelandOnly after ESB Networks refuses a grid connection; connections are queued, never refusedEffectively bannedZero authorisations since 1999; Cloughjordan waiting since 2016

The pattern is consistent: notify or register, build, and be regulated in proportion to size. Ireland is the exception because of a single statutory feature, the refusal precondition in Section 37 of the Electricity Regulation Act 1999.

Country by country

Easiest

Germany: Layered: three routes

No energy-law permit for a direct line; ordinary planning and property law only. Wiring inside a building or campus is exempt from network regulation if any supplier may serve any tenant. Industrial parks run closed distribution systems under § 110 EnWG.

Signature example: Rhine chemical parks (Leverkusen, Marl, Höchst); Mieterstrom rooftop solar for tenants.

In C-293/23 (Nov 2024) the EU Court of Justice held that Germany's building-wiring exemption had grown too broad. The lesson: use the categories the EU Directive already provides.

A form

Netherlands: Notify, register, operate

Notify the regulator (ACM), go on a public register and run the line yourself (Energiewet, in force 1 Jan 2026). Closed systems need recognition, must connect anyone where capacity exists and publish cost-based tariffs.

Signature example: Chemelot chemical campus; wind and solar "cable pooling" on one connection; "energy hubs".

Faced with severe grid congestion, the Netherlands did not tighten the rules: it promoted private and shared wires as the cure. What Ireland prohibits, the Netherlands prescribes.

Notify / permit

Belgium (Flanders): Notify on your own site

Own-site direct lines on notification; the regulator (VREG) authorises only where a public road is crossed, against published criteria. The practical issues are civil-law ones: easements, a small levy, decommissioning. Wallonia and Brussels authorise lines leaving the site.

Signature example: Kristal Solar Park: 99 MWp, 303,000 panels, built in under nine months and wired straight into the Nyrstar zinc smelter at Lommel.

City, region, smelter and developer agreed it, the regulator authorised it, and heavy industry got clean power it could plan on.

Licensed competition

Great Britain: Independent network licences

Licensed independent networks (IGTs for gas, IDNOs for electricity) build and own last-mile networks on new housing estates. Their charges are capped at the incumbent's level, and supplier switching is preserved.

Signature example: Around 3 million connections; about 80% of new housing gas networks. At transmission scale, the OFTO regime: 24 offshore assets, over £6bn, 9.5 GW.

The early problem was real: households on private networks paid more. One licence rule fixed it: a private network may never charge a household more than the big network would.

Register a scheme

France: Collective self-consumption

Neighbours share solar within a local perimeter of about 2 km (wider in rural areas), with allocation settled through smart meters. Direct lines are authorised and closed distribution networks exist.

Signature example: Thousands of collective self-consumption operations.

None of it needed exotic technology. Ireland has near-complete smart metering already; the feature has not been switched on.

Statutory

Spain and Portugal: Direct lines and shared self-consumption

Spain wrote direct lines into its electricity act (Ley 24/2013, art. 42) and runs collective self-consumption with regulated allocation keys. Portugal has collective self-consumption units (UPAC; DL 15/2022).

Signature example: Neighbourhood solar sharing at national scale.

Sharing is run through regulated allocation keys, not bespoke deals.

Rewarded

Austria and Italy: Discounts and premiums for local sharing

Austria gives energy communities reduced grid tariffs for local sharing (EAG 2021), because power moving a few hundred metres uses less network. In 2024 Italy added a premium tariff for energy shared in communities, on top of its legacy closed systems.

Signature example: Austria: community sharing discounts. Italy: the State pays a premium for locally shared renewable energy.

Ireland is debating whether to allow what Italy pays people to do.

Exempt / sandboxed

Sweden and Denmark: Lists and sandboxes

Sweden exempts listed categories of internal network from the concession requirement (IKN rules): ports, industrial sites, housing blocks. Denmark put a whole industrial park into a regulatory sandbox to trade energy over its own internal grid.

Signature example: Sweden: ports and housing blocks. Denmark: GreenLab Skive.

Quietly sensible: boring, working, uncontroversial.

Ireland: the outlier

Effectively banned

Section 37 of the 1999 Act lets the regulator (CRU) permit a direct line only after the applicant has applied for a public connection and been refused for lack of capacity (or won a dispute with a public-interest finding). ESB Networks never refuses: it queues. So the door has never opened. As far as anyone has been able to establish, no direct line has been authorised since 1999.

The three 5 MW community solar farms beside Cloughjordan ecovillage have been waiting for a connection since 2016, a few hundred metres from the village they were designed to power. In Flanders that is a notification; in the Netherlands a registration.

The asymmetry: in January 2025 the 504 MW Greenlink interconnector entered service, privately conceived, privately financed and licensed by the CRU under the same Act. The State has accepted privately owned electricity infrastructure at 500 MW, yet prohibits the same act at one-hundredth the size.

Poland once had Ireland's rule: a direct line only where grid connection was impossible. It repealed it in September 2023 and replaced it with notification, a public register, a light tier below 2 MW and a "solidarity fee" for users who keep a grid connection. Finland removed its 2 MVA cap on separate lines in 2025, and the Netherlands consolidated its regime in 2026. Every recent move in Europe is toward openness.

Five lessons from Europe

1. The wire is easy; the relationship is regulated

Every mature regime attaches obligations to networks (openness, cost-based access) and to supply relationships (household protections), not to the cable.

2. Price the boundary

Britain's parity price cap, Dutch cost-based closed-system tariffs and Austrian discounts for avoided network use mean the distributional problem is managed by design.

3. Openness is the trade for lightness

Germany's rule: any supplier may serve any customer inside a private system. That one line answers the "captive tenant" objection.

4. Use the EU's own categories

Direct lines (Art. 7) and closed systems (Art. 38) are court-tested. C-293/23 punished Germany for exemptions beyond the Directive; Ireland's error is the mirror image: restricting a right the Directive grants.

5. Congestion is the reason, not the excuse

The Netherlands, with some of Europe's worst grid congestion, chose private and shared wires as the remedy. Ireland, with a queue and curtailment, chose prohibition.

Direct Line Openness Index: 30 states

ZETA's first-cut index scores 30 European states out of 12 on six criteria (each scored 0 to 2): consent regime, absence of a grid-refusal precondition, tiering by scale, Article 38 closed systems, an operating energy-sharing framework, and a public register. The index is a published draft; the scoring rubric is public and "Low" confidence rows rest on secondary sources only.

Show or hide all 30 scores
Netherlands12High
Belgium (Flanders)11High
Finland11Medium
Poland11Medium
France10Medium
Germany10High
Great Britain10High
Italy10Medium
Sweden10Medium
Austria9Medium
Croatia9Low
Czechia9Medium-low
Estonia9Low
Greece9Low-medium
Hungary9Medium
Lithuania9Low
Luxembourg9Low
Portugal9Medium
Slovenia9Low
Spain9Medium
Cyprus8Low
Norway (EEA)8Medium
Romania8Low-medium
Slovakia8Low-medium
Switzerland8Medium
Bulgaria7Low
Denmark7Low-medium
Latvia7Low
Malta6Low
Ireland0High

Source: ZETA, Reference Paper v1.1, Appendix C (September 2026). Belgium is scored on the Flemish regime. Switzerland scores 8 of the 10 applicable points (Article 38 does not apply to non-EU states).

Take action before 17 December 2026

Second Stage of the Heneghan Bill will be taken on Thursday, 17 December 2026 in the evening Private Members' Business slot. Tell your TD that Ireland should join the rest of Europe.

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Figures are taken from the ZETA documents named above and are the authors' analysis, not official statistics. Where a national regulator's own description of its regime differs from ZETA's index coding, the regulator's description should be preferred.