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
| Country | How a direct line gets built | Difficulty | Signature example |
|---|---|---|---|
| Germany | No energy-law permit needed; ordinary planning and property law. Industrial parks run closed networks (§ 110 EnWG) | Easiest | Rhine chemical parks; Mieterstrom |
| Netherlands | Notify the regulator (ACM), go on a public register, operate it yourself | A form | Chemelot; cable pooling |
| Belgium (Flanders) | Notify on your own site; regulator (VREG) only if you cross a public road | Notify / permit | Kristal Solar Park to Nyrstar smelter |
| Great Britain | Licensed independent network companies, charges capped at incumbent parity | Licensed competition | ~3m connections; OFTO regime |
| France | Collective self-consumption within a ~2 km perimeter, settled by smart meter | Register a scheme | Thousands of operations |
| Spain / Portugal | Direct lines in statute; collective self-consumption with allocation keys | Statutory | National-scale neighbourhood solar |
| Austria | Energy communities with reduced grid tariffs for local sharing | Community route | Discount for local sharing |
| Italy | Legacy closed systems plus a premium tariff for shared energy (2024) | Rewarded | State pays you to share locally |
| Sweden | Internal networks exempt from concession by category (IKN) | List-based exemption | Ports, industrial sites, housing blocks |
| Denmark | Regulatory sandbox for an industrial park with its own internal grid | Sandboxed | GreenLab Skive |
| Ireland | Only after ESB Networks refuses a grid connection; connections are queued, never refused | Effectively banned | Zero 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
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.
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.
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.
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.
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.
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.
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.
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
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
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.
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.