电池储能系统（BESS）的未来 | 英国与欧洲

September 2025 Introduction As electrification accelerates andrenewable generation grows acrossEurope, power grids are facing mountingcongestion challenges. This is particularlyacute in leading markets where connectioncapacity for new projects - includingbattery energy storage systems(“BESS”)- may be limited as a direct consequenceof these bottlenecks. Despite thesechallenges, BESS technology is widelyrecognised as a crucial enabler for gridflexibility, improved system stability, andthe continued expansion of intermittentrenewables. European regulatory framework:progress and remaining hurdles The European Union has taken significant stepsto integrate energy storage into its electricitymarket framework through the Clean EnergyPackage, marked by the recastElectricityMarket Directive(“EMD”) and the recastElectricity Market Regulation(“EMR”). Underthese instruments,battery energy storagesystems(“BESS”) is explicitly defined andrecognised for its role in shifting electricity useand providing a suite of services (includingancillary and balancing). The EMD requirestransmission system operators to enable non-discriminatory access for storage in ancillaryservice markets and sets limits on grounds forrefusing grid connections. Similarly, the EMRmandates non-discriminatory treatment ofstorage in market and capacity mechanisms,while also prohibiting unjustified discriminationin network charges. In recent years, Europe has experiencedsubstantial growth in the deployment of BESS,setting new annual installation records despitea moderate slowdown in market expansion in2024. To maximise the benefits of BESS, moreEuropean countries will need to implementsupportive policy frameworks and investmentconditions. Jurisdictions already leading inBESS deployment should also intensify theirefforts to address ongoing challenges, includinglimited grid connection capacity, complexpermitting processes and double grid charges. Nevertheless, challenges remain: the EMR’snon-discrimination principle does not entirelyprevent the application of double grid tariffs(charging for both offtake and injection), whichcan materially affect project economics. TheEuropean UnionAgency for the Cooperationof Energy Regulators(“ACER”) has clarifiedthat paying charges for both directions isnot necessarily unjustified, yet double tariffspersist as a notable barrier for BESS acrossjurisdictions. Introduction Key trends and focus of this contribution Across Europe, regulatory practice, the availability of dedicated authorisation pathways, and the structure of revenue streams for BESS projectsdiffer markedly from country to country. While broad European rules provide important guarantees for fair market access and service participation,the remaining hurdles - such as connection constraints, non-refunded curtailment, and varying approaches to grid fee exemptions - often requirenational solutions. In this contribution, we examine key regulatory aspects and trends impacting BESS development across jurisdictions.We focus on: >key regulatory aspects, including the nature of permitting and special authorisation regimes;>typical revenue streams for BESS projects, including market and policy-based income;>common obstacles such as grid access restrictions, double tariffs, and market saturation risks;>the design and impact of government support schemes and available subsidies; and>bankability considerations that are vital for investment. By mapping these key issues, we highlight how BESS can help address Europe’s grid congestion and energy transition challenges, as wellas where regulatory and market developments must progress to unlock the full value of energy storage for a modern, electrified Europeanenergy system. Belgium Belgium Regulations (Technisch Reglement), whichpartly implement relevant EU network codes.These instruments set out the proceduresand obligations for connecting installations tothe transmission grid and organising ancillaryservices (such as balancing services). Moreover,BESS operators must either themselves act asbalancing responsible party(“BRP”) for theirconnections or appoint a third party to do so. Many BESS operators partner with third-partyproviders specialising in BESS optimisationor market access to support commercialoperations. In these arrangements, revenue isshared in line with contractually agreed terms. in an increase in capacity of more than 10 percent or more than 25 MW are also subject to thispermit requirement. Key regulatory aspects Under the Belgian Federal Electricity Act(Elektriciteitswet), a BESS qualifies as an‘energy storage facility’ which is defined as an“installation for ‘energy storage’ where electricityis taken from the grid through the sameinstallation to be fully injected back into the gridlater, subject to efficiency losses”. In addition,‘energy storage’ refers to “deferring the final useof electricity to a later point in time than when itwas generated, or converting electrical energyinto a storable f