On 1 October 2022 the new gas balancing model and Energinets new backend IT-system was commenced. During the first period after commencement, the market participants have experienced difficulties in balancing their portfolios, mainly due to IT flaws and data issues caused by the new IT-system. Energinet acknowledge that this has been the case.

Since the beginning of January 2023, many of the challenges with IT and data have been solved, which has entailed a more stable operation and thereby a more stable basis for balancing.

Following the challenges in the first period, Energinet has investigated the legal basis for invoicing imbalance charges based on General Terms & Conditions for Gas Transport. Based on this investigation, two main principles apply:

• Energinet are not entitled to collect imbalance charges for shippers in situations where the imbalances are caused by significant mistakes made by Energinet, or from data errors from Energinets subcontractors.
• Energinet must collect imbalance charges where imbalances are not caused by Energinet, or from data errors from Energinets subcontractors.

In practice, the principles will be performed in the following way:

• Energinet will investigate all gas days where there has been traded in the yellow zone between 1 October 2022 and until 8 January 2023.
• The neutralization will only apply for shippers delivering gas towards the Joint Exit Zone.
• For all gas days where Energinet determines that imbalances were caused by mistakes from Energinet and/or from data errors, all imbalance charges (both yellow zone and end-of-day prices) for the current gas day will be neutralized via the EEX ETF EGSI price.
• In special cases where the EGSI price is less attractive for the shipper, the original balancing price will apply.
• 8 January 2023 is chosen as cut-off date when the last major IT-challenge (matching) was solved. However, if Energinet identifies gas days with similar challenges after this cut-off date, these will also be considered, in terms of neutralization.
• The No Punishment Principle (NPP) will generally apply both during and after the determined period, to indemnify balancing costs incurred by missing and/or faulty data.

By applying these principles, most of the relevant gas days, and thereby also most of the balancing costs, will be neutralized during the determined period.

Comment on the principles

Market participants are welcome to send in written comments to the neutralization principles by 12 May 2023 to gasinfo@energinet.dk.