SHERIDAN, WYOMING - April 13, 2026 - The Agency for the Cooperation of Energy Regulators (ACER) has published a compliance assessment of the Danish gas transmission tariff methodology proposed by Energinet, Denmark's transmission system operator, identifying critical gaps in cost transparency around the Baltic Pipe upstream infrastructure and flagging non-conformities in emergency supply tariff classification. The report, directed at Energinet and the Danish national energy regulator (DUR), determines that full compliance with EU Network Code on Harmonised Transmission Tariff Structures (NC TAR) cannot be confirmed without substantially more disclosure on upstream pipeline costs - a finding with direct consequences for how network users and regulators structure tariff decisions across the Danish gas market.
What Energinet proposed
Energinet's reference price methodology (RPM) rests on a uniform postage stamp approach with an ex-post entry-exit split, meaning all users pay a single blended rate regardless of the specific network zones they access. Revenue recovery relies exclusively on capacity-based tariffs: users pay for the network capacity they book, not the volume of gas they physically transport. ACER's assessment notes this design avoids volume risk exposure for the TSO, which satisfies one NC TAR requirement.
The methodology also retains the existing joint market zone, which integrates the upstream section of the Baltic Pipe - the pipeline carrying Norwegian gas to Poland via Denmark - directly into the Danish entry-exit zone. Costs for that upstream segment continue to be recovered from network users through a separate non-transmission tariff rather than a standard transmission charge. Two non-transmission services remain in place: Baltic Pipe upstream infrastructure and emergency gas supply. Energinet additionally proposes to maintain ex-ante discounts for interruptible capacity in five-percent intervals, allowing users to book spare capacity at reduced prices subject to pre-emption by firm-capacity holders.
Where ACER found compliance and where it did not
ACER concludes the proposed methodology satisfies EU requirements on transparency, non-discrimination, and volume risk allocation. However, three areas could not be fully cleared. First, compliance with cost-reflectivity rules and the prohibition on cross-subsidisation cannot be confirmed because Energinet has not provided sufficient detail on the upstream Baltic Pipe infrastructure costs embedded within network user charges. Second, whether the pricing of upstream non-transmission services aligns with NC TAR principles remains unverifiable for the same reason. Third, the proposed emergency supply tariff is structurally misclassified: it funds a security-of-supply service delivered directly to end users, not to network users, and therefore falls outside the NC TAR regulatory framework entirely.
The interruptible capacity discount mechanism also draws scrutiny. ACER finds that the current five-percent step structure does not reflect actual interruption risk with sufficient precision, and recommends applying the network code formula to recalibrate discount levels so they correspond to the real probability of capacity pre-emption under firm-user priority rules.
ACER's recommendations to DUR
ACER directs three specific actions at DUR when it issues its final regulatory decision on Energinet's methodology. DUR must ensure the upstream Baltic Pipe section is subject to the same level of transparency and regulatory scrutiny applied to the core transmission network, given that its costs are passed through to transmission network users. Emergency supply tariffs must be separated from standard network fees and handled under a distinct regulatory framework, since their beneficiaries are end users rather than network users. Finally, DUR must require Energinet to recalculate interruptible capacity discounts using the NC TAR formula rather than the current fixed-interval approach.
These recommendations carry structural weight because the Baltic Pipe - operational since 2022 - represents a strategic corridor for Norwegian gas entering Central and Eastern European markets via Denmark. Its upstream costs, currently socialised across all Danish transmission network users without detailed cost-allocation disclosure, affect tariff levels throughout the Danish entry-exit zone and by extension the competitiveness of gas flows destined for Poland and beyond.
Business impact
Industrial gas users and energy-intensive manufacturers procuring capacity on the Danish transmission network face direct exposure. Until DUR enforces greater upstream cost disclosure, these buyers cannot independently verify whether their non-transmission tariff contributions are proportionate or cross-subsidising infrastructure that serves transit flows rather than domestic consumption. Procurement leads and energy managers at large industrial offtakers should treat current tariff benchmarks as provisional and build regulatory-outcome contingency into 2026 and 2027 gas cost models.
Gas traders, shippers, and capacity brokers operating on the Baltic Pipe corridor must also reassess their interruptible capacity positions. If DUR adopts ACER's recommendation to realign discount steps with the NC TAR interruption-risk formula, the effective cost of interruptible bookings will shift - potentially narrowing the arbitrage between interruptible and firm capacity products. Capacity planning teams at cross-border shippers should model revised discount scenarios before the DUR final decision and adjust booking strategies for the next capacity auction cycle accordingly.