Executive Summary

Eurelectric supports the objectives of the IAA

Our members are both upstream and downstream of the proposed Industrial Accelerator Act (IAA) rules, procuring end-products from and supplying increasingly decarbonised electricity to European industry. We support Open Strategic Autonomy as the right balance between resilience and openness.[1] Strengthening trade partnerships with reliable actors is key to securing strategic supply chains. Eurelectric calls on co-legislators to:

• maintain the IAA proposal’s targeted approach to diversify supply chains and develop competitive European industry
• clarify the scope and practical application in primary legislation to mitigate disproportionate cost increases or additional administrative burdens

Prioritise NZIA implementation before expanding scope

The proposal significantly expands rules from the Net-Zero Industry Act (NZIA) which is not yet fully implemented at Member State level. The IAA has to prioritise implementation of the NZIA instead of further evolution of criteria to ensure regulatory certainty and to avoid delays to new projects. Eurelectric calls on co-legislators to:

• restore NZIA thresholds for auctions and for cost-based exemptions
• clarify how the new opt-out provision applies for project delivery delays
• extend “no suitable tenders” opt-out to 5 years in public procurement
• maintain robust cybersecurity rules and ensure consistent implementation with the ongoing Cybersecurity Act (CSA) II revision

Keep Union origin requirements targeted and clarify scope

Eurelectric views the targeted scope of the technologies covered positively, potentially delivering added value for reducing dependencies and countering unfair trade practices by focusing on phased implementation of demand-side requirements. We welcome that countries with which the EU has strong international agreements based on reciprocity are included in the scope.

However, the IAA proposal still requires urgent clarification onthe exact scope of countries eligible for Union-origin equivalence, the application of exemptions from applying non-price criteria, definitions and processes for implementation.

Eurelectric calls for these pending clarifications to be enshrined within primary legislation to ensure an effective IAA and provide sufficient visibility for market participants to adapt their procurement processes in due time. Eurelectric calls on co-legislators to:

• maintain third-country eligibility based on reciprocityand provide a stable list
• introduce a co-decision procedure for ad hoc country exclusion
• ensure a level playing field between public and private utilitiesin power generation
• keep the targeted scope of products and more strongly align product requirements with market realities

Prioritise regulatory certainty in FDI and permitting rules

Eurelectric supports the objectives of foreign direct investment (FDI) screening rules to retain added value in the EU. The proposal requires clarification to ensure that IAA FDI rules complement the existing FDI screening framework and that its criteria are clear and implementable.

Eurelectric views the proposed measures for accelerated permitting positively. The provisions should avoid overlaps with the Industrial Manufacturing Acceleration Areas (IMAAs) in the same text, as well as with permitting simplification in other legislation, such as the Permitting Directive, to ensure regulatory consistency.

Industrial Manufacturing Acceleration Areas should support increased industrial electrification

The Industrial Manufacturing Acceleration Areas (IMAAs) are a welcome concept to support the designation of system friendly zones where industrial electrification projects receive faster grid connection, simplified permitting and coordinated planning to speed up deployment. Co-legislators should design these zones to support direct electrification where cost-effective by[2]:

• expanding the scope to include all industry
• introducing and ensuring compatibility of IMAAs with the concept of “Electrification Acceleration Areas” for increased electrification: reliably plannable locations for new loads based on readily available grid capacity

Include dedicated funding to scale up manufacturing and electrify industry

The IAA proposes new regulatory obligations without financial commitments to reach its objectives. Diversification and local-content rules will increase product prices and project costs and should be complemented with financial incentives for European manufacturing to scale up and for industry to decarbonise, particularly via electrification.

The IAA’s objectives can be met by institutionalising targeted support for cleantech manufacturing and industrial electrification within instruments like the Innovation Fund Heat Auction, ETS Investment Booster, Industrial Decarbonisation Bank and Competitiveness Fund.

[1] Eurelectric, Open Strategic Autonomy, April 2026.

[2] Eurelectric – Electrification Acceleration Areas, 2026