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Response to ENTSO-E consultation on collateral solution for long-term flow-based LTTR auctions

10 April 2026

KEY MESSAGES

  • Eurelectric welcomes ENTSO-E’s consultation on a new solution to collateral management under flow-based LTTR auctions. We have long highlighted the risk of spiralling collateral needs in the context of simultaneous LTTR auctions.
  • The go-live date of a lasting solution to the unsustainable collateral burden under long-term flow-based auctions is of the highest importance to market participants. We regret that the current draft allows for implementation not before 2027 and up to 2028 .
  • The interim solution under implementation for the November 2026 flow-based auction strongly overestimates the collateral that market participants need to post, reducing auction surplus through the unnecessary filtering of bids.
  • We welcome ENTSO-E’s proposal for an enhanced bid filtering approach, which strongly reduces the magnitude of filtered bids by integrating the credit limit verification step in the auction result determination.

The possibility for market participants to prioritise bids on certain borders during flow-based auctions should be considered

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