The current situation
On 2 March 2026, Energinet announced a national pause on new grid connections. The pause was introduced due to excess demand for grid connections that does not match the available capacity (in total, approximately 60 GW of new consumption is queued across the transmission and distribution grids).
The temporary pause on grid connections has now been lifted as of 3 June 2026, and Energinet is transitioning to a new case processing model that imposes stricter requirements on electricity customers.
Energinet (amongst others) also expects the new government to take a political position on the prioritisation of grid customers through emergency legislation. In the new coalition agreement (“regeringsgrundlaget“) published on 2 June 2026, the energy sector is specifically highlighted, with the newly formed government stating, among other things, that energy infrastructure is to be prioritised and that an emergency plan for Energinet will be implemented.
Furthermore, the Danish Utility Regulator (“Forsyningstilsynet“) announced today, 8 June 2026, that it has initiated a supervisory review of the new prioritisation model. The review will examine whether Energinet may apply the new prioritisation criteria and maturity requirements without prior approval from the Danish Utility Regulator under the Danish Electricity Supply Act. Read the article here (in Danish).
What happens now that the pause has ended?
Before the pause, larger projects were to a greater extent handled on a rolling and individual basis. Going forward, the connection queue will not simply be restarted – it will be reviewed and processed according to the new principles developed during the pause.
Energinet will gather case processing in batches, enabling projects to be assessed in context with one another, with the capacity available in the transmission network, and with the load across the transmission and distribution networks.
The first batch under the new practice is expected to be completed in Q4 2026. This means that no new decisions on grid connection agreements for larger customers in the transmission network will be made under the new practice before then.
Energinet has also indicated that for many new customers, there will in many cases be a need for additional transmission grid expansion before they can be connected with full network access. This includes new connections, substations, and other facilities which require planning, regulatory processing, procurement, and construction, with an expected time horizon in several cases being 5-10 years.
Remaining questions concerning Energinet’s new model for processing grid connections
Energinet has introduced a set of stricter, phase-divided maturity requirements and has adjusted the model for prioritisation in case processing. The new model can be found on Energinet’s website (in Danish).
Although Energinet’s recent announcements have provided some clarity regarding the situation and the case processing in the coming months, outstanding questions remain, leaving potential project owners in an uncertain legal position. The uncertainties relate i.a. to:
- What deadlines and timelines apply to the first batch of grid connection requests to be processed this year?
- How concepts such as “larger connections”, “organic growth”, and “grid-friendliness” are defined;
- How and whether Energinet will ensure that projects do not become “stuck” in the prioritisation queue as new projects are added;
- How the referenced need for new construction legislation (“anlægslove“) will ensure faster progress in grid expansion; and
- When the supplementary information regarding the new model will be published, and whether this will have any impact on projects.
What does this mean for your ongoing grid connection case?
On 10 December 2025, the European Commission issued guidance on grid connections as part of its Grids Package, recommending that capacity constraints be managed through transparent, criteria-based prioritisation rather than a purely “first come, first served” model. Energinet has stated that its new model is consistent with these recommendations.
On 27 February 2026, days before the pause was announced, the Danish Energy Agency published an internal note assessing the legal basis for a temporary pause. The Agency concluded that a pause may fall within the framework of the Electricity Market Directive, but only if it is objectively justified by demonstrable and current capacity constraints, clearly limited in time, and does not amount to a general or permanent restriction of access to grid connection.
Whether these conditions are satisfied, and whether the transition to the new model, with no new grid connection agreements being signed until at least Q4 2026, remains within those limits, is an open question. As the situation develops, it cannot be ruled out that what was introduced as a temporary pause may, at some point, no longer be regarded as compliant with applicable law.
Project owners affected can therefore consider assessing whether Energinet’s conduct potentially gives rise to claims under their specific contractual arrangements, pre-contractual arrangements or -dispositions or under EU law.
What can project owners do?
Given the new framework, project owners are advised to consider the following steps:
- Review your maturity status: Ensure your project documentation is up to date and corresponds to the relevant gate;
- Prepare planning documentation: Initiating early dialogue with your local municipality in order to acquire the necessary planning documentation;
- Notify Energinet of improvements: As a project owner, your project can move up or down in priority groups if there are project-specific improvements in relation to the criteria;
- Explore flexible connection solutions: such as the use of limited grid connection agreements or behind-the-meter solutions, in order to gain a better position within the new prioritisation model;
- Contact Energinet or the relevant DSO: and stay informed of any developments and coming deadlines; and
- Consider your legal position: based on your existing contractual arrangements with Energinet or the relevant DSO.
Navigating regulatory uncertainty
The new prioritisation model and the anticipated emergency legislation raise a number of unresolved questions, creating an uncertain landscape for all stakeholders.
We are closely monitoring these developments, and our dedicated team of advisors stand ready to provide guidance on all aspects of energy and infrastructure project development. Please do not hesitate to get in touch.