Switching energy suppliers within 24 hours: The European Commission has adopted the regulation implementing the new rules by the end of 2026

The European Commission has adopted new EU rules making it easier for consumers to change supplier and secure better energy offers. This Implementing Regulation – secondary legislation linked to the Electricity Directive (EU/2019/944) – will help ensure that Europe’s energy market works better for consumers by supporting affordable energy and strengthening the ability of consumers to mitigate price increases. As outlined in last month’s Citizens’ Energy Package, it reinforces the EU’s commitment to a consumer-centred energy transition. The new rules will enable the back-office process of switching supplier to be completed within 24 hours by the end of 2026. In practice, this means that once a customer decides to switch, the process behind the scenes, including registering the new supplier, will be completed within one working day.

This will make it easier for consumers to switch to better deals, including pricing options which reward flexibility, or new services like demand response, while also strengthening competition and innovation in retail electricity markets.

The Commission will continue to support EU countries and market participants in implementing the new rules, including through guidance and stakeholder engagement.

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Context and Legal Basis

On April 14, 2026, the European Commission adopted a draft Implementing Regulation (C(2026) 2310) establishing interoperability requirements and non-discriminatory and transparent procedures for access to data necessary for switching electricity suppliers. The Regulation was adopted pursuant to Article 24(2) of Directive (EU) 2019/944 on common rules for the internal market in electricity and supplements the existing Implementing Regulation (EU) 2023/1162, which regulates access to metering and consumption data. The new act is the result of the work of the Joint Working Group on Data Interoperability of ENTSO-E and the EU DSO Entity and has been coordinated with the European Data Protection Supervisor (opinion of June 12, 2025).

The main objective of the regulation is to ensure that, by the end of 2026, the technical process of switching suppliers is completed within 24 hours on any business day—an obligation arising from Article 12(1) of Directive (EU) 2019/944. This timeframe covers the registration of the new supplier in the register of metering points and the notification of affected and entitled parties (procedural steps 1.13–1.19 of the Annex). The Regulation is directly applicable in all Member States and applies from December 31, 2026.

Reference Model for Interoperability

At the core of the Regulation is a technology-neutral “reference model” that standardizes the workflows of the supplier switching process across the EU. The model covers three high-level interoperability layers—business layer, functional layer, and information layer—without prescribing specific technical solutions at the communication and component levels, which remain at the discretion of Member States. The model comprises three key components: (i) a role model, defining the roles and responsibilities of participants and their interactions; (ii) an information model defining information objects, their attributes, and relationships; and (iii) a process model detailing procedural steps.

The reference model deliberately uses definitions and terminology from established standards and European initiatives, including the Harmonized Electricity Market Role Model (HEMRM) of ENTSO-E and the Common Information Model (CIM) of the International Electrotechnical Commission (IEC). This approach ensures terminological consistency and facilitates implementation by market participants.

The Regulation sets out specific obligations for three main categories of participants in the supplier switching process:

New electricity supplier (Art. 5)

The new supplier bears the primary responsibility for initiating and conducting the switching process. It is required to verify the identity of the end customer using authentication solutions, preferably with at least two factors of authentication (including the European Digital Identity Portfolio under Regulation (EU) No. 910/2014); identify the relevant accounting point; ensure a balance responsible party (balancing group coordinator) (balance responsible party) to assume responsibility for the balance of the identified point from the start of supply; obtain authorization from the end customer to perform preparatory activities; submit a registration application to the metering point administrator; obtain metering data for accurate billing; and, if necessary, request cancellation of the current switching process.

Previous supplier (Art. 6)

The previous supplier is required to provide the end customer with a final closure account in accordance with Article 10(12) of Directive (EU) 2019/944 and to obtain metering data to ensure accurate billing after the supply has ended. The Regulation expressly prohibits the current supplier from obstructing or delaying the switching process.

Metering Point Administrator (Article 7)

The Metering Point Administrator (or a delegated entity, where Member States have provided for such a person) performs a central coordinating role. They are required, without undue delay, to provide the new supplier with the characteristics of the relevant metering points in a non-discriminatory manner via an online interface, to process the validated switching request, and to notify the entitled and affected parties of the changes. Furthermore, the administrator must provide a testing facility through which suppliers can verify the compatibility of their systems with the procedures under the Regulation both prior to and during their operation.

Furthermore, the Regulation distinguishes between two categories of market participants affected by the change: “affected parties” (affected parties) — participants who gain or lose responsibility for the metering point as a result of the change (including the current and new supplier, the party responsible for balancing, the metered data administrator, and the network access provider/network operator); and “entitled parties” – participants who must be informed of the changes (including metered data aggregators, flexibility service providers, guarantees of origin registries, and control area managers).

Supplier Switching and Cancellation Procedures

The Annex to the Regulation contains two main procedures describing the standard data exchange workflow (happy flow):

Procedure 1. Supplier Switching

The supplier switching procedure (Table III.1 of the Annex) is structured into 22 procedural steps (1.1–1.22), covering the entire cycle from the initial contact between the end customer and the new supplier to the receipt of metering data for accurate billing. The steps include: contact and initiation of the process (steps 1.1a/1.1b); optional check for contractual restrictions with the current supplier (steps 1.2–1.5); optional preliminary inquiry regarding the characteristics of the metering point (steps 1.6–1.10); invitation to conclude and conclusion of a new contract (steps 1.11–1.12); technical switchover—submission of a request, validation, registration in the metering point registry, and notification of affected and entitled parties (steps 1.13–1.19); and requesting and receiving metering data (steps 1.20–1.22).

The technical switchover (steps 1.13–1.19) must be completed within 24 hours.

Procedure 2. Cancellation of a supplier switch

The cancellation procedure (Table III.2) comprises 12 steps (2.1–2.12) and allows the end customer to withdraw the request to switch, provided that supply under the new contract has not yet commenced and the cancellation falls within the withdrawal period under national and European consumer law, including Directive 2011/83/EU. If delivery under the new contract has already begun, the customer must initiate a new supplier switching procedure, as the cancellation procedure is no longer applicable.

Information objects and data exchange

Table IV of the Annex defines 15 information objects (IDs A through O) exchanged within the two procedures. Key information objects include: accounting point ID; end-customer identification data; requested start date of supply; new supplier ID and the balancing responsible party; validation result; accounting point characteristics; change notifications to affected and entitled parties; and cancellation requests and notifications. The Regulation does not specify specific code values for the attributes, as these are detailed in the relevant business standardization documentation. Metering data is exchanged in accordance with the procedures of the already in-force Regulation (EU) 2023/1162.

Description of the procedure for switching suppliers

The procedure for switching electricity suppliers proceeds in the following sequence: the end customer initiates contact with a potential new supplier (or the supplier makes an offer), after which the new supplier verifies the customer’s identity using at least two authentication factors, identifies the relevant metering point, and obtains authorization for preparatory activities; if necessary, the new supplier checks for contractual restrictions with the current supplier and, if applicable, requests the metering point administrator for the characteristics of the metering point; after a supply contract is concluded between the customer and the new supplier, the latter submits a registration request to the metering point administrator, who validates the request, registers the new supplier (along with the balancing responsible party) in the metering point register for the specified date, and notifies all affected and entitled parties. This technical switching process must be completed within 24 hours, after which the current and new suppliers report meter readings to the meter data administrator to ensure accurate billing.

Risks and Implementation Challenges

From the perspective of energy suppliers, the main risk is associated with the extremely short deadlines for technical switching (24 hours), which require full automation of internal processes and investments in IT systems capable of processing requests in real time. For smaller suppliers, especially in markets like Bulgaria’s, this can represent a significant financial and organizational burden. The requirement for two-factor customer authentication, while justified by security concerns, introduces additional complexity, especially in countries where the European Digital Identity Portfolio is not yet widely adopted. Another risk is the scenario of mass simultaneous switching (collective switching), in which the systems of suppliers and metering point administrators could become overloaded.

For traditional providers with a large number of customers (incumbents), there is also a risk of abuse of the process—for example, by repeatedly initiating switching procedures without any real intention of entering into a contract, which would create an administrative burden and hinder normal operations. The cancellation procedure, while necessary to protect the consumer’s right of withdrawal, further complicates suppliers’ operational planning, as customers have the option to withdraw their application right up until the actual start of supply.

For electricity distribution companies (in their role as metering point administrators), the main challenges are ensuring 24-hour readiness to process requests, establishing and maintaining a test environment for suppliers, and guaranteeing grid stability amid frequent supplier changes. An additional problem is the fact that the regulation describes only the “ideal scenario” (happy flow)—the standard flow without errors or deviations. The handling of invalid requests, data inconsistencies, and errors in communication between systems remains largely unregulated and depends on national decisions, which may lead to varying service quality standards across Member States.

National Implementation and Technical Requirements

As an implementing regulation, the act is directly applicable in all Member States and does not require transposition into national law. However, its implementation requires significant national preparation. Each Member State must designate a competent authority or other entity responsible for reporting on national practices regarding the implementation of the reference model (Art. 9). This authority must prepare and maintain an up-to-date detailed mapping of national practices, including a description of how the procedural steps in the Annex are applied at the national level, including any consolidation of steps and the sequence of their implementation.

Reports on national practices must be submitted to ENTSO-E and the EU DSO Entity by July 1, 2027, and published in a publicly accessible repository that expands the existing repository under Regulation (EU) 2023/1162. ENTSO-E and the EU DSO Entity must develop and publish reporting guidelines by July 1, 2026 (Article 11). These organizations act in a purely technical and advisory capacity—they have no executive or enforcement powers, nor are they responsible for validating national reports.

The technical requirements for national implementation include:

building or upgrading online interfaces for accessing data on reporting points;
providing a test environment for suppliers;
implementing two-factor authentication solutions for customers;
integration of data exchange with existing procedures under Regulation (EU) 2023/1162.

Member States retain flexibility regarding the communication and component levels of interoperability, but must document their national decisions in a uniform format accessible to all market participants. In the context of the Bulgarian market, a key challenge is the coordination of roles—in particular, the possibility of delegating the responsibilities of the metering point administrator to an entity other than the one designated under Regulation (EU) 2023/1162 (Article 4(4)), which requires a clear separation of functions between electricity distribution companies and other market participants.

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