Europex and the All NEMO Committee welcome the opportunity to respond to the European Commission consultation on the draft Commission Delegated Regulation establishing a Network Code for Cybersecurity Aspects of Cross-Border Electricity Flows (NC CS). Our membership includes Nominated Electricity Market Operators (NEMOs) as well as Organised Marketplaces (OMPs), which both fall within the scope of the draft NC CS provided that they are identified as high-impact or critical-impact entities. While we generally support the initiative to enhance cybersecurity in the energy system, as far as the current draft is concerned, we call for crucial improvements in relation to stakeholder involvement, planning certainty, alignment with other legislative acts and existing international standards, as well as proper safeguards for sensitive information and more inclusive provisions on cost recovery.
For a more detailed feedback please see the submitted PDF.
