1. Digitalisation and AI driving the energy transition

The EU is accelerating the digitalisation of its energy system. As part of this effort, the European Commission is preparing a strategic roadmap on digitalisation and AI in the energy sector, by early 2026. It aims to support key elements of the decarbonisation process, including electricity grid optimisation, energy efficiency in buildings and industry, and demand-side flexibility[1].

2. Towards a common EU policy framework

The strategic roadmap is part of a broader push towards a common EU policy framework for digital energy solutions. Its legal basis can be found in Action 5 of the EU’s Affordable Energy Action Plan to complete the Energy Union[2]. According to the European Commission, a lack of coordinated action could result in system cost increases of up to EUR 103 billion by 2040.

3. AI and electricity grid operations

By leveraging digitalisation and AI, the EU seeks to improve the security and efficiency of electricity grid operations[3]. Against this background, the European Commission has announced the development of a European AI Foundation Model for Energy Grids[4]. This AI model contributes to the preparation of the strategic roadmap.

4. A European AI Foundation Model for Energy Grids

This initiative builds on existing EU AI policies, including the AI Act, the Apply AI Strategy and the AI Factory / Gigafactory ecosystem, which establish a supportive framework for trustworthy and sovereign AI foundation models in the energy sector. The proposed AI Foundation Model brings together stakeholders from both the energy and technology sectors.

5. Stakeholder involvement through working groups

On 8 December 2025, the European Commission organised a stakeholder workshop structured around three working groups to define the next steps towards a common framework:

(i) Working Group 1 – Use-cases

Working Group 1 focuses on defining priority use-cases, such as grid forecasting, congestion and voltage management, network hosting capacity assessment and grid infrastructure planning, as well as identifying the associated data and modelling needs.

(ii) Working Group 2 – Data sharing and governance

Working Group 2 addresses data-related aspects, including the identification of data needs, scope and barriers to data sharing for each priority use case, alongside the identification of relevant governance, requirements and contributions.

(iii) Working Group 3 – AI model framework

Working Group 3 is tasked with the development of the overarching framework for AI models in the energy sector. System operators will explore data-sharing solutions, while technology providers and research institutions will contribute their technical expertise. Smaller system operators are expected to be involved at a later stage.

6. Next steps and relevance for companies active in the energy sector

In the first half of 2026, the working groups will continue their work with a view to further developing the common framework. For companies active in the energy and technology sectors, these developments are worth close attention, particularly in light of upcoming obligations under EU data and AI legislation. We will continue to monitor and report on further progress.

Please do not hesitate to contact us should you have any questions or require further information on this topic.

Frederik Holtappels

frederik.holtappels@moov.law

Lawyer

[1] European Commission, “Digitalisation of the energy system”, 17 December 2025.

[2] COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Action Plan for Affordable Energy Unlocking the true value of our Energy Union to secure affordable, efficient and clean energy for all Europeans, Action 5, Brussels, 26 February 2025.

[3] ENTSO-E, “ENTSO-E’s Response to the European Commission Call for Evidence on the Strategic Roadmap for Digitalisation and Artificial Intelligence, 5 November 2025, p. 2.

[4] European Commission, “Conclusions – Workshop on European AI Foundation Model for Energy Grids”, 8 December 2025.