2.1 Characteristics of the Nordic electricity retail markets
The Nordic electricity markets, including the electricity retail markets, share many fundamental characteristics. Although Iceland shares some of these characteristics with the other Nordic countries, Iceland is not connected to the European power grid and has several fundamental differences in how the electricity retail market is organized compared with the other Nordic countries. In this chapter, we shall describe some fundamental shared characteristics of the Nordic electricity retail markets. A further description of the characteristics of the Icelandic market is found in chapter 7.
2.1.1 Relevant players
The organization of the electricity retail markets in the Nordic countries is quite similar, with the Icelandic market being the exception. In all countries, the key players in this market include power producers, Transmission System Operators (TSOs), Distribution System Operators (DSOs), Balance-responsible party (BRP), and electricity retailer suppliers. They work together to ensure the functioning of the electricity retail market. Electricity production companies are entities responsible for generating electricity from various energy sources and supplying it to consumers or selling it on the wholesale electricity market. There are several electricity production companies in all the Nordic countries, except from Iceland where Landsvirkjun produces 70 percent of the electricity production. TSOs are responsible for the high-voltage transmission of electricity from power plants to distribution networks. They also manage the operation of cross-border interconnectors. DSOs manage the low-voltage distribution networks and deliver electricity to end-consumers. They are responsible for grid maintenance and connecting new consumers to the grid. BRPs are companies with the authorization to manage the balance responsibility for production and consumption units, as well as engage in the actual trading of electricity. BRPs are also accountable for discrepancies and variations in the anticipated versus real production, consumption, and trading of electricity. Electricity retailers sell electricity directly to consumers. Retailers offer various pricing plans and services, giving consumers choices in selecting their electricity provider.
2.1.2 A liberalized electricity retail market
Most European electricity markets were liberalized during the 1990s. Before the electricity market liberalization, the electricity retailers owned all aspects of the electricity value chain, from production and transmission to the final distribution of electricity to customers. With the electricity market liberalization, neither consumers nor distribution companies were tied to their own power plants anymore, leading to a separation of the original monopoly – the electrical grid – and the competitive activities, such as electricity production and trading. The main goals of these reforms were to introduce competition, increase efficiency, and reduce electricity prices for consumers. The process also involved establishing a regulatory body to oversee the sector. The liberalization introduced competition in the Nordic electricity retail market, allowing consumers to choose their electricity supplier. This competition has led to innovations in pricing and services, giving consumers more options to select electricity plans that suit their needs. The unbundling process has, however, varied somewhat between the different Nordic countries. Today, there are for instance some differences regarding the degree of separation between some companies’ distribution activity, power production and retail activity.
2.1.3 Nord Pool, NASDAQ and OTC agreements
The liberalization of the electricity market also led to the establishment of Nord Pool in 1996. Nord Pool operates as a common marketplace where electricity producers, traders, and consumers can buy and sell electricity across the Nordic and Baltic regions. This integration has led to increased market liquidity and efficiency. Nord Pool operates both day-ahead and intraday electricity markets. In the day-ahead market, market participants trade electricity for delivery on the following day. The intraday market allows for more flexible trading closer to real-time and helps balance supply and demand.
Additionally, entities can trade financial contracts on the Nasdaq exchange. The financial contracts have different durations, ranging from weeks, months, quarters, and annual agreements, with contracts including forward, futures, or options contracts, and EPADs. The financial contracts enable power traders, producers, distributors, and electricity retailers to mitigate electricity price-related risks effectively. Nasdaq Commodities exchange announced in June 2023 that they have agreed to transfer Nasdaq's operations in the electricity futures market within the Nordic region to The European Energy Exchange (EEX). EEX operates a marketplace for the futures market, spot market, and intraday market across extensive portions of the European Economic Area (EEA). Through its subsidiary, EPEX, EEX provides its members with the ability to engage in trading activities within the spot and intraday markets in Norway and the broader Nordic region. Nord Pool has also stated that they are considering establishing a financial trading platform.
In addition to Nasdaq, trading with standardized contracts can occur on what is known as OTC (Over The Counter), where a broker serves as an intermediary or facilitator. Market participants often prefer exchanges over OTC agreements if exchanges are efficient and have good liquidity. However, if liquidity is low, those in need of price hedging typically use OTC-agreements. OTC-agreements can also be tailored to the specific needs of market participants, and thus be preferred over financial markets. This can for instance be the case if a market participant needs particularly long contracts, or full hedging against differences between the area prices and system prices. The financial markets, however, have positive externalities through the establishment of reference prices for the expected long-term power price that everyone can use in their investment and operational decisions, and as a reference to OTC-agreements.
The energy crisis has contributed to decreasing liquidity in the financial markets. Because of significant variations in the area prices, the products in the financial markets have become less relevant. In addition, they have become more expensive because of high collateral requirements, and typically higher than for OTC trading. Thus, OTC trading has become increasingly common in the Nordic market and is today relatively common for futures contracts that hedge the price in a specific bidding area. OTC trading represents both competition and a supplement to power exchanges like Nasdaq and EEX and is considered a part of the futures market.
2.1.4 Organization of the electricity retail market
The organization of the retail markets in the Nordic countries is quite similar, apart from Iceland. Private customers and business customers purchase electricity for their own consumption through an electricity supplier or a broker. Entities that sell electricity in the retail market acquire electricity in the wholesale market, which they then sell to their customers. Some larger end-users such as major industrial companies, trade directly in the wholesale market or through bilateral agreements with electricity producers, and they do not fall within the scope of the retail market.
Electricity suppliers and consumers have contractual agreements outlining the amount of electricity to be bought and sold. Electricity suppliers bear the responsibility for any imbalances between production and consumption that may arise. BRPs manage discrepancies between production and consumption, ensuring that the difference is zero, which is crucial to maintain grid stability.
Electricity suppliers are not responsible for the physical delivery of electricity. It is the DSOs that ensure the customers’ access to the market by connecting them to the electricity grid and distributing electricity to customers. In addition to the payment of electricity to the chosen electricity supplier, customers must also pay a grid fee and taxes to their local DSO for the distribution of power. Distribution network companies operate as local monopolies and are subject to monopoly regulation. These monopoly regulations cover, for instance, the price setting of tariffs and terms for accessing the grid. Therefore, in the retail market, there is a distinction between monopoly activities (conducted by the distribution network company) and competitive activities (conducted by the electricity supplier).
2.1.5 Key regulatory and consumer actors involved in the electricity retail market
In the electricity retail markets, various regulatory and consumer actors play essential roles in ensuring fair competition, consumer protection, and the overall functioning of the market. Here are some of the key regulatory and consumer actors typically involved:
The National Regulatory Authorities (NRAs) in the Nordic countries are responsible for regulating, monitoring and improving the functioning of electricity markets. They typically aim to ensure a user-friendly and efficient retail market, occasionally imposing fines for breaches. They can propose, and in some of the countries approve, regulations. In Iceland, laws must be approved in parliament and regulations by the ministry. Typically, the NRAs also enforce specific sector regulations regarding consumer rights.
The Consumer Authorities in the Nordic countries function as supervisory authorities that work to make the electricity markets simpler and safer for consumers. The Nordic Consumer Authorities are responsible for monitoring the business practices and contract terms of traders. Their primary focus is on preventing and stopping illegal marketing, unfair contract terms, and other forms of unlawful trading practices directed towards consumers. The Consumer Authorities can impose various types of financial sanctions, either infringement fines, penalty payments, or both. There are also a National Board for Consumer Disputes in the Nordic countries that handles complaints arising from contractual relationships between energy companies and consumers.
Furthermore, there are also Consumer Councils in the Nordic countries that represent the consumer interests and influence businesses and government authorities to become more consumer-friendly. The Nordic countries typically also have industry organizations to represent electricity retailers that are members of the organization. Their goal is to forward the mutual interests of its members, guard their interests in mutual projects, foster research and gather information for its members as well as for public authorities, hosting seminars and conferences and acting on behalf of the members. The industry organizations in Denmark and Norway have industry standards such as the standard electricity supply agreements. In Denmark, this regulates the cooperation between grid companies and electricity suppliers. The standard electricity supply agreement in Norway provides a summary of the rights, which consumers and businesses have under current legislation and practices.
The Competition Authorities also play a role in the electricity markets by working to promote competition for the benefit of consumers and businesses. In their daily operations, the Competition Authorities have limited involvement in the retail electricity market. However, they are, for example, involved in acquisitions and mergers among electricity retailers, and they typically comment on proposals or activities that influence the competition in the electricity retail market.
2.1.6 Regulatory framework in the Nordic electricity retail markets
The regulatory framework governing the electricity retail market in the Nordic countries is designed to ensure fair competition, protect consumers, and promote the efficient functioning of the market. The main regulations that cover the electricity retail market generally involve an electricity market act, a marketing act, and a price information act. Additionally, there may be other laws specific to each country.
An electricity market act typically specifies the need of a license from the regulatory authority for engagement in trading of electrical energy. Furthermore, it introduces requirements for the structural and functional separation of vertically integrated companies. All Nordic countries have implemented measures to split up traditionally vertically integrated companies, but the degree of vertical integration with production and/or grid companies varies.
Most regulations concerning information to the consumers in the electricity retail market fall under general marketing or consumer protection acts. These laws typically lay out the general consumer protection for contracts and states that the seller must use good market practice and that unfair trade practices are illegal. The consumer authority in each country holds the authority to impose financial sanctions on entities found to be in violation with the marketing act. Notably, while households benefit from consumer protection, the same level of protection is not extended to SMEs in all the Nordic countries. This particularly applies to Finland and Norway, where the customer rights of SMEs are limited in comparison to households. Legislation pertaining to the protection of non-household consumers is, in practice, nearly non-existent. Additionally, regulations in the Nordic countries encompass requirements for invoicing information and the procedures for entering into agreements, typically outlined in regulations on settlements.
2.1.7 The energy crisis
In the last two years, starting from the second half of 2021 and into 2023, there was an unexpected and significant increase in electricity prices in the Nordic countries and in Europe in general. The primary reason for this was the energy shortage resulting from Russia's invasion of Ukraine. The war in Ukraine also unfolded concurrently with a more long-term climate-driven transformation of the energy landscape in Europe, gradually phasing out both coal and nuclear power, while actively introducing renewable electricity as a replacement.
The energy crisis did not impact the physical distribution of power; electricity remained available but at an elevated cost. In addition to the price shock that customers suddenly experienced, leading to the implementation of electricity support schemes in several countries, a major challenge was the low liquidity within the financial markets and the retail supplier’s ability to hedge their portfolio.
Most market participants in the Nordic electricity retail market have traditionally used the system price to hedge their portfolio and take the risk that the difference between the system price and the price in the bidding area does not fluctuate more than what the retail supplier can tolerate. This has been a common practice due to the relatively low variations in the area prices compared to the system price. The system price is a computed index based on bids in the spot market for Norway, Sweden, Denmark, and Finland and does not provide the same rights for physical delivery. The system price does, however, not consider the different area prices due to constraints within the Nordic countries’ power grids. The term often used for the current electricity price in a specific bidding area is the area price. If a market participant has bought or sold electricity on NASDAQ, they have the option to physically deliver electricity at the prevailing area price in that particular region. Norway has five bidding areas, Sweden has four, and Denmark has two, while both Iceland and Finland only have one.
During the energy crisis, the Nordic electricity retailers did not find it sufficient to hedge only the system price due to the vast fluctuations in the different price areas. Electricity retailers in specific bidding areas thus wanted to hedge a larger volume in their own area in addition to the system price. The electricity retailers therefore needed a contract for the system price as well as an agreement for the difference between the system price and the price in the bidding area of interest. The market for futures contracts based on the system price has been efficient and liquid because there are more participants who want to hedge their price exposure to the system price rather than to individual bidding areas. The agreement that provides price hedging in a bidding area is called EPAD (Electricity Price Area Difference). EPADs are potentially available for each bidding area in all the Nordic countries. There are fewer participants interested in any EPAD than there are in contracts based on the system price. This poses a significant risk that the market for each individual EPAD contract is inefficient and lacks liquidity. The lack of liquidity in the financial markets thus posed a significant challenge for the electricity retailers during the energy crisis in terms of the ability to effectively hedge their portfolio. This made it, for instance, challenging for electricity retailers to offer attractive fixed price agreements to their customers.
Over the last decade, the liquidity in the financial futures markets have been steadily decreasing regardless of the energy crisis. The negative trend began when American entities withdrew from Europe in the aftermath of the financial crisis in 2008. To reduce the risk of a future financial crisis, Europe gradually introduced requirements that clearing of exchange-traded futures contracts had to be backed by cash or exchange-listed securities, and that the market would no longer accept bank guarantees. Following this change, liquidity declined. The price shock during the energy crisis in 2021 did, however, further weaken the liquidity in the market. This has led to a gradually shift towards bilateral agreements.