Public consultation on the amendment of the standard terms and conditions of the imbalance settlement agreement
fter public consultation amendments to the Imbalance Settlement Agreement has been submitted for approval to the National Energy Regulatory Council.
The main changes:
1) Change in the calculation of the neutrality component. From October 2025, upon joining the MARI platform, in order to increase market transparency and create conditions for market participants to make informed decisions when planning production and consumption, a preliminary neutrality component for the upcoming reporting period is announced in advance, using the difference between the actual neutrality components of previous months. This has led to practical problems when income is not collected for the actually incurred balancing costs and the Company's financial neutrality is not ensured.
The Agreement provides that the preliminary neutrality component is calculated using the actual data of the three previous market balance periods, i.e. by applying the average of the actual calculated neutrality components for these periods and evaluating the accumulated actual difference (S) between the costs and revenues attributed to the Company's balancing function. For example: the preliminary neutrality component (NC) for June is calculated according to the following expression: (actual February NC + actual March NC + actual April NC) / 3 + (uncollected revenue of previous periods (cumulative amount of April) / average imbalance amount for 3 months (i.e. February + March + April). It is expected that if the actual neutrality component is negative, it is equal to zero. If the calculated compensation part of the actual difference for previous periods (S) in the neutrality component exceeds 50 Eur/MWh, the Company may spread the compensation over a longer period, setting a compensation part not exceeding 50 Eur/MWh.
After applying the new neutrality component formula, it is predicted that the unearned income would be collected within 7 months.
In addition, the Company made other adjustments to the Agreement:
2) Deadlines for changing the balance structure. It is expected that the party responsible for the balance (hereinafter referred to as the BRP) must submit changes to its balance structure no later than within 10 days (instead of the previous 5 days). This change was made because market participants (and therefore the BRP) must submit planned electricity volumes to the exchange 7 days before the trading session, by which time the changes need to be entered into the systems.
3) Changes to the publication of the reserve guarantee component. Following the comments received during the public consultation, the deadline for publishing the reserve guarantee component was shortened from 5 days to 2 days. d., therefore, the calculation of the reserve component is provided using forecast data - such a pricing principle is uniform in the Baltic States.
4) Other editorial adjustments have been made. They relate to the deleted provisions that were relevant when the Baltic Balancing Market (CoBA) was in place until October 2024. and some wordings are being revised so that customers can clearly understand the requirements and (or) calculation principles.
It should be noted that during the public consultation, the principles of invoicing in the case of negative amounts were provided in the Agreement, providing that if the amount is negative, VAT invoices are issued by the purchasing party. However, upon receipt of information from the State Tax Inspectorate (hereinafter referred to as the Inspectorate), the Company needed to additionally apply to the Inspectorate for clarification. Accordingly, the Company did not make any changes regarding invoicing at this stage.
The Company conducted a public consultation of the draft Agreement from July 1, 2025 to August 1, 2025. After receiving and evaluating the comments and proposals received from market participants, the Company made corrections to the draft Agreement. On July 16, 2025 and August 22, 2025, the Company conducted public discussions of the draft Agreement, also additional meetings were held with several English speaking clients upon their request.
ENCLOSED:
1. Evaluation of the comments received (part in Lithuanian, part in English if comments received in English) (Disb_sut_derinimo pazyma(1).docx);
2. Amendment to the Imbalance Settlement Agreement (EN_imbalance agreement.docx) (automated translation to EN);
3. Comparative Version between current Imbalance agreement and amended Imbalance agrement (EN_comparative version.docx) (automated translation to EN).
