DLMS User Association
DLMS UA
International Standardization Organization standardizing the Data Model and Data Format, focused on developing and promoting efficient and effective interoperable and secure data exchange for the digitalization of strategic infrastructures (Electricity, Gas, Heat and Water).
ID: 595957994270-62
Lobbying Activity
Response to Roadmap for artificial intelligence and digitalisation for energy (RAID-E)
26 Aug 2025
The digitalisation of Europes energy system is accelerating, driven by the deployment of smart grids, smart metering, distributed energy resources, electric vehicles, and flexible demand services. Artificial Intelligence (AI) plays a central role in turning this wealth of operational and consumer data into actionable insights for grid stability, demand forecasting, and energy efficiency. However, without a clear roadmap and governance framework at EU level, the rapid adoption of AI risks creating fragmented solutions, inconsistent safeguards, and new cybersecurity vulnerabilities. A European initiative is necessary for three key reasons: 1. Governance of Algorithms and Trust Energy data analytics increasingly rely on algorithmsranging from forecasting models to optimization engines for distributed flexibility. The opacity of algorithmic decision-making, combined with the sensitivity of energy data, raises risks of bias, manipulation, or misuse. EU-level governance can establish rules for transparency, auditability, and accountability of algorithms applied in the energy domain, ensuring trust across Member States and protecting consumers as critical infrastructures digitalise further. 2. Cybersecurity by Design Edge vs. Cloud Many AI analytics today are performed in cloud environments. While centralised processing offers scale, it also creates new attack surfaces: large data transfers from millions of devices, increased dependency on external providers, and potential exposure of critical grid data. By contrast, edge computingwhere algorithms are deployed directly in or close to the devicecan reduce latency, improve resilience, and minimize data exposure. A roadmap must therefore guide when AI analytics should remain at the edge, and when secure cloud processing is appropriate, supported by standards and certification. Without such guidance, inconsistent choices may lead to higher cybersecurity risks and higher compliance costs. 3. Interoperability and Market Efficiency Europes energy system depends on cross-border exchanges and interoperability among thousands of actors. Divergent national approaches to AI in energy risk creating silos, market barriers, and vendor lock-in. An EU-level roadmap can set common principles for algorithm management, certification of AI-based energy applications, and the use of harmonised standards. This will enable the innovation through the standardization while ensuring that digital solutions are portable, interoperable, and aligned with the Single Market. The "Innnovation through the standardization" being one of the most powerfull business development tool. 4.Lifecycle and Sustainability AI models evolve continuously, requiring retraining, updates, and patch management. In energy, this lifecycle must be managed carefully to avoid introducing vulnerabilities or operational instability. The EU roadmap should therefore align with the Cyber Resilience Act (CRA), NIS2, and RED requirements, by embedding secure lifecycle management of algorithms, including monitoring, auditing, and coordinated vulnerability disclosure. Conclusion An EU-level roadmap on Artificial Intelligence and Digitalisation for Energy is essential to secure Europes energy transition. It will provide governance for algorithms, reduce cybersecurity risks by clarifying the edge/cloud balance, ensure interoperability across Member States, and embed lifecycle security for AI applications. Such a framework will foster trust, innovation, and resilience in Europes digital energy future.
Read full responseResponse to Targeted technical update of EU rules on measuring instruments
8 Jan 2025
Detailled comments are made into the here attached pdf file. Those concerns elements identified in the following areas: Appendix I - We reccomend to add the Water and Heat meter to take full advantage of the digitalization standardization work ongoing which would benefit from the MID amendment alignement. Appendix Va - We reccomend to issue it only specifically to cover the Commercial EVCS or EVCS used also for Public Transactions to avoid penalizing Residential or Private use EVCS with the costs burden to fulfill these metrology requirement needed to identify the EVCS losses and remove them from the Public EVCS Transactions. The same comments have been made during the interview occuring last December with CSES Leading Consultant and Spark Legal and Policy Consulting.
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