OpenLobby.EU
Explore

European Smart Energy Solution Providers

ESMIG

ESMIG represents European companies providing products and services for smart energy and water management.

Lobbying Activity

Meeting with Bonifacio Garcia Porras (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

27 Nov 2025 · Discussion over the ESMIG’s feedback on the Call for Evidence to the Foreign Subsidies Regulation Review Report

Smart energy providers back rules for delaying cyber notifications

8 Nov 2025
Topic — This regulation defines when authorities may delay sharing reports of cyber vulnerabilities.
Message — ESMIG supports efforts to harmonise and clarify cybersecurity vulnerability and incident notification obligations. They believe the proposal provides important safeguards for handling sensitive information.12
Why — This helps manufacturers by preventing the premature public disclosure of sensitive product vulnerabilities.3
Read full response

Smart energy providers urge faster smart meter deployment

4 Nov 2025
Topic — This consultation addresses the integration of digital technologies and artificial intelligence into energy systems.
Message — ESMIG recommends making smart meter deployment a cornerstone of the roadmap to provide data infrastructure. They call for common standards for data spaces and harmonised privacy guidelines to support innovation.123
Why — Accelerated rollouts would increase demand for the high-tech metering infrastructure ESMIG members produce.4
Impact — Privacy advocates may see their protections weakened if harmonised guidelines prioritize innovation over strict rules.5
Read full response

Smart energy group urges binding EU meter rollout targets

9 Sept 2025
Topic — An initiative to help citizens benefit from and participate in the energy transition.
Message — The group requests a binding 80% smart meter rollout target for all member states by 2030. They demand real-time data access for consumers to better manage their bills. They also call for removing barriers to flexible energy consumption.123
Why — Mandatory rollouts would guarantee long-term demand for the smart meter products and services they provide.4
Impact — Non-European technology providers face potential exclusion from the market due to proposed security screening.5
Read full response

ESMIG urges faster smart meter rollout to secure European grids

31 Jul 2025
Topic — The consultation seeks input on measures to accelerate the upgrade and expansion of European grids.
Message — ESMIG recommends prioritising the roll-out of smart meters to enable a more efficient grid. They also suggest identifying and assessing high risk suppliers to protect infrastructure.12
Why — Focusing on technology sovereignty would protect European companies from non-EU competition.3
Impact — Foreign technology vendors may lose access to the EU market due to security-based exclusions.4
Read full response

ESMIG backs Cybersecurity Act to ensure uniform EU standards

11 Jun 2025
Topic — This consultation aims to revise the Cybersecurity Act and the EU certification framework.
Message — ESMIG recommends keeping the current Cybersecurity Act text and ENISA support. They stress the need to prevent fragmentation caused by differing national certification schemes.12
Why — A single certification approach would streamline market access across all European countries.3
Read full response

Meeting with Bonifacio Garcia Porras (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

10 Jun 2025 · COM and ESMIG agreed to cooperate closer on FSR and public procurement related matters.

Response to Technical description of important and critical products with digital elements

17 Apr 2025

ESMIG - The European association of smart energy solution providers welcomes the opportunity to comment on the European Commission's draft implementing regulation that contains draft technical descriptions of the products with digital elements in the important and critical categories of the Cyber Resilience Act. Our comments are listed in the document attached. Additionally we would like to discuss with the Commission the CRA category for smart meters after this consultation.
Read full response

Smart energy providers urge European preference in public procurement

6 Mar 2025
Topic — Evaluation of three directives governing the award of public procurement and concessions contracts.
Message — ESMIG proposes strengthening non-price criteria like sustainability and cybersecurity for tenders. They urge stricter rules to identify and reject abnormally low bids from subsidized competitors. The association also supports introducing European preference criteria for strategic sectors.123
Why — These changes would protect European manufacturers from being undercut by state-subsidized foreign competition.4
Impact — Subsidized third-country producers would find it harder to win contracts based solely on price.5
Read full response

Response to Delegated act on primarily used components under the Net-Zero Industry Act

19 Feb 2025

ESMIG, the European association of smart energy solution providers, fully supports the objectives of Net Zero Industry Act (NZIA) to enhance European manufacturing capacity for net-zero technologies and their key components. Thus, we welcome the inclusion of smart meters and Advanced Metering Infrastructure (AMI) in the list of final products considered to be primarily used for the production of net-zero technologies, under the category Technologies to digitalise the grid and other electricity grid technologies. Indeed, smart meters and AMI are an integral part of and a prerequisite for the development of smart electricity grids enabling demand side flexibility and the uptake of renewables. Europe is a global leader and standard setter in this innovative industry. However, this role is being challenged by the EUs main competitors, benefitting from strong public support schemes and subsidies. European companies are increasingly facing unfair competition from third country producers in the EU market. The risks of losing global leadership in energy infrastructure and smart energy solutions and of compromising Europes strategic autonomy and becoming increasingly dependent on non-European technology vendors cannot be ignored. With the Net-Zero Industry Act, the EU has taken a first set of measures to support European excellence, strengthen manufacturing, and limit vulnerabilities as a consequence of dependencies on single third countries. Setting the the right priorities in implementing the NZIA will ensure that the EUs energy and climate ambition goes hand in hand with the EUs industrial policy, supporting sustainability and competitiveness, European technology sovereignty and mastering of critical value chains.
Read full response

Response to List of net-zero technology final products and their main specific components

19 Feb 2025

ESMIG, the European association of smart energy solution providers, fully supports the objectives of the Net Zero Industry Act (NZIA) to enhance European manufacturing capacity for net-zero technologies and their key components. Thus, we welcome the inclusion of smart meters and Advanced Metering Infrastructure in the list of net-zero technology final products and their main specific components to assess the contribution to resilience, under the category Technologies to digitalise the grid and other electricity grid technologies. Indeed, smart meters and AMI are an integral part of and a prerequisite for the development of smart electricity grids enabling demand side flexibility and the uptake of renewables. Europe is a global leader and standard setter in this innovative industry. However, this role is being challenged by the EUs main competitors, benefitting from strong public support schemes and subsidies. European companies are increasingly facing unfair competition from third country producers in the EU market. The risks of losing global leadership in energy infrastructure and smart energy solutions and of compromising Europes strategic autonomy and becoming increasingly dependent on non-European technology vendors cannot be ignored. With the Net-Zero Industry Act, the EU has taken a first set of measures to support European excellence, strengthen manufacturing, and limit vulnerabilities as a consequence of dependencies on single third countries. Setting the the right priorities in implementing the NZIA will ensure that the EUs energy and climate ambition goes hand in hand with the EUs industrial policy, supporting sustainability and competitiveness, European technology sovereignty and mastering of critical value chains.
Read full response

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur for opinion) and European Association Automotive Suppliers and Fair Standards Alliance

20 Oct 2023 · Standard Essential Patents (COD 2023/0133) (Meeting with APA)

Response to Voluntary cybersecurity certification for ICT products, based on a Common Criteria set of security requirements

16 Oct 2023

Annex I of the Implementing Regulation lists State of the Art documents. In the field of smart meters, some Protection Profiles have been developed and certified under the SOGIS framework. These profiles are listed on the Common Criteria portal under "Other devices and Systems" (smart meter) and under "Network and Network Related Devices" (smart meter gateway). We propose to include these Protection Profiles and Start of the Art documents.
Read full response

Meeting with Maria da Graça Carvalho (Member of the European Parliament, Shadow rapporteur for opinion)

5 Oct 2023 · Standard Essential Patents

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Shadow rapporteur for opinion)

4 Oct 2023 · SEPs

Smart energy association backs transparent EU patent licensing rules

25 Jul 2023
Topic — A legislative proposal to create a transparent and predictable framework for standard-essential patents.
Message — ESMIG urges the swift adoption of rules requiring licensing at all supply chain levels. They also want 5G standards included to prevent royalty stacking from hindering innovation.12
Why — This framework would lower transaction costs and remove uncertainties for smart meter manufacturers.3
Impact — Patent holders will lose their ability to charge inflated royalties based on end products.4
Read full response

Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

16 Jun 2023

ESMIG, the European association of smart energy solution providers, fully supports the proposal to defer the application of Delegated Regulation (EU) 2022/30 to 1 August 2025. An agreement on the applicability of the generic harmonised standard for smart meters has been reached, however the current requirements (that are not fully defined yet) need to be considered carefully regarding their feasibility for smart meters. In addition, defining additional guidance for the application of the generic requirements in the case of smart meters (or similar equipment) might be needed. As a consequence, more time is needed to finalise the harmonised standard with security requirements.
Read full response

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

17 Apr 2023 · Standard essential patents (SEP)

Meeting with Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

31 Mar 2023 · Standard Essential Patents

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

29 Mar 2023 · Standard Essential Patents

ESMIG Urges EU to Streamline Smart Meter Cybersecurity Rules

23 Jan 2023
Topic — The consultation addresses mandatory cybersecurity requirements for manufacturers and vendors of digital products.
Message — ESMIG calls for industry involvement in risk assessments to ensure appropriate product classification. They advocate for eliminating overlapping security requirements between different EU acts to ensure regulatory clarity.12
Why — This would reduce administrative burdens and prevent duplication of costly certification procedures.3
Impact — Public safety might be compromised if manufacturers exclude unexploited vulnerabilities from reporting requirements.4
Read full response

Response to Cyber Resilience Act

20 May 2022

ESMIG members would like to share their feedback on the call for evidence on the Cyber Resilience Act. In the past few years, cyber and information security topics, network protection, security risk management, security governance, security certification and data protection have been addressed with several legislative and regulatory directives, acts and frameworks, like the Network and Information Security (NIS) Directive and General Data Protection Regulation (GDPR). Namely for smart metering solutions, there are several legislative and regulatory acts already in place, to which smart metering products, solutions and industry must comply with: - The Measurement Instrument Directive, with Articles 8.1 - 8.5 related to protection of functions and data. - The Radio Equipment Directive’s (RED) new Delegated Act, applicable to smart meters, where several baseline and high-level protection requirements must be respected. - The Cybersecurity Act, establishing cybersecurity frameworks for products and services. In this regard, a separate cybersecurity certification approach for smart meters was prepared, based on Common Criteria. - The Network Code on Cyber Security, as an extension of NIS / NIS 2 directive, applicable specifically for energy sector, proposes and applies new security requirements and risk management approaches for all equipment used in energy systems. As with other industries and sectors, smart metering providers and manufacturers are subject to general legislative and regulatory directives, as mentioned above, the NIS and GDPR. The smart metering sector supports any upcoming legislative and regulatory acts in the field of cybersecurity, addressing ever changing and evolving cybersecurity threats. Particularly, we would like to point out threats, related to major incidents in past 2 years, originating from the violation of trust between vendors and customers (this includes supply chain threats, open-source software threats and similar). We would like to emphasise that it is crucial that any obligatory acts do not overlap or even compete with one another, causing confusion and the possibility of several interpretations. Furthermore, we believe that the existing regulations, where smart meters are in scope, already cover a substantial set of requirements for our sector. Additionally, the security requirements, defined in existing legislation, should be applicable to a wider scope of products, irrespective of their country of origin. As briefly described and stated in ESMIG’s position paper on “Fair Competition in the Energy Sector” in 2021, cybersecurity legislation and regulatory acts must be broader and include non-European countries, governments or related bodies to minimise any supply chain and cybersecurity risks, originating from components and products outside the European Union. Therefore, ESMIG strongly supports the initiative that “[…] European intervention would likely cover a broad range of products placed on the internal market, irrespective of their origin” and proposes to exclude the word “likely”, applying the intervention to all products, irrespective of their origin. Based on the discussion presented above, ESMIG proposes a combination of both mandatory and voluntary measures in a phased approach towards a legislative framework, with the involvement of relevant stakeholders: - A horizontal regulatory intervention introducing cybersecurity requirements for a broad scope of tangible digital products and ancillary services - Guidelines or recommendations. For e.g., non-embedded software as a first step, potentially followed by regulatory intervention depending on the results of implementing such measures.
Read full response

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

ESMIG members welcome the proposal for a revision of the Energy Performance of Buildings Directive (EPBD) to contribute to the achievement of the EU’s energy and climate objectives for 2030, and the climate neutrality objective for 2050. The decarbonisation of the buildings sector is indeed vital to deliver on the EU’s climate and energy objectives, given that buildings are responsible for 40% of total energy consumption. Within this context, energy efficiency is an essential element. The smart meter is directly linked and indispensable in achieving energy savings. The deployment of intelligent metering systems in buildings is necessary not only for enabling consumer awareness and participation, but also for electro-mobility. The smart meter is the only way to have a reliable and certified measurement of the energy consumed and/or generated by a building at a specific time of use. ESMIG welcomes the new article 14 on data exchange. In particular, we fully support that consumer have access to their data and can decide to provide access to a third party at no cost. However, there are still untapped opportunities such as data interoperability and analytics, dynamic tariffs and real-time information which are crucial components of consumer empowerment. The system needs to be designed for consumers to enable them to participate in the energy market, and to protect their rights and privacy. Therefore, if access to historical data will be beneficial in the context of buildings renovation, it is crucial to enable the consumers to access their energy consumption data in real time to ensure more energy efficient buildings. This will encourage them to change their consumption patterns and to engage in energy generation and demand response. In addition, this will give them the possibly to provide access to the energy service providers they chose to help them better manage their energy usage. This can only be done if they receive accurate and timely information on their energy consumption. The lack of real time access to data and sharing of data between market participants in many countries are the barriers preventing savings being directly shown to consumers. Data needs to be interoperable and made available, in a non-discriminatory manner, to all energy market participants, including transmission and distribution system operators, retailers, energy services providers, and other market players.
Read full response

Response to Action plan on the digitalisation of the energy sector

10 Sept 2021

ESMIG, the European association representing the smart energy solution providers, welcomes the proposal for an action plan on the Digitalisation of the Energy sector. With a clear focus on digitalisation and clean energy, ESMIG and the introduction of smart meters have an important role to play in the dual green and digital transition. Smart meters are essential for achieving the 3 D’s: a decarbonized, digitalised and decentralised energy system. The success of smart metering roll outs depends on the quality of the data generated and transmitted. Compromises to the security of this data can impact the privacy and safety of European citizens. Hence, implementing steps in the supply chain to guarantee data security and sovereignty – on the meter, in transit and when stored on the back-end, are essential. Indeed, achieving the energy transition and digitalisation while maintaining the privacy and data security of Europe’s citizens and businesses is crucial. On that matter, Europe’s strategic autonomy will be vital for key enabling technologies such as communications and cybersecurity. Depending on non-EU technology and solution providers can have serious consequences for the complex value chain in our sector. This involves using existing laws and technology, while also certifying the supply chain for these technologies, to ensure that no external actor can manipulate it in compromising European rights and laws. Europe needs to adopt policies that mitigate the risk linked to communication technology supply chains and security. Enhancing the cybersecurity in the energy sector is key for the digitalisation of the energy sector. However, the proposed Directive on Security of Network and Information Systems (NIS-2 Directive), the planned Network Code on cybersecurity as well as the delegated act under Articles 3(3)(d), (e) and (f) of the Radio Equipment Directive already constitute a comprehensive framework. It will be important to carefully evaluate the need for any additional measures to ensure consistency with the existing legislations. In addition, to take full advantage of the digitalisation, data generated by smart meters needs to be provided in an efficient, non-discriminatory way and free of charge for all authorized energy market participants. This involves interoperability of the data and the processes that go with this data.
Read full response

Response to Addressing distortions caused by foreign subsidies

16 Jul 2021

ESMIG welcomes the proposal for a Regulation on foreign subsidies distorting the internal market. ESMIG members are confronted to this situation in the specific context of public procurements for the national rollouts and solutions of smart meters in the European Union. Among others, actions should be taken to strengthen contract award criteria, address non-compliance with EU rules and standards, tackle abnormally low tenders, and be stricter in terms of buyer accountability. ESMIG supports the European Commission’s proposal in Article 28 to introduce a mechanism of prior notification of foreign financial contributions in the context of public procurement procedures whereby bidders would have to notify the contracting authority, or the contracting entity of foreign financial contributions received in the last three years. The Commission would then assess whether there is a foreign subsidy and whether it made the procurement procedure unfair. In this case, the bidder would be excluded from the procurement procedure. However, we would like to express our concerns on the decision to apply this procedure only where the estimated value of the procurement is €250 million or more. Most of the public procurements for the national rollouts and solutions of smart meters in the European Union are below this threshold. We understand the European Commission’s approach and the stake of setting such threshold. However, defining only one criterion exclude most of the European industries from this procedure, some of them being critical for the European Union. ESMIG members participate in mission critical infrastructure and risks of unfair competition are closely connected with the safety of the electricity and gas grids, privacy and data security of Europe’s citizens. At the same time, these technologies are essential for enabling the green and digital energy transition. Therefore, we think that multiple criteria should be defined, including “mission critical infrastructure” in addition to the threshold. That way, the Regulation would not only protect the European economy, but also strategic independence of EU mission critical infrastructure. However, we agree that extending this obligation to main subcontractors and main suppliers in the context of procurements below €250 million would represent an excessive administrative burden which should be avoided. The tender shall be automatically rejected by the contracting authority if a company fails to prove that it has not benefited from non-EU state aids. ESMIG also agrees with the proposal to consider the balancing between the negative and positive effects of a foreign subsidy. However, the potential positive impact(s) will be very difficult to evaluate. A long-term assessment, ensuring that the effect(s) of the foreign subsidies are aligned with all the other EU policy objectives will be essential. In addition, specificities of sectors should be taken into consideration and in particular companies involved in critical infrastructure. Compliancy with the EU legislation and guidelines should be proved by the bidding candidate and take the form of an audit which could potentially lead to the prohibition for the company to participate in EU tenders for a given period. Bidding candidates should have the possibility to notify the authority in case of suspicion of abnormally low prices or any other non-compliancy with EU legislation and guidelines. In this context, abnormally low tenders should be addressed. This term should be clearly defined and the obligations of contracting authorities to check the justifications for low price should be strengthened. Awarded bids must be considered as potentially abnormally low if the winning price is more than 10 to 15% below the average given price. The burden of proof would be on the bidding candidate whose offer is suspected to be abnormally low. For a matter of transparency, the final price of winning tenders should be released.
Read full response

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

ESMIG members welcome the proposal for a revision of the Energy Performance of Buildings Directive (EPBD) to contribute to the achievement of the EU’s energy and climate objectives for 2030, and the climate neutrality objective for 2050. The decarbonisation of the buildings sector is indeed vital to deliver on the EU’s climate and energy objectives, given that buildings are responsible for 40% of total energy consumption. Within this context, energy efficiency is an essential element. The smart meter is directly linked and indispensable in achieving energy savings. The deployment of intelligent metering systems in buildings is necessary not only for enabling consumer awareness and participation, but also for electro-mobility. It is crucial to enable the consumers to acknowledge and change their consumption patterns and to encourage them to engage in energy generation and demand response. This can only be done if they receive accurate and timely information on their energy consumption. The smart meter is the only way to have a reliable and certified measurement of the energy consumed and/or generated by a building at a specific time of use. However, there are still untapped opportunities such as data interoperability and analytics, dynamic tariffs and real-time information which are crucial components of consumer empowerment. The system needs to be designed for consumers to enable them to participate in the energy market, and to protect their rights and privacy. Smart meters and the aforementioned untapped opportunities would also serve as enabling technologies for a wide range of European companies to provide services and further expand the smart energy technology sector of the economy. Therefore, an ambitious revision of the EPBD, which will not only reduce building’s energy consumption, but will also enable a more end-user focused, more decarbonised and more digital energy system is needed.
Read full response

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

ESMIG members welcome the proposal for a revision of the Energy Efficiency Directive (EED) to achieve a higher level of greenhouse gas reduction by 2030 as well as the European Green Deal initiatives. Energy Efficiency First principle is indeed a key means to decarbonise the energy system. The EED revision represents also an opportunity to improve the enabling framework for energy management. In effect, the smart meter is directly linked and indispensable in achieving the energy efficiency targets. Its successful deployment will enable consumer empowerment, measuring and thus managing consumption patterns. In this matter, article 9 on metering is of particular importance to ensure the participation of end-users in the smart energy system of Europe’s future. This article needs to be clarified as it is subjected to interpretation and leads to uncertainty. Indeed, it creates loopholes which open the possibility of avoiding smart meters deployment: • The criteria mentioned in paragraph 1: “technically possible, financially reasonable and proportionate in relation to the potential energy savings” ignore the societal benefits: the whole energy system profits from smart meters, not only the consumers, helping avoid costly and disruptive outages and better manage the grid. Smart meters are also essential in enabling energy management and consumer empowerment. • The phrase “Competitively priced” is ambiguous: meters are not sold to final consumers and when utilities buy meters, many times this falls under public procurement rules, so competition guarantees the cost efficiency and the market determines the reasonableness of the price. • The roll-out of gas smart meters is of utmost importance for consumers as the potential savings are high. Moreover, some Member States have already started their roll-out. Therefore, the effective deployment of gas smart meters should be ensured, and to this end, an ambitious target date should be set, as it is already the case for the electricity smart meters. Finally, the deadline of 1 January 2027 for the replacement of meters by remotely readable devices is not ambitious enough to achieve the new energy efficiency target. The target date should be no later than 2025 to possibly reach the climate goals.
Read full response

Response to Commission Communication – "Renovation wave" initiative for the building sector

5 Jun 2020

ESMIG welcomes the ‘renovation wave’ initiative, energy efficient buildings being indispensable for reaching the EU’s carbon neutrality, energy efficiency and renewable energy objectives. The timing of electricity management, related to when and where electricity is needed on the grid, will matter far more in coming decades due to an increasing reliance on distributed energy resources and the integration of large and small renewables. Moreover, building owners and tenants will have the right tools to increase their consumption during supply peaks and reduce it when the system is on a low supply or when there is high demand. The number of ‘prosumers’ will grow, along with the flexibility of consumption increasing. However, this will only be possible if customers have access to systems that work for them. It is crucial to prevent unplanned downtime that could impact the flexibility and energy supply. Smart metering systems and access to real time energy data are both indispensable to empower the consumer and to ensure a good management of the whole system. Demand response will be a key element of this new system. The ability for the consumer to monitor and control consumption is the pre-requisite for market-based pricing and network optimisation. The EU based electricity generation has been successful at reaching a high level of decarbonisation. However, there are still untapped opportunities such as data interoperability and analytics, dynamic tariffs and real-time information which can be used for energy efficiency of buildings. The benefits of data interoperability of building energy management solutions must be considered. This would lead to easier and better benchmarking and possibly CO2 footprint calculation for buildings. Regulatory barriers, a lack of practical experiences and slow political processes still hinder the transition towards a digitalised and decentralised energy management. We need: ✓ A regulatory framework that encourages rather than hinders the trend towards a multidirectional, dynamic, decentralised and interoperable participation in the energy system by building owners or tenants. ✓ Energy settlement to take place between market operators, for residential and business customers, on the basis of interval measured energy profiles (not synthetic) ✓ Solutions for energy management applications that work with near real-time energy consumption data ✓ Non-discriminatory access to the market for new players: regulated companies should offer non-discriminatory access to the system and consumption data to new players with consumer consent (independent aggregators, flexible energy services, such as demand-side flexibility and battery storage, and other energy service companies) ✓ Interoperable systems for metering and energy management that can be used for multiple commodities such as electricity, gas, water and heat upgraded with solutions for the consumers.
Read full response

Response to Strategy for smart sector integration

19 May 2020

ESMIG contribution to the Consultation on the EU strategy for the integration of the smart sector for a future integrated European energy system is attached.
Read full response