Fluence Energy

Fluence is a global market leader in energy storage products and services, and optimization software for renewables and storage.

Lobbying Activity

Meeting with Monika Zsigri (Head of Unit Energy)

14 Nov 2025 · Exchange of views on cybersecurity risks

Response to Revision of the EU’s energy security framework

13 Oct 2025

Fluence welcomes the opportunity to respond to the European Commissions call for evidence on the EUs energy security framework. Fluence is a global market leader in energy storage products, services, and optimisation software for renewables and storage, having deployed or contracted over 41 GWh of battery-based storage systems worldwide. In Europe, Fluence has deployed or contracted over 5 GWh of storage assets across 110 different projects. We ask the Commission to consider two key areas in their review: 1. Accelerate Energy Transition to Reduce Fossil Fuel Dependency The Ukraine energy crisis has exposed Europes vulnerability due to reliance on foreign fossil fuels. The weaponization of gas by Russia has led to hardship, high energy prices, and risks to European competitiveness and jobs. Reducing fossil fuel imports by accelerating the deployment of renewable energy is essential for energy security. We welcome the REPowerEU package and the Action Plan for Affordable Energy, as well as the grids package, which will strengthen interconnections. However, Europe must also accelerate the rollout of flexibility across its power system. Large-scale energy storage is vital for system resiliency, integrating renewables, and reducing costs. The roll out of renewable and power grids must go hand in hand with the deployment of energy storage. We call for a dedicated EU energy storage strategy, building on national flexibility assessments and the Commission Recommendations on Energy Storage, to create a robust framework for member states to accelerate the deployment of energy storage. Forecasts show the EU large-scale energy storage market will grow from 22 GWh in 2024 to 325 GWh by 2030, representing 75 billion in investment and 115 GW of capacityequal to 90 nuclear power plants. The market share of Chinese suppliers has increased from 4% in 2021 to more than 75% in 2025. We therefore believe that Europe should also take targeted action to strengthen the European energy storage industry alongside its solar and wind industry. Energy storage and renewables should therefore be treated equally in EU policy. Currently, storage is disadvantaged in the Net-Zero Industry Act (NZIA) and Clean Deal State Aid Framework (CDSAF) compared to renewable energy sources. Instead, Europe must also support the European energy storage industry going forward. 2. Safeguard Europes Energy System Against Cybersecurity Threats Europes reliance on foreign energy storage manufacturers heightens cybersecurity risks. The EU has a robust framework (Cybersecurity Act, Cyber Resiliency Act, NIS-2 Directive), but gaps remain in national implementation and applicability timelines. In the meantime, hybrid and cyberattacks on critical infrastructure are rising, with ENISA reporting that 25% of state-aligned cyberattacks on the EU originating from China, raising additional awareness around cybersecurity risks introduced by foreign supply chains. Additionally, energy storage assets are uniquely digital assets, often with multiple software control equipment, opening multiple attack ankles, on top of regularly being directly under operational control of energy storage OEMs. Given the EUs dependency and gaps in its cybersecurity framework, we urge the European Commission to conducts a targeted cybersecurity supply chain review for energy storage, similar to ongoing reviews for solar and wind. This review should provide investors and OEMs clarity on cybersecurity requirements, in particular on system and component supply chains. It should also create clarity and communality between critical infrastructure, as for example vendors defined as high-risk providers in 5G networks are currently building GW portfolios of energy storage assets across Europe. We are happy to provide further evidence to our submission to the European Commission, particular on energy storage cybersecurity, which we can not release within a public consultation.
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Meeting with Maroš Šefčovič (Commissioner) and

8 Apr 2025 · State of play on US-EU trade relations

Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

Please find our feedback below: Inclusion of energy storage under Art.26 NZIA In our understanding, auctions to deploy energy storage are not covered under Art. 26 of the NZIA. We see this as harmful oversight that will interfere with the creation of a harmonized procurement of clean tech in Europe. It is inconsistent with the objective of the NZIA to reduce supply chain dependency and increase manufacturing in Europe. The battery energy storage market in Europe is increasingly dominated by Chinese suppliers. Based on our analysis, we believe the market share of Chinese manufacturers for battery-based energy storage technology in Europe to have increased from approximately 4% in 2021 to 45% in 2024. Without non-price criteria on energy storage auctions in Europe, there is likely to be further increases in market share of and supply chain dependency on non-European suppliers. Not only does this hamper economic activity in Europe, but it also brings cybersecurity risks for the European energy sector. We ask the European Commission to apply prequalification requirements and non-price criteria also to energy storage auctions, either by amending the implementing regulation, or by addressing this topic via other means, such as the reform of the EUs state-aid framework. Article 5: Prequalification requirement on cybersecurity We agree with the Commissions assessment of the cybersecurity risks in the energy sector, which identifies severe risks from cybersecurity threats within the supply chain. We believe that prequalification requirements on cybersecurity should be clarified -- specifically which countries of equipment origin are being addressed, and which form cybersecurity defense plans should take. The EU, via a body such as ENISA could also develop a whitelist for suppliers qualifying as cybersecurity safe. We further agree on the threat that stems from operational control of renewable assets from countries of concern. We believe that operational control needs to be further defined and should include direct asset access and control via operation and maintenance contracts by cleantech OEMs. Direct asset control has to consider the threat potential from software updates by OEMs, especially those from countries of concern, and the need to prohibit or certify software updates by EU-based third-party agents to prevent compromising of operational control via software updates. It is vital that such strengthened cybersecurity rules need to apply to all assets connected to Europes critical energy infrastructure, including energy storage and renewable energy projects. Such measures should be taken for all projects connected to the grid including those developed outside of public procurements or renewable energy auctions. Article 6: Ability to deliver projects in full and on time We are aware of an increasing number of stranded energy storage projects in several European countries, where systems are not connected to the energy networks, due to a lack of capability of system OEMs to install and commission projects. We believe that the new prequalification requirements under article 6 should be appropriately defined to ensure that projects are only awarded if bidders can demonstrate that they and their system supplier can deliver projects (alternatively, there could be meaningful penalties for those projects that are not operational in a timely fashion). Non-price criteria We believe non-price criteria should be introduced for energy storage auctions. For energy storage, we believe that clear guidance on EU content would allow manufacturers to bring increasing portions of the value creation of energy storage technology into Europe. First, we would expect more of the systems integration work, including manufacturing of critical inverter equipment, to be completed in Europe. With the right policies, we would expect more and more the components to be manufactured in Europe, including battery cells.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

We welcome the opportunity to provide feedback to the European Commissions Delegated act on primarily used components under the Net-zero Industrial Act. We will focus our feedback on the primarily used components for energy storage and specifically battery-based energy storage technology as listed in the Annex to the Delegated Regulation. In our view, the subcomponent list for battery-based energy storage is too narrow, and excludes the full scope of battery based energy storage solutions as deployed into the European market. At the moment the list of subcomponents only focus on battery packs and modules. Those components constitute only the core part of energy storage solutions and are missing critical components for the manufacturing and deployment of energy storage products. For better illustration we would like to point to chapter 7 of the attached energy storage market briefing which we have developed for European policy makers. Figure 11 on page 21 shows that the battery module and its subcomponents only constitute 31% of capital expenditure for battery-based energy storage projects in Europe. This narrow definition is therefore not in line with the broader definition applied for other technologies on the component list. For solar for PV technology sub-components such as solar inverters but also junction boxes or PV trackers are included in the subcomponent list. To apply a similar level of granularity the list of subcomponents for battery-based energy storage technology should therefore be extended to comprise the scope of storage projects on an AC-block level, which would include the Battery BOP (Enclosure, HVAC/thermal management, BMS and EMS on container level, Safety equipment), as well as inverters and inverter controls. This approach has been used in the United States, where the IRA supports the following sub-components of energy storage assets: 1) Battery Pack/Module - Cells - Packaging 2) Inverter /Converter - Printed circuit board assemblies - Electrical Parts - Enclosrue & Skids 3) Battery Container/Housing - Enclosure - Battery Management System - Thermal Management System for Battery Container/Housing The exclusion of the wider sub-component list would result in a narrow focus on battery cell manufacturing and module packaging, which is currently highly dominated by China. The United States focus their manufacturing support and supply build up on the AC level of energy storage technologies. If Europe were to focus only on a narrow element, where European companies have a large competitiveness gap, it would undermine the AC-block integration capability and manufacturing in Europe, an area, where European manufacturers are still competitive, but are coming under increasing pressure from non-EU suppliers. As outlined in the attached market briefing, non-EU manufacturers have increased their market share for battery-based energy storage solutions on AC-block level from 4% to 45% between 2021 and 2024. Europe therefore has to strengthen the capability of the European industry to be not further loose competitiveness and market share in this critical AC-block integration of battery-based energy storage value chains. Keeping and strengthening the capability around AC-block integration has further a specific relevance in terms of strengthening cybersecurity safeguards. While non-EU AC blocks are fully equipped with IT hardware and software of countries of concern, this creates cybersecurity risks, which the EU is trying to reduce, e.g. as part of prequalification requirements under the Implementing Regulation on Non-Price Criteria of the NZIA. Including the full scope of AC-block subcomponents is therefore a key step to strengthen the competitiveness of European energy storage companies and acts as a safeguard on cybersecurity of Europes critical energy sector infrastructure. The mentioned briefing document includes confidential information and we can share it on request with the Commission.
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Meeting with Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen), Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

10 Feb 2025 · Clean Industrial Deal and Affordable Energy Action Plan

Meeting with Stefano Soro (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

13 Jan 2025 · Discuss the current state of the Battery Energy Storage System (BESS) market, pricing, and supply chain dynamics in Europe.

Meeting with Anna Stürgkh (Member of the European Parliament)

14 Oct 2024 · Energy Storage

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur) and ENEDIS and France Renouvelables

10 Oct 2023 · EMD

Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

20 Feb 2023 · Electricity Market Design Reform

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

20 Feb 2023 · Electricity market design reform

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

20 Feb 2023 · Electricity Market Design