UFE's reply to the All Nemo Committee consultation around the Fallback concept for SDAC
23 April 2026
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UFE, the association representing the French Electricity, strongly supports the European Commission’s initiative to adopt an Electrification Action Plan, recognising that electrification is becoming a central objective of the European strategy.
Reducing our dependence on imported fossil fuels makes it both crucial and urgent to accelerate electrification, which is the key condition to address climate change while strengthening European competitiveness and independence. As electricity in Europe is already largely decarbonised[1] and produced domestically, accelerating electrification is a prerequisite for reaching carbon neutrality by 2050, ensuring our energy security and reducing the EU’s trade deficit (in 2024, fossil fuel imports still cost the EU around €375 billion).
Electrification is not just a technical transition: it is a pathway to cleaner air, quieter cities, better comfort at home, domestic jobs and stronger European resilience. It brings decarbonised mobility, efficient heating and cooling, and competitive industries powered by energy made in Europe. It is also one of the few scalable levers to reduce our dependence on fossil fuels, strengthen energy sovereignty, limit our exposure to prices linked to fossil-fuel markets, and contribute to making the European Green Deal a success story for both climate and society. To succeed, electrification must inspire public trust and enthusiasm, with a positive narrative that highlights its direct benefits for every consumer.
Despite this, the electrification rate of the European economy has stagnated at 23% for the past decade, far from the at least 50% required in all trajectories to achieve the 2050 objective. In this context, UFE welcomes the Commission’s KPI target of 32% by 2030 and calls for the Electrification Action Plan to be published swiftly and to provide a clear direction for Europe’s electrification. In particular, the European commission should develop a demand-side oriented policy framework that would support the reinforcement of the internal markets of clean technology.
UFE would like to provide recommendations for the Electrification Action Plan.
Our key asks :
The Commission’s target of 32% electrification by 2030 is a welcome milestone, even if it is rather a ceiling than a rooftop, but a target alone will not deliver change. What Europe now needs is a credible and operational plan to make this ambition tangible across all sectors.
The Electrification Action Plan must be published swiftly and should therefore:
Ensure the 32% electrification target is translated into clear sectoral breakdowns (industry, buildings, transport) within the NECPs. Establish common EU-level guidance to make national targets comparable and measurable, and introduce a monitoring mechanism to guarantee accountability and timely implementation.
Provide concrete roadmap of measures, with implementation timelines so that investors, consumers, and public authorities have predictable signals.
Establish a robust governance framework anchored in the revised Governance Regulation, empowering the Commission to monitor progress, provide targeted guidance, and ensure transparency through a European Observatory on Electrification, with annual reporting and Member State benchmarks. This Observatory should preferably rest on existing structures (EC or EEA) to avoid multiplication of reporting bodies.
Empowering consumers
The success of electrification hinges on active public and business engagement in shared goals: cutting greenhouse gas emissions, boosting EU competitiveness, strengthening energy sovereignty, creating quality jobs, and delivering tangible local benefits. To achieve this, the electric option must become the default and instinctive choice in every energy-related decision. This requires first and foremost, a strong effort to raise awareness and build trust. Citizens and businesses must clearly perceive the benefits of electrification in their daily lives. This can be achieved through:
Finally, empowering consumers to play an active role in the energy market is crucial for both social acceptance and system efficiency. This means:
Together, these measures would not only accelerate the adoption of electric solutions but also turn consumers into active partners of the energy transition.
Affordability
Affordability remains a key obstacle for electrification: access to electrical solutions (heat pumps, electric vehicles) remains insufficient, mainly due to their higher upfront compared to fossil fuel-based alternatives. Although economic incentives have been put in place to make them more affordable, these are often inadequate and not sufficiently targeted at the most economically vulnerable populations. In parallel, higher-income households are not sufficiently incentivised to adopt electrical solutions either. To bridge this awareness and competitive gap and encourage consumers to switch to electrical solutions, UFE recommends mobilising private funds to compensate the limited availability of EU funds and national budgets:
To this aim, UFE proposes a Tripartite Contract for Electrification, aimed at reducing upfront costs and accelerating the electrification of the mass market. This approach would empower Member States, on a voluntary basis, to mandate national entities to promote and finance electrification as a public good, by helping these consumers to switch to an electrical appliance.
The State would not finance the investment costs but mobilise private funds by providing a long-term guarantee against default risk, which evidence shows to be very limited. It is also worth noting that this mechanism would not have any link or impact on the Electricity Market Design. More precisely, this entity would:
Additionally, such a concept would build on existing tools and frameworks, reinforcing and streamlining part of the “aquis”, e.g. the one-stop shops mandated by the Energy Performance of Buildings Directive. It would also be a way to accompany the implementation of legislation such as the ETS2.
A ready-made legal basis, defined under Article 14 TFEU2, could be used. Recognised by DG COMP and already applied in areas such as affordable housing, this framework could be extended to electrification, given its strategic importance for Europe’s transition and independence.
Mobilising regulations and EU funds will also be crucial, notably to derisk investments in electrical solutions and provide regulatory certainty:
UFE strongly supports the establishment of a European Industrial Decarbonisation Bank, which is absolutely fundamental to shift the industry to electricity. To serve as a true driver for financing the industrial decarbonisation and deliver on the EU’s reindustrialisation ambitions, the Bank’s design should be guided by a number of clear and effective principles:
Support the reinforcement of electricity grids
A robust and resilient electricity network is essential for a successful
electrification. It is necessary to anticipate the modernisation, development, and adaptation of electricity grids, both at transmission and distribution level, to integrate new generation capacities, support the growth of electric uses, and address cybersecurity and climate adaptation challenges. The electricity system is also shifting towards a more decentralised and bidirectional system, with most of the electrified uses connected to the distribution grid, and the active participation of consumers. Therefore, in order to support the development of a modern and resilient transmission and distribution grid, UFE calls for:
Ensure the resilience of energy infrastructures
Ensuring that electricity, which is an essential public service, is available at all times is crucial. Despite this fundamental principle, climate change and extreme weather events (flooding, drought etc.), threaten the physical security of energy infrastructures, whether at the level of production capacities or transport and distribution networks. For instance, French system operators have faced a record of 16 storms in 2023. In this context:
Furthermore, cybersecurity risks management presents another major challenge for the security of critical energy infrastructures, especially in light of the deteriorating geopolitical context.
For electrification to accelerate and ultimately enable the achievement of our climate targets, EU policy and taxation frameworks must ensure a truly level playing field between low-carbon electricity and fossil fuels, while avoiding discrimination between different low-carbon technologies.
Policy & regulatory neutrality: the Electrification Action Plan must guarantee that a non-discriminatory approach is respected between all decarbonised electricity generation technologies – renewables (onshore and offshore wind, solar, hydro) and nuclear – to secure sufficient electricity supply for the transition. This principle must guide all policy, funding and regulatory frameworks supporting electrification.
Fair taxation: in many Member States, domestically produced electricity remains significantly more taxed than imported fossil fuels (in France, up to 4–11 times more, adjusted for CO2 emissions). UFE urges the swift finalisation of the revision of the Energy Taxation Directive, to ensure fiscal neutrality between energies and support decarbonisation, while reducing households’ electricity bills.
Conclusion : Electrification is the cornerstone of Europe’s energy transition, delivering on climate, competitiveness and sovereignty. The Electrification Action Plan is the opportunity to turn this potential into reality through a clear governance framework, fair market conditions, robust infrastructures, and accessible solutions for consumers and industry. UFE calls on the European Commission to seize this moment to make electrification the natural choice for Europe’s future.
1 According to the European Environment Agency, greenhouse gas emission intensity of electricity generation in the EU reached 210 gCO2e/kwh in 2023. It corresponds to a 58% drop compared to GHG intensity levels in 1990 and 19% compared to 2022 levels.