A framework for electricity grid data exchange and reuse for AI foundation models : reflections on five implementation aspects

In July 2026, the European Commission presented a legislative proposal to amend the Electricity Market Regulation. Among the proposed provisions, a new Article 18a(5) foresees the establishment of a grid data exchange framework that enables the reuse of data for research and innovation purposes of developing, testing, integrating and deploying state-of-the-art technologies that support the efficient and safe operation of the grid. The proposal also specifies a series of tasks and obligations for the involved transmission and distribution system operators, and assigns to the ENTSO for Electricity and the EU DSO Entity the duty to define several implementation aspects. Moreover, the European Commission is empowered by the new Article 61(5b) to establish, by means of implementing acts, detailed requirements to enable the lawful, secure and controlled reuse of the exchanged energy grid data. This Policy Paper looks at the approach proposed by the European Commission and reflects on some of the implementation aspects it raises that will have to be addressed if the proposed reform is adopted. Assuming, as suggested by the reading of the Staff Working Document that accompanies the legislative proposal, that Artificial Intelligence (AI) foundation models for electricity grids are part of the state-of-the-art technologies to which the proposal refers, this Paper explores and provides initial answers to the following practical questions: 1) who participates in the establishment of the grid data exchange framework?; 2) who pays for the costs associated with the framework and the development of the AI foundation models?; 3) who owns the resulting AI foundation models and their output?; 4) who bears responsibility when harm results from the use of those models?; and 5) which elements are to be considered when designing the implementing acts under Article 61(5b)?