SHERIDAN, WYOMING - March 31, 2026 - Danish gas tariff decisions in 2026 face a more demanding transparency test, with direct implications for how shippers, storage users and regulators evaluate network charges tied to upstream infrastructure. ACER's latest report reviews Energinet's proposed reference price methodology under the EU Network Code on Harmonised Transmission Tariff Structures and finds that while several core design elements align with the rules, the cost treatment of the upstream Baltic Pipe section cannot yet be fully assessed because key detail is missing.
What ACER found in the Danish tariff review
The report examines Energinet's proposal to keep a uniform postage stamp reference price methodology with an ex-post entry-exit split and storage discounts. It also reviews the continuation of capacity-based tariffs only, meaning users would continue paying on the basis of booked network capacity rather than the volume of gas transported. Energinet's proposal further maintains the existing joint market zone that integrates the upstream section of the Baltic Pipe into the Danish entry-exit zone.
ACER concludes that the proposed methodology meets EU requirements on transparency, non-discrimination and volume risk. At the same time, it says compliance with cost-reflectivity, the avoidance of cross-subsidisation and the prevention of cross-border trade distortions cannot be fully determined because the consultation material does not provide enough detail on the upstream infrastructure. The agency also says there is insufficient information to assess whether pricing for the upstream non-transmission services complies with network code principles.
Business impact
Procurement leads and gas portfolio managers now have a clearer signal that 2026 tariff planning in Denmark cannot rely only on the headline transmission methodology; they also need to test how separate upstream Baltic Pipe charges are justified and allocated. Where infrastructure costs are recovered from transmission network users through a non-transmission tariff, sourcing teams must examine whether those charges could affect route economics, storage usage and booked-capacity decisions across the Danish market zone.
Regulatory affairs teams and network tariff specialists face a more immediate compliance task. ACER is explicitly pushing for the upstream Baltic Pipe to be subject to transparency and scrutiny similar to the main transmission network because its costs are also borne by transmission network users. That matters for cross-border trade and budget cycles in 2026: if the underlying cost detail remains limited, companies moving gas through Denmark may need to build greater tariff sensitivity into vendor selection, contracting and hedging decisions. The Baltic Pipe's link between Norwegian gas and Poland via Denmark gives the issue broader supply-chain significance because cost allocation on this route can influence how market participants assess access conditions in the wider regional corridor.
Key recommendations for Denmark's final decision
ACER recommends that the Danish national regulator, DUR, ensure the upstream Baltic Pipe is overseen with transparency and scrutiny comparable to the main transmission network. That recommendation is tied directly to cost recovery: the report stresses that these upstream infrastructure costs are covered by transmission network users, so the supporting detail must be robust enough to evaluate whether pricing follows network code principles.
The agency also advises handling emergency supply tariffs separately from standard network fees because they pay for a security-of-supply service provided directly to end users rather than to network users. In addition, ACER says discounts for interruptible capacity should be adjusted using the network code formula so they better reflect the actual risk of interruption. For market participants, that means the final Danish decision will matter not just for tariff compliance, but for how interruptible products are priced and compared with firm capacity in 2026 booking strategies.