France's NEBCO mechanism lets electricity demand compete on energy markets through explicit changes in consumption. A flexibility project can now account for both the event and the associated recovery period, provided that the declared programme, control method and metering path meet the market rules.
That distinction matters for buildings, cold stores, industrial processes, batteries, thermal storage and EV charging. Reducing power during one interval can cause a rebound later. NEBCO can recognise that shifted energy, but it does not turn every increase in consumption into a flexibility service.
What NEBCO changed
The French Energy Code defines demand response as a temporary reduction in actual withdrawal, measured against a forecast programme or estimated consumption. It also recognises that this reduction can increase consumption before or after the event.
NEBCO calls these actions consumption modulations:
| Modulation | What happens at the connection point | Typical operational example |
|---|---|---|
| Downward modulation | Consumption falls below the approved reference during the event | An HVAC chiller, process load or charging fleet reduces demand |
| Upward modulation by anticipation | Consumption rises before the reduction because useful work is brought forward | A cold store pre-cools before a reduction |
| Upward modulation by deferral | Consumption rises after the reduction because useful work was postponed | EV charging resumes after a constrained interval |
An upward modulation is tied to load shifting around a reduction. Chapter 5 limits the absolute upward volume so it cannot exceed the downward volume over seven calendar days for remotely read demand-response entities and two calendar days for profiled entities. The programme uses positive values for downward modulation and negative values for upward modulation.
The rules contain notified implementation dates for the ability to declare upward modulation and for each eligible control method. RTE's current service page lists upward modulation for the corrected double-reference rectangle, forecast, history and panel methods, with a separate notified date still referenced for the corrected double-reference method. Check the current Chapter 5 text and RTE notifications for the intended delivery date rather than assuming every deferred provision is active.
NEBCO is a market arrangement, not an automatic site tariff
NEBCO can value modulation through bilateral energy trades or the day-ahead and intraday exchanges. It separates the flexibility service from the site's electricity-supply contract. French law allows an approved demand-response aggregator to act without the electricity supplier's agreement.
Several parties still have defined roles:
| Party | Main role |
|---|---|
| Consumption site | Provides the flexible load, authorises required data access and agrees the operating constraints |
| Demand-response operator | Builds the demand-response perimeter, declares programmes, controls the load and carries the participant duties |
| RTE | Operates NEBCO, retains programmes, establishes reference curves, certifies realised modulation and performs the market calculations |
| Distribution network operator | Manages site attachment checks and supplies official load curves for distribution-connected sites |
| Balance-responsible party | Receives the retained programme and realised modulation in its balance perimeter |
| Electricity supplier | Supplies the site and receives the applicable payment for energy treated under the demand-response settlement model |
The operator needs a participation agreement and a valid technical approval for consumption modulation. Its declared and realised programmes must be attached to a balance-responsible perimeter, unless it participates as a balance-responsible party itself. The technical approval process includes evidence from at least three downward-modulation command tests and verification of the command chain.
A declared programme is a daily load curve at the control interval and to kilowatt precision. Each non-zero value must have an absolute value of at least 100 kW. This is a programme threshold for the demand-response entity, not a statement that every participating site must be 100 kW on its own.
Profiled sites without a communicating network meter have a separate operator qualification process. The Chapter 5 submetering provisions are also a specific experiment with operator and site qualification. A generic claim that a portfolio is “NEBCO ready” hides these differences.
The reference curve determines the delivered modulation
RTE does not certify an event from the operator's requested setpoint alone. For each control interval, it compares the entity's consumption curve with an approved reference curve. A downward modulation exists when consumption is below the reference. An upward modulation exists when consumption is above it, subject to the programme, method and capacity limits.
The available control methods are not interchangeable:
| Method | Downward modulation | Upward modulation | Main boundary to confirm |
|---|---|---|---|
| Corrected double-reference rectangle | Yes | Subject to the notified implementation date | Reference before and after the event, with the rule selecting the applicable value |
| Consumption history | Yes | Yes under the current service description | Historical eligibility and homologation of the site |
| Consumption forecast | Yes | Yes under the current service description | Forecast submission and homologation of the site |
| Site-by-site algebraic rectangle | Yes | No | Suitable site composition and measurement record |
| Representative panels | Yes | Yes under the current service description | Eligible profiled population and the approved representative panel |
CRE approved the panels method for profiled sites. It compares controlled sites with a representative group, avoiding the assumption that a small site's normal demand can always be reconstructed from its own short history.
For the history and forecast methods, the reference construction is the same for upward and downward modulation. For the corrected double-reference method, the higher of the initial and final references is selected for upward modulation, while the lower reference applies to downward modulation.
Record the method against each demand-response entity. A technically plausible baseline calculated in a building platform cannot be substituted for the method assigned under the market rules.
Official metering and operational telemetry have different jobs
Chapter 5 sets a 15-minute measurement interval for low-voltage distribution sites at or below 36 kVA. It sets a 5-minute interval for higher-power low-voltage and high-voltage distribution sites and transmission-connected sites.
For a remotely read distribution site, the consumption curve normally comes from the distribution network operator's metering installation. The network operator collects the site-level load curve and transmits it to RTE. For a transmission-connected site, the normal source is RTE's metering installation.
Qualified submetering can be used only within the specific Chapter 5 experiment and only when both the operator and site hold the required qualification. If those conditions are not met, operator-supplied submeter curves are not used for certification. Missing a required qualified-submeter submission can prevent modulation from being certified for the period.
An operational monitoring system has a different and still useful job:
- show whether the flexible asset was available before dispatch;
- record command issue, receipt, acknowledgement and expiry;
- measure site import and the asset's own power at a faster interval;
- preserve operating mode, limits, state of charge, temperature and alarms; and
- explain why certified delivery differed from the requested response.
Keep the market meter identity, network load curve, operator telemetry and final certified volume as separate records. Reconcile them over complete intervals. Do not replace missing telemetry with zero, and do not overwrite the raw event history when RTE or a network operator later corrects the official data.
The 2026 update changed supplier-payment formulas
The current general provisions took effect on 1 January 2026. CRE Decision 2025-275 approved changes to the fixed supplier-payment formula for remotely read sites under the regulated model because ARENH and the previous capacity mechanism were ending in 2026. The updated formula uses two-year averages of baseload and peakload market quotations and adjusts the capacity-obligation component.
That update concerns the financial flow to affected suppliers. It did not replace the Chapter 5 process for site attachment, programme declaration, reference construction or certification of realised modulation. Keep commercial settlement assumptions versioned separately from the control design.
Build one auditable event record
A useful event record connects the market instruction to the physical result without confusing them.
| Layer | Record to retain | Purpose |
|---|---|---|
| Site identity | Connection point, network operator, meter identifier, supplier and operator | Fixes the market boundary |
| Demand-response entity | Entity identifier, sites, control method, maximum modulation capacity and effective dates | Fixes the certification contract |
| Programme | Direction, requested volume, control intervals and retained-programme status | Records what entered the market process |
| Dispatch | Asset command, issue time, receipt, acknowledgement, expiry and release | Shows what the site controller was asked to do |
| Operation | Site power, asset power, state, limit, alarm and data-quality flags | Shows what physically happened |
| Certification | Reference curve, consumption curve, realised downward or upward modulation and revisions | Records RTE's delivered-volume result |
| Settlement | Accepted quantity, supplier payment model, balance allocation and final status | Records the commercial result |
Use one documented time standard and retain source timestamps. A five-minute market interval and a one-minute controller series can only be compared when interval starts, interval ends, time zone and daylight-saving handling are explicit.
Set safe control boundaries before enabling writes
Start read-only. Measure the connection point and the flexible asset, verify sign convention and scaling, and compare operational totals with the network data available through the operator. Test missing values, late values and clock drift.
Enable control only when all of these are defined:
- the demand-response operator's dispatch interface, authentication and acknowledgement contract;
- the equipment manufacturer's documented writable command, units and permitted operating modes;
- local electrical, process, comfort and equipment protections that retain final authority;
- the priority between market dispatch and production, safety, maintenance or occupant needs;
- a command expiry, release condition and safe state after communication loss; and
- commissioning tests for full delivery, partial delivery, rejection, timeout, recovery and rebound.
A readable register does not prove that the adjacent register is safe to write. A demand reduction also does not justify an uncontrolled rebound. Thermal stores, batteries, chargers and production loads each need limits on duration, recovery power and the energy state required after the event.
Where EpiSensor fits
EpiSensor can measure the site boundary and equipment feeders, collect documented controller states and retain time-aligned operational data on site. Edge can exchange an approved dispatch and acknowledgement over a documented interface when the complete market and equipment-control design permits it.
This supports availability checks, event diagnosis and reconciliation with the official load curve. It does not issue the technical approval, create the approved reference curve, qualify submetering, register the demand-response entity or calculate NEBCO settlement.
Use the demand response baseline guide to document the counterfactual and event interval. Use the operational and settlement metering guide to keep site telemetry separate from the official market record. Then use System Builder to map the measurement points, equipment interface and safe control boundary.
Common questions
What replaced NEBEF in France?
The NEBCO rules replaced NEBEF on 1 September 2025. NEBCO retains explicit demand reduction and adds a framework for valuing some increases in consumption caused by anticipating or deferring load around a reduction.
Can NEBCO pay a site simply to consume more electricity?
No. An upward modulation under NEBCO is an anticipation or deferred use associated with a demand reduction. The rules constrain declared upward and downward volumes over defined periods. Confirm that the selected control method and any notified implementation date allow upward modulation before relying on it.
How does RTE measure delivered demand flexibility?
RTE compares a reference load curve with the consumption curve for the demand-response entity. The applicable method can use corrected double-reference rectangles, consumption history, a consumption forecast, a site-by-site algebraic rectangle or representative panels. The method determines which modulation types can be certified.
Can a building meter or IoT gateway provide the NEBCO settlement record?
Usually no. For remotely read distribution sites, the rules normally use load curves from the distribution network operator's metering. Qualified submetering is a defined experimental exception. Site telemetry remains valuable for dispatch, availability and fault investigation, but it must be kept separate from the official certification record.
Does monitoring equipment make a site eligible for NEBCO?
No. Eligibility and settlement depend on the operator's agreements and approvals, the site's inclusion in a demand-response entity, the selected control method, official metering and the current market rules. Monitoring equipment can support the operator with time-aligned operational evidence.