Legislation and Regulation as Enabler for Flexible Energy Storage in Building Masses

The transition toward a climate-neutral European Union by 2050 requires buildings to evolve from passive energy consumers into active flexibility assets. This presentation examines how forthcoming European legislation—particularly the EPBD recast, RED III, EED, and Electricity Market Design reform—can enable large-scale integration of Thermally Activated Building Systems (TABS) and other mass-based storage technologies within the 15-minute electricity market framework. Drawing on Task 43 interviews across Germany, Denmark, Belgium, and Spain, the study identifies four non-technical levers for unlocking building-mass flexibility: regulatory recognition, market access, skill development, and demonstration. Empirical evidence shows that predictive control of TABS can shift 4–6 kWh/m²·day with minimal comfort deviations (ΔT < 0.5 K), providing an EU-wide potential of 10–12 GW of short-term flexibility—comparable to the output of large pumped-hydro fleets. Yet, current EPBD and EPC methodologies remain quasi-static, excluding dynamic storage behavior and preventing financial valorization. Policy recommendations include integrating thermal-storage indicators into the EPBD Annex I and Smart Readiness Indicator, reducing aggregator thresholds below 100 kW, and establishing EU programs for “Flex-Ready Buildings.”