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The EU’s Net-Zero Industry Act: Why a kW Is No Longer Just a kW

The EU’s Net-Zero Industry Act: Why a kW Is No Longer Just a kW

The European Union’s Net-Zero Industry Act (NZIA) is more than a regulatory framework.
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Martin Leenane

12th December 2025

The European Union’s Net-Zero Industry Act (NZIA) is more than a regulatory framework—it’s a clear signal that the economics of clean energy are entering a new era. The Regulation entered into force on 29 June 2024, and by 30 December 2025, Member States will be required to apply non-price criteria—such as sustainability, flexibility, and supply-chain resilience—to at least 30% of their annual renewable auction volumes.

This shift marks the beginning of a market where value is determined not by energy quantity, but by energy quality.

One of the most transformative elements is the requirement that at least 30% of procurement criteria in major clean-energy auctions must be based on non-price factors. Assets are no longer rewarded purely for cheap output—they’re rewarded for system value. And notably, adding storage, repowering, or hybridising an existing site will often move a generator into that 30% non-price category—especially when the upgrade is tied to a procurement process. Generators are now incentivised to deliver flexibility, resilience, and locational benefit, not just raw kilowatt-hours.

The message is clear:
A kW is no longer just a kW.

How NZIA Is Changing the Real Market: Industry Examples

🔋 1. Batteries: Turning Intermittent Assets into Flexible Assets

A 100 MW solar farm in Spain adds a 40 MW/80 MWh battery.
Suddenly, it can time-shift generation, relieve local congestion, and deliver grid services.
Under NZIA-aligned auctions, this hybrid asset performs far better—not because it’s cheaper, but because it’s more useful.

♻️ 2. Repowering: Bigger Output, Same Footprint

A 15-year-old wind farm replaces 2 MW turbines with 6 MW modern units.
The site becomes more stable, produces more consistently, and reduces curtailment.
Repowering is now a strategic move that boosts non-price scoring and grid value.

⚡ 3. Hybridisation: Getting More Out of Every Connection

A co-located wind-solar-battery project in Ireland spreads generation across more hours, maximises its connection point, and provides ancillary services.
This is exactly the type of project NZIA wants to promote: efficient, flexible, high-impact infrastructure.

The New Value Stack: What a kWh Is Really Worth

The New Value Stack: What a kWh Is Really Worth

NZIA accelerates a shift already underway: the market now prices electricity on three dimensions:

  1. Locational Value — Where it is generated

Does it relieve congestion or support a key demand centre?

  1. Temporal Value — When it is generated

Can it deliver during system stress, not just when the sun shines?

  1. Qualitative Value — How it is generated

Does it provide flexibility, stability, or sustainability advantages?

These criteria will increasingly determine procurement success, revenue certainty, and long-term project value.

From Commodity to Service

The market is no longer buying a commodity; it is buying a service with temporal, locational, and qualitative characteristics.

Electricity is becoming a differentiated product—one that values flexibility as much as raw output.

Implications for Developers

Under NZIA, developers who invest in:
  •  storage
  •  repowering
  •  hybridisation
gain a tangible competitive advantage in auctions and procurement.  The winning strategy is no longer “be the cheapest.”

It’s deliver the most system value.

Full Stack Energy: Your Partner in This New Market Reality

With NZIA now in force and its procurement obligations kicking in by the end of 2025, developers need to rethink how they design, optimise, and model their assets. Success depends on understanding the full value stack—temporal, locational, and qualitative.

This is where Full Stack Energy comes in.

We help developers, investors, and operators:

  • identify where value is highest
  • model hybrid and repowering strategies
  • quantify flexibility and system-service benefits
  • optimise projects for NZIA’s non-price scoring
  • turn assets into high-scoring, future-proofed infrastructure

If you want to position your pipeline for success in the NZIA era, let’s talk.
→ Full Stack Energy can help you build projects that don’t just generate power—they generate value.

Contact us.

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