Counsel Rome
"The widening disparity in energy prices between the EU and its main global competitors poses a tangible threat to the EU’s international competitiveness."
The widening disparity in energy prices between the European Union (“EU”) and its main global competitors poses a tangible threat to the EU’s international competitiveness.¹
As highlighted in the Action Plan for Affordable Energy (“the Plan”), this imbalance undermines the EU’s position in global markets, compromising its ability to attract investment and sustain long-term economic growth.
In response, the European Commission (the “Commission”) has identified the reduction of energy costs for citizens, businesses and industries across the EU as a key priority of the Plan. The increasing digitalisation of the energy sector is recognised both as a strategic lever and a potential risk factor within the energy value chain (transport, distribution, supply and consumption).
Proposed Solution: The Strategic Roadmap for Digitalisation and Artificial Intelligence in the Energy Sector
To address these challenges, between 5 August and 5 November 2025, the Commission launched a public consultation (“the Consultation”) aimed at defining a ‘Strategic Roadmap for Digitalisation and Artificial Intelligence in the Energy Sector’ (“Strategic Roadmap”).
The Commission’s objective is to accelerate the deployment of European AI-based solutions in three key areas for decarbonisation:
- optimisation of electricity grids;
- energy efficiency in buildings and industrial processes; and
- greater flexibility in energy demand.
The Strategic Roadmap, expected in the first quarter of 2026, will form part of the broader EU legislative framework – including the AI Regulation (Regulation EU 2024/1689), the NIS 2 Directive (Directive 2022/2555), and the Cyber Resilience Regulation (Regulation EU 2024/2847) – and align with strategic initiatives under the European Green Deal, REPowerEU and the Digital Decade.
Consultation Highlights
According to published data, the Consultation gathered 145 valid contributions, mainly from:
- companies/businesses: 31.72% (46 contributions);
- business associations: 26.21% (38 contributions);
- EU citizens: 17.93% (26 contributions); and
- non-governmental organisations (“NGOs”): 8.28% (12 contributions).
The predominance of business contributions reflects their greater need, compared to other stakeholders, to adapt to new regulations and seize opportunities arising from the digital transition.
Key Business Concerns
Among the main issues and concerns raised by businesses are the following:
- data access and cybersecurity: businesses call for a balance between data interoperability and the protection of security and confidentiality within energy systems, which are increasingly exposed to cyber risks. Particular emphasis is placed on strengthening cybersecurity skills, including through EU-funded initiatives, to prevent cyberattacks;
- regulatory simplification: there is a strong call to avoid regulatory overproduction and overly complex or incomplete national procedures that could cause delays or uncertainty in project implementation. Businesses also request that high-risk AI systems are not interpreted too broadly to avoid stifling innovation;
- consultation and knowledge sharing: companies advocate for platforms to share best practices and for an EU-wide stakeholder consultation, fostering structured dialogue with regulatory authorities;
- resources and incentives: some businesses suggest allocating more resources to EU programmes supporting digitalisation, incentivising the adoption of digital technologies through cost-recovery mechanisms, and increasing investment in clean-tech start-ups; and
- reskilling: despite AI’s potential, human oversight remains essential: maintenance, data interpretation and plant management require specialised and up-to-date technical skills. Businesses therefore call for targeted reskilling programmes aligned with the needs of the energy transition.
"Defining the Strategic Roadmap will be a pivotal step in integrating AI and digital technology into the energy transition, whilst ensuring resilience and consumer data protection."
Outlook and Conclusions
EU initiatives on energy affordability and digitalisation outline an ambitious path towards a more competitive, secure and sustainable energy system. Defining the Strategic Roadmap will be a pivotal step in integrating AI and digital technology into the energy transition, whilst ensuring resilience and consumer data protection.
Pending the final document, businesses are already expected to assess the opportunities and risks of digitalisation processes and implement these technologies responsibly, in full compliance with EU and national regulatory frameworks.
[1] The European Commission has emphasized how the high cost of energy is significantly affecting not only the daily lives of European citizens – with over 46 million people living in so-called “energy poverty”- but also the entire production system. In 2023, for instance, electricity tariffs for industrial users almost doubled, recording an increase of 97% compared to the average for the 2014–2020 period.
Key contacts
Counsel Rome
Associate Rome
