Named, Not Funded: who Europe’s electrification plan leaves behind

In a LinkedIn post, Marine Cornelis (Next Energy Consumer) and newest member of the board of eceee, writes about Europe’s recently announced Electrification Action Plan that recognises vulnerable households but does not provide the funding, safeguards or enforceable measures needed to protect them. It is unbelievable that during the hottest summer on record, a plan meant to prepare Europe’s homes for it, and the people it still leaves out.

 

Named, Not Funded

It is the hottest summer so far. Forty-five degrees in Spain, a new all-time record in Germany, cities that do not cool down at night, top-floor flats that turn into ovens. This is the Europe the Electrification Action Plan is supposed to prepare households for. It arrived last week: fifteen actions, a target of 46% electrification by 2040, and a diagnosis that is largely right.

That is how I read a plan like this. Once for what it says, once for who is missing. On the second reading, the same names come up that came up with April’s emergency plan. The renter who cannot get the vote for a reversible heat pump. The household heating with coal, off the gas grid.

Against that list, the plan scores like this. One silence became a real proposal. Four got named, then parked. Five did not move at all.

The one that moved

Start with the win, because it is real.

The electricity bill is not plumbing. It is a political document. Half of a household bill is the price of power, a quarter is network charges, a quarter is taxes and levies. Design those three badly and the bill sorts people by who can keep up. Design them well and it can do the opposite.

This plan finally touches the network quarter. The Commission adopted a network-charges proposal alongside it, aimed at the electricity-to-gas ratio, with time-of-use signals and a target to pull that ratio below 2.5 for households. That is a real move, on the exact mechanism that has made electrifying more expensive than staying on gas. Worth saying clearly, without hedging.

Then comes the taxation section, and the fix goes home. Reform there is something Member States “can” do. “Electricity should not be taxed more than gas” is written as a principle, not a floor. The Energy Taxation Directive that would settle it has been stuck since 2021, and this plan does not move it. The network quarter gets a proposal. The tax quarter gets a sentence.

Named, not funded

The most consumer-facing part of the plan is Annex II, the guidance on social leasing and on-bill finance. These are the tools that can put a heat pump in a low-income home without a €15,000 cheque upfront, and they matter.

They also come with conditions the annex mostly skips. Social leasing works as a bridge when it is publicly backed, carries clear consumer rights, and protects tenants. On-bill finance is riskier, and should never replace tailored subsidies. And there is a quiet trap under both: these contracts often fall outside EU consumer law, including the Consumer Credit Directive. No guaranteed dispute resolution, unclear end-of-contract terms, and hidden costs that a single radiator upgrade can push into the thousands.

The plan takes the instruments and leaves the safeguards in the drawer. The renter, the coal household, cooling, shared solar for the apartment block are all there, and all optional, filed as things Member States “could consider.” The tools are aligned with the goal. The protection that decides whether the tool reaches anyone is not.

This is the pattern worth naming, because it repeats. A Commission can learn to name a problem long before it agrees to fund the fix. Naming is cheap and generous; instruments are expensive and contested. And the gap between them is not sloppiness. It is where competence sits. Taxation, tenancy law, consumer protection, network levels are all Member State ground. The Commission can name, guide and target. It cannot mandate. Named, not funded, is what you get when the will is there and the power is not.

The lock the plan walked past

The hardest version of this is the ordinary building. It is easy to electrify a flagship site. It was the question that kept coming up at the New European Bauhaus festival in June: how do you scale it to an ordinary Parisian block, six owners, a condo meeting, a heritage rule against touching the façade, and over forty degrees outside?

The plan names the barrier. Annex II says address the split incentive, protect tenants from eviction. Then it leaves the thing that actually decides whether that flat gets a heat pump, the vote in the condominium and the landlord’s yes, to national discretion. In several countries the homeowners’ association is not even a legal entity, so it cannot take the loan. The person who most needs the heat pump has the least control over the wall it hangs on. Naming the split incentive without touching the decision rule is naming the barrier and walking past the lock.

Still silent

Five silences held. Two are worth dwelling on, because the heat this month makes both concrete.

The first is flexibility. The plan rewards households for shifting load in response to price and network signals: dynamic tariffs, demand response, storage. But a household running a single fan through a heatwave has nothing to shift. When flexibility becomes the price of fair treatment in the retail market, inflexibility becomes a tax on the already-exposed. This is not intuition. Poorly designed dynamic tariffs can raise bills by up to a fifth for households that are sick, low-income, or simply not free to move their demand. A plan can reward flexibility, or it can protect the people who cannot flex. This one rewards, and stays quiet on the rest.

The second is the gas endgame. As better-off households leave the gas grid, the fixed cost of the pipe is spread over a shrinking, poorer base. Somebody pays to keep the last network warm, and it is the household too poor to leave it. The plan is fluent on grids for data centres and heat pumps. On who carries the cost of the pipe we are retiring, it is silent.

Cooling sits between the columns, half-moved. In a summer like this one, cooling is not comfort, it is survival. Heat is the quiet killer of people the system does not see, and the households cooking in top-floor flats sit outside almost every official definition of “vulnerable.” What we do not measure, we do not fund. The plan gives cooling an Action Plan and a reversible heat pump in an annex. That is a start, not a right, and the distance between the two is measured in people.

Citizens, once

Step back, and the longer pattern shows.

In the Citizens Energy Package, we were citizens, and the word named real people. In April’s emergency plan, we were consumers again. In this one, framed as sovereignty and competitiveness, we are an asset in an industrial strategy, benefiting by spillover. Across three documents in eighteen months, the citizen appears once and retreats twice.

There is a simpler way to put the whole problem. Europe is still regulating for yesterday’s consumer, the winter-heating, bill-paying, grid-following household of the 2010s, while the consumer actually in the room is heat-exposed, often inflexible, frequently outside the indicators, and not naturally trusting of schemes that have not trusted them first. The New European Bauhaus keeps insisting that what is sustainable must also be affordable and accessible, that vulnerable households should not be handed the cheapest, ugliest version of the transition and told to be grateful. That register is missing from a plan built for the value chain. And exclusion is not neutral.

People written out of the plan do not stay neutral about it.

What would change my score

The network-charges text is being drafted now. It is the live document. So this is for the people writing it.

First, a no-harm floor: where a dynamic charge cannot be guaranteed not to raise the bill of a household that cannot flex, it should not be the default.

Second, take the four names out of the annex. Give at least one of them, the renter, the coal household, cooling, the apartment block, an instrument with money, consumer-law coverage and tenant protection attached, and “could consider” becomes a commitment.

Do that, and the score changes to four, publicly and gladly. Until then, the sentence stands. Named is not funded. Not just for the smart and savvy, but for every household in Europe.

References

Electrification Action Plan, COM(2026) 595, and Annex II on social leasing; AccelerateEU, COM(2026) 370; Citizens Energy Package, COM/2026/115; the network-charges legislative proposal adopted alongside the plan. Related work: “Electricity tariff design” (HBS EU / Green European Foundation, 2024); “Can heat pumps be accessible for all?” (HBS EU, 2025); “Framing summer energy poverty” (European Commission, 2025); “Is Europe regulating for yesterday’s energy consumer?” (2026). On dynamic tariffs and vulnerability: Dudka et al., “Flexibility as a justice fix?”, Energy Research & Social Science 134 (2026).

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