Balancing Responsible Group And Aggregation In The Electricity Market

1. Introduction

Balancing, settlement, and responsibility mechanisms in the electricity market operate within an integrated system established by the Electricity Market Law No. 6446 ("Law") and the secondary legislation enacted pursuant to this Law. Within this system, the Balancing Responsible Group ("BRG") emerges as a specific structure that gains its legal character particularly under the Regulation on Balancing and Settlement ("RBS"), the Market Operation Procedures and Principles, and the Energy Markets Operation Joint Stock Company ("EPİAŞ") Market Management System ("MMS") regulations, enabling the management of imbalance responsibility of generation and consumption facilities under a single portfolio. Although the concepts of BRG and aggregation are often mentioned together in the electricity market, they are clearly distinct in terms of their legal nature, scope of responsibility, and functions within market operations. This article focuses on the relationship between BRG and aggregation in the electricity market, as well as their legal characteristics and differences.

2. Concept and Legal Nature of the Balancing Responsible Group

From a legal perspective, a BRG is a structure lacking legal personality, designed as a mechanism that enables the consolidation of imbalance responsibilities of market participants under a single "responsibility pool." The Balancing Responsible Group Responsible Party ("BRGRP"), who acts as the manager of the BRG, is the sole counterparty of the group before the Turkish Electricity Transmission Corporation ("TEİAŞ"), EPİAŞ, and the Market Financial Settlement Center ("MFSC"), and is the only actor that may be held liable for the entire imbalance of the group. Pursuant to Article 99 et seq. of the RBS, the BRGRP is obliged to submit balancing notifications through the MMS, make forecast and schedule submissions, and operate the internal imbalance allocation mechanism within the group.

The function of a BRG is to net the deviations arising from generation and/or consumption units within the scope of the group at the group level, thereby creating a lower total imbalance cost. This structure enables, in particular, small-scale generators and interruptible consumption facilities to participate in the market with a reduced operational burden. As the BRG constitutes a responsibility mechanism related to maintaining system balance, the relationships between the BRGRP and the facility owners participating in the BRG are, as a natural consequence, not public law relationships but are entirely of a private law nature. Accordingly, the conditions for participation in the BRG, methods for allocating imbalances, accrual processes, data sharing, penalty clauses, and payment obligations shall be determined by a participation agreement. Since EPİAŞ and TEİAŞ do not intervene in the internal private law relationships of the BRG, the sole counterparty of these institutions, from a regulatory perspective, is the BRGRP.

3. Aggregation Mechanism and Its Place in the Legislation

Aggregation, which was given a statutory basis through the amendment introduced to Article 12/A of the Law on 22 December 2022, was subsequently regulated by the Regulation on Aggregation Activity in the Electricity Market published in the Official Gazette on 17 December 2024. Although aggregation is a relatively new concept and intersects with the concept of a BRG in terms of purpose, they represent distinct market roles. From a legal standpoint, aggregation is addressed within the scope of the Electricity Market Licensing Regulation, the Regulation on Balancing and Settlement, and the relevant Demand Side Participation regulations. It refers to the consolidation of the commercial, technical, and operational processes of small-scale facilities under a single portfolio and their centralized management through MMS. In this context, the aggregator assumes obligations such as carrying out data collection, meter reading, and forecasting processes, submitting balancing notifications, and transmitting the required notifications to EPİAŞ and TEİAŞ. Although the generation and consumption data of legal entities processed in this process do not technically constitute personal data, the confidentiality provisions of participation agreements are of critical importance due to the extensive amount of information that must be regarded as trade secrets.

4. Difference Between BRG and Aggregation

As stated above, a BRG constitutes a "responsibility pool" established for the purpose of netting the imbalances of market participants on a group basis. Accordingly, the BRG itself is not a revenue-generating market actor; rather, it is essentially an operational structure aimed at minimizing imbalance costs. Aggregators, on the other hand, are independent market participants defined under the Law and secondary legislation, capable of engaging in commercial activities in demand side participation, ancillary services, and the balancing market. This fundamental distinction results in the BRG creating economic value through cost reduction, whereas aggregation generates value directly through market participation and commercial transaction volume.

By contrast, aggregation activity is a service-oriented function focusing on organizing demand side participation on behalf of small-scale consumers and/or distributed generation facilities, pooling portfolios under a single structure, enabling the trading of flexibility capacity, and facilitating participation in the balancing power market. Accordingly, while the BRG undertakes an obligation aimed at maintaining system balance, the aggregator primarily acts as an interface that optimizes demand side participation and flexibility services. This distinction is of critical importance in practice for determining the chain of responsibility, allocating imbalance costs, conducting MFSC transactions, and managing registration and reporting obligations before EPİAŞ. Furthermore, in order to prevent excessive market concentration, the Energy Market Regulatory Authority has introduced an upper limit of 2,000 MW for aggregator portfolios, thereby aiming to prevent large-scale portfolios from being consolidated under a single entity in a manner that could distort competition.

5. Conclusion

In conclusion, the BRG and aggregation mechanisms are two distinct structures within the electricity market, each possessing different legal identities, economic motivations, and operational functions. A BRG is a responsibility pool without legal personality, aimed at achieving cost efficiency by netting imbalances on a group basis, and operates as a closed structure in which the BRG Responsible Party is the sole counterparty vis-à-vis public authorities within the framework set forth under the Regulation on Balancing and Settlement. In contrast, aggregation is an independent market role that may engage directly in commercial activities, aiming, pursuant to the Law and the relevant secondary legislation, to render demand side participation, distributed energy resources, and flexibility services manageable by the market. Recent draft regulations indicate that aggregation is increasingly viewed as a more functional instrument in terms of system operation and grid security, and that there is a policy tendency toward limiting the BRG mechanism in the long term. Accordingly, it is expected that the Turkish electricity market in the coming period will be shaped around an aggregation-based model centered on flexibility management and demand side participation, rather than on the operational consolidation of imbalances through BRGs.

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