This paper offers a comparative analysis of the transposition of the EU Renewable Energy Directive (RED II) in Italy and France, examining two distinct institutional paradigms for the energy transition. While both legislative frameworks aim to democratise the energy landscape through Renewable Energy Communities, they diverge significantly in how they implement proximity, governance, and energy-sharing. Italy has adopted an incentive-centric model, marked by flexible plant ownership and the development of “umbrella RECs” that operate across expansive market zones, prioritising economic support mechanisms. France, by contrast, employs a framework that requires mandatory collective self-consumption within strictly defined geographical boundaries, obliges communities to retain ownership of their production assets, and fosters local energy markets without relying on direct national subsidies. Building on the European Court of Auditors' warnings that the EU risks missing its 2025 targets because of legal ambiguity and infrastructure “gridlock”, this study assesses the structural and regulatory effectiveness of both models. It finds that, while the Italian model incentivises rapid adoption through economic mechanisms, the French approach may offer more durable local markets -though this advantage remains to be empirically confirmed. Both systems, in any case, face regulatory deficiencies that threaten the inclusivity and scalability of the wider community energy movement.
Proximity, Control, and Shared Energy: A Comparative Analysis of Renewable Energy Communities in Italy and France
daniela pappada'
2026-01-01
Abstract
This paper offers a comparative analysis of the transposition of the EU Renewable Energy Directive (RED II) in Italy and France, examining two distinct institutional paradigms for the energy transition. While both legislative frameworks aim to democratise the energy landscape through Renewable Energy Communities, they diverge significantly in how they implement proximity, governance, and energy-sharing. Italy has adopted an incentive-centric model, marked by flexible plant ownership and the development of “umbrella RECs” that operate across expansive market zones, prioritising economic support mechanisms. France, by contrast, employs a framework that requires mandatory collective self-consumption within strictly defined geographical boundaries, obliges communities to retain ownership of their production assets, and fosters local energy markets without relying on direct national subsidies. Building on the European Court of Auditors' warnings that the EU risks missing its 2025 targets because of legal ambiguity and infrastructure “gridlock”, this study assesses the structural and regulatory effectiveness of both models. It finds that, while the Italian model incentivises rapid adoption through economic mechanisms, the French approach may offer more durable local markets -though this advantage remains to be empirically confirmed. Both systems, in any case, face regulatory deficiencies that threaten the inclusivity and scalability of the wider community energy movement.
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