This service is for suppliers, traders, BRPs, aggregators, and large consumers who receive imbalance settlement reports or balancing invoices and need a clear, documented position. We review the data and methodology, build the evidence file, and help you choose the right route: correction request, formal objection, negotiation, regulatory steps, or litigation.
The information is general and does not replace legal advice. Facts, documents and chronology matter.
When you need this
- You received an imbalance settlement invoice and you need to verify the calculation and inputs.
- Imbalance costs increased unexpectedly compared to schedules and forecasts.
- You suspect metering or allocation errors, missing corrections, or wrong portfolio mapping.
- A counterparty disputes contractual pass-through of balancing costs (supplier vs customer, trader vs counterparty).
- Credit limits, suspension, or collateral requirements are triggered by unpaid balancing charges.
- A short deadline applies for objections, data corrections, or dispute notices.
- You want to negotiate a payment plan or set-off while preserving your rights.
- You need to assess recourse against service providers (forecasting, aggregation, BRP services) or internal process gaps.
What we do in practice
- Identify the settlement chain (TSO, settlement operator, BRP, market participant) and the governing documents for the invoice.
- Reconcile metering data, schedules, nominations, notifications, and settlement statements in one chronology.
- Check whether the applied methodology matches the applicable ANRE rules and market documents.
- Flag issues that can be corrected administratively (meter correction, reallocation, data resubmission) and document them.
- Draft objections, notices, and reservation of rights letters, with a clear evidence map.
- Support negotiations on payment, offsets, and operational solutions, without unintended waivers.
- Assess regulatory routes (where relevant) and align the case file for any authority communication.
- Prepare dispute strategy for court or arbitration: claim framing, evidence, expert needs, and risk controls.
Documents / information useful for the first review
| Document | Why it matters | Notes |
|---|---|---|
| Imbalance invoice(s) and settlement statements | Shows amounts, periods, and the formal basis used for settlement | Include annexes and any referenced methodology |
| Metering data (raw and validated) and corrections | Core input for allocations and imbalance volumes | Keep versions, timestamps, and correction requests |
| Schedules, nominations, and notifications | Used to compare planned vs allocated volumes | Export the full period with identifiers |
| BRP agreement and balancing responsibility terms | Defines responsibilities, data flows, and remedies | Include annexes on data, deadlines, and settlements |
| Supply or trading contracts (pass-through clauses) | Allocates costs and defines notice and evidence requirements | Check price, indexation, and settlement wording |
| Correspondence and meeting notes | Supports chronology and positions taken by each party | Preserve originals and complete threads |
| Collateral and credit documents (if applicable) | Explains credit triggers and operational risk | Include notices and collateral calculations |
Risks and frequent mistakes
- Missing contractual or regulatory deadlines for objections and corrections.
- Paying without a written reservation of rights when you intend to contest later.
- Relying on partial data exports (wrong time zone, missing identifiers, incomplete periods).
- Inconsistent portfolio mapping or changing identifiers during the period without documentation.
- Weak contract language on pass-through of balancing costs, evidence standards, and audit rights.
- Negotiations carried out informally, creating admissions or implied acceptance.
- Failure to preserve evidence (data versions, logs, settlement reports, and communications).
FAQ
What is an imbalance invoice in practice?
It is a financial settlement of the difference between allocated volumes and your final position for a settlement period, calculated under the applicable market rules. The practical step is to identify which data inputs were used and which document governs settlement for your role.
Can we dispute metering data after the invoice is issued?
Sometimes yes, depending on correction procedures and timelines in the relevant rules and contracts. A practical approach is to preserve all data versions, submit a documented correction request, and keep a clear written record while discussions continue.
If we pay, can we still contest the settlement later?
Payment can be interpreted differently depending on the facts and documents. If you need to pay to avoid operational impact, a written reservation of rights and a clear objection record can reduce the risk of being treated as accepting the settlement.
What deadlines matter most?
Deadlines for data corrections, invoice objections, and contractual dispute notices can be short. The first step is to extract every deadline from the governing rules and your contract set, then act in the safest order.
Do we need to go to ANRE before court?
It depends on whether the dispute concerns a regulatory act, the application of market rules, or a purely contractual issue. We assess the fastest route that preserves evidence and procedural options.
Internal links
Sources
- ANRE Order no. 213/2020 (imbalance calculation and settlement)
- ANRE Order no. 127/2021 (amendments related to balancing responsibilities)
- ANRE Order no. 18/2024 (changes in balancing and imbalance rules)
- Romanian Energy Law no. 123/2012 (electricity and natural gas)
- Regulation (EU) 2019/943 (internal market for electricity)
- Directive (EU) 2019/944 (internal electricity market rules)
- Commission Regulation (EU) 2017/2195 (electricity balancing guideline)