Who Holds the Switch: Eight Jurisdictions Answered a Different Question From the One the Sector Was Arguing About

Ten regulatory decisions reached this register in 2026 from eight jurisdictions, and read one at a time they look like eight unrelated stories about batteries. Read together they are one story, and it is not the story the sector thinks it is in.

The argument about distributed energy has been conducted, for two decades, as an argument about export. May a household put power back onto the wire, and at what price. That argument is close to finished. Bangladesh set an export price of Tk 10.50 and benchmarked it. Germany is ending guaranteed payment and pushing new rooftop solar toward the market. South Africa ran a registration window and closed it. The direction of travel is not seriously contested anywhere: power flows both ways, and the remaining disputes are about the number.

While that argument was being won, a different one opened underneath it, and almost nobody is reading the documents side by side. The question is no longer whether electricity may leave your house. It is who is allowed to operate the thing that sends it.

Three permissions, not one

The useful distinction comes from Nevada, which made it by accident. The Public Utilities Commission approved performance pay for distributed energy, which is the right direction: it pays a resource for what it actually does on the night the system is short, rather than for what it nominally is. Then it declined to let an aggregator collect that payment (№ 50).

Separate those two decisions and a structure appears. Operating a household device involves at least three distinct permissions, and they can be granted to different parties:

who may switch the device, who may read the meter that proves what the device did, and who may be paid for it.

A utility programme quietly holds all three. Every regime below is an argument about splitting them up, and each jurisdiction is splitting them differently.

Where the line is being drawn

Britain is drawing two lines at once. P511 puts a size boundary around the licence-free wholesale market route opened by P415: under 2 MW is in, over 10 MW is out (№ 52). The argument that closed the door was cost socialisation, which is worth noticing, because it is the argument normally deployed against net metering. The same objection now does work at both ends of the system.

Separately, and much less noticed, Britain has consulted on who should be exempt from needing a licence to control your heat pump (№ 57). That consultation has already closed. A licensing regime raises the floor on cyber security and consumer protection, which any household would want for a device that could otherwise be recruited into a botnet. It also sets a fixed cost of entry, and fixed costs sort a market toward incumbents. The exemption list is the answer to the question of who is allowed to touch the edge, and it was settled in a consultation most of the sector did not read.

Brazil has gone further than anyone. Its regulator is consulting on rules that would make distributed generation observable, operable and controllable by the distributor (№ 35). Most markets are still arguing about whether households may export at all. Brazil has enough distributed capacity on its networks that it can no longer defer the question, and is answering it in the distributor's favour.

India answered a narrower version of it and said the quiet part in writing. MNRE ordered that PM Surya Ghar inverter data, and the control servers behind it, be kept on Indian soil (№ 24). The compliance circular names the risk it is managing: unauthorised control of the devices. That is not a data protection rule wearing an energy hat. It is an official acknowledgement that a subsidised rooftop fleet is a population of remotely operable switches rather than a population of passive generators. Once a state has written that down, the question of who may operate them is permanently on the table.

What has actually been settled

Three decisions this year moved a permission from the utility to somebody else, and they are worth separating from the consultations.

From 1 November 2026, ISO New England opens its markets to distributed energy aggregations (№ 25). On that date 100 kW of somebody's batteries stops being a utility programme and becomes a market participant with an asset identifier and a settlement account. That is the entire content of FERC Order 2222, and it arrives six years after the order. The difference is not the money. A utility programme is bilateral: the utility sets the price, the call window and the exit terms, and the customer's only real power is to leave. A market participant has a price it can refuse.

California sent the governor a bill counting aggregated home batteries toward resource adequacy (№ 46), a year after he vetoed three distributed energy bills. Resource adequacy is the accounting by which a state decides which resources it may rely on in the worst hour of the year, and it has always counted power plants. Writing customer-owned devices into that ledger is categorically different from paying households to export. Export compensation is a payment. Resource adequacy is a promise the system makes to itself.

And FERC ordered PJM to accept statistical sampling for demand response, routing around a utility metering-data blockade (№ 23). This is the one to read twice, because it concerns the second permission rather than the first. Whoever holds the measurement holds the market. A slow answer to a metering-data request excludes a competitor more quietly than any written rule could, and PJM's own filings name the mechanisms: two-factor authentication, secondary-user enrolment, batch limits. None of those is a policy anyone voted on. All of them decide who can compete.

Who pays decides who is owed

Two Californian entries sit together and make the last point.

Google is paying for PG&E's new virtual power plant, which enrols nearly 21,000 devices customers already own (№ 43). Most Californian VPPs of any size have been tariffed programmes, which means the terms on which a household lends out its battery are set in a CPUC proceeding that any customer, ratepayer advocate or community group may intervene in. A privately funded programme is a contract. The terms are as good as the counterparty chooses to make them, and the forum in which they could be contested does not exist.

Then the other side of the same coin: California's final budget left its largest virtual power plant with no funding for 2027 (№ 20). The state built the thing, proved it at more than a gigawatt across roughly 200,000 households, and then declined to pay for it. The distinction that exposes is between a right written into a tariff and a payment written into an appropriation. A tariff persists until it is changed through a process. An appropriation expires unless it is renewed, and renewal is a budget negotiation in which two hundred thousand households are not a party.

The pattern

Put the ten together and the shape is consistent across jurisdictions that share no legal system and no market design.

Export is being settled, mostly in favour of the household. Control is being settled, mostly in favour of whoever already operates the network. Measurement, which decides both, is being settled almost silently, in interconnection queues, metering-data protocols and exemption lists that are consulted on and closed without coverage.

That asymmetry is not a conspiracy. It is a consequence of where the expertise sits. An export tariff is a number, and numbers attract intervenors. An exemption list is a schedule in an annex, and schedules do not.

For anyone arguing that power should move toward the edge, this is the uncomfortable finding. The argument that was won, the right to export, turns out to be the less important of the two. A household that may sell its output but may not decide when its battery runs has won a payment and lost a say. The decentralization question in energy is no longer whether power flows both ways. It does, nearly everywhere now.

It is who holds the switch, who may read the meter that proves what the switch did, and who gets paid for it. Those are three separate questions, they are being answered separately, and in most of these eight jurisdictions they are not being answered in the same direction.