In recent years, the global energy transition has accelerated and the proportion of renewable energy has continued to rise, posing many challenges to the traditional centralized power production and dispatch model The traditional power system focuses on centralized power generation and transmits electrical energy to users through ultra-high voltage transmission networks However, with the rapid development of distributed energy sources such as wind and solar power, this centralized power dispatch model is difficult to cope with the strong volatility and wide distribution of renewable energy In this context, virtual power plants have emerged as a new energy management and scheduling model, gradually becoming an important way to solve the problem of distributed energy coordination and scheduling in modern power systems

Virtual Power Plant (VPP) is a system that integrates multiple distributed energy resources (such as wind power generation, photovoltaics, energy storage equipment) and demand loads through information technology to achieve flexible adjustment and combination of electricity

The core concept of virtual power plants is to view geographically dispersed energy resources as a whole through digital technology and standardized management It utilizes advanced Internet of Things technology, communication technology, and automation control systems to monitor and manage the real-time operation status, power generation capacity, and electricity demand of various energy resources. Based on big data analysis and prediction, it flexibly adjusts the power grid, responds to price fluctuations in the electricity market, and even provides auxiliary services for the power grid (such as peak shaving, frequency regulation, etc.) to improve the flexibility of the system It enables the aggregation, scheduling, and participation of dispersed energy resources in market transactions, optimizes the energy structure, balances the supply and demand relationship of power sources, and thereby enhances the stability and economy of the power grid

1、 The Development Status of Virtual Power Plants in China

Virtual power plants, as an emerging energy management model, have achieved significant development worldwide in recent years Compared to European and American countries, the development of virtual power plants in China started relatively late. However, with the rapid development of renewable energy and the promotion of national policies, virtual power plants have gradually attracted widespread attention from the industry and the government

Before 2016, the concept of virtual power plants was still in the research and exploration stage in China, with more discussions at the technical level

From 2016 to 2019, China's virtual power plants shifted from conceptual exploration to preliminary commercial practice For example, in 2016, Thirty Li Jingzi in Yumen City, Gansu Province launched a demonstration project for the integration of wind, solar, and energy storage grids. This is one of the earliest supply side virtual power plant projects in China, with a wind and photovoltaic power generation capacity of 35MW and the addition of 10MW energy storage facilities By 2017, Zhangjiagang Smart Electricity Demonstration Park in Jiangsu Province had been launched, integrating distributed clean energy and electric vehicle charging piles, becoming one of the first large-scale demand side response virtual power plants in China In addition, the Jibei Virtual Power Plant made its debut in 2019, demonstrating the enormous potential of virtual power plants in power and load management through flexible resource allocation

From 2019 to 2021, the concept of virtual power plants has gradually been accepted by people, and more projects have been put into practice The first batch of virtual power plant operation pilot projects in Shanghai has been launched, involving 4 virtual power plant operators and 512 customer access platforms, integrating various resources such as electric vehicle charging piles, commercial buildings, and park microgrids At this stage, virtual power plants are gradually extending from the supply side to the demand side, and hybrid virtual power plants continue to emerge, promoting the application of virtual power plants in more scenarios

Since 2021, with the gradual maturity of technology and the improvement of policies, virtual power plants have been widely promoted and applied nationwide For example, Shanghai has built a virtual power plant that covers commercial buildings, 5G base stations, and energy storage units, achieving automated regulation and management of multiple types of loads In addition, the virtual power plant cloud platform of Southern Power Grid has been put into operation in Shenzhen. The platform integrates distributed photovoltaics and adjustable loads, participates in grid auxiliary services, and further verifies the role of virtual power plants in peak shaving and frequency regulation Shandong, Anhui and other provinces and cities are also actively building virtual power plants, gradually exploring the commercial profit model of virtual power plants by participating in electricity spot market transactions At present, the virtual power plant project has not only expanded its scale, but also placed greater emphasis on integration with the electricity spot market, further enhancing the virtual power plant's peak shaving and frequency regulation capabilities and market response speed

2、 Current legal situation of virtual power plants in China

Before 2020, China issued a series of laws, regulations, and policy documents on the development of renewable energy and distributed energy For example, the Renewable Energy Law of the People's Republic of China and the Energy Conservation Law of the People's Republic of China have been revised successively to support the development of distributed energy and smart grids This provides a favorable environment for the subsequent development of virtual power plants

In 2020, the National Development and Reform Commission and the National Energy Administration issued a notice on the signing of medium and long-term electricity contracts in 2021, demonstrating China's active attitude towards promoting electricity marketization and improving the stability of electricity supply The state encourages market entities to sign medium and long-term electricity contracts, and promotes the electronicization and platformization of electricity contracts The introduction of time slot contracts allows market entities to flexibly adjust according to actual electricity load demand, effectively responding to electricity demand in different time periods and improving market responsiveness and efficiency These measures reflect the clear support and commitment of the country to ensure the efficient and orderly operation of the electricity market and support the development of virtual power plants Virtual power plants can ensure the consumption of renewable energy through the signing of medium and long-term market electricity, and obtain more economic benefits through market transactions

Since 2021, multiple provinces and municipalities have successively introduced policies to support the development of virtual power plants, and various regions have also accelerated the participation of new market entities such as virtual power plants in electricity market transactions The notice issued by the Guangzhou Municipal Bureau of Industry and Information Technology on the implementation rules for virtual power plants in Guangzhou has further promoted the application and development of virtual power plants in the electricity market by clarifying the definition, participation conditions, response mechanisms, and market-oriented subsidies of virtual power plants

In 2022, the National Development and Reform Commission and the National Energy Administration issued the "Opinions on Improving the System, Mechanism, and Policy Measures for Energy Green and Low Carbon Transformation", supporting virtual power plant operators to participate in electricity market transactions and system operation regulation

Since 2023, the policies and relevant laws for virtual power plants in China have gradually improved, forming a regulatory system centered on market access, technical standards, and market-oriented transactions In 2023, the National Development and Reform Commission revised and released the "Electricity Demand Side Management Measures", "Electricity Load Management Measures", and "Basic Rules of the Electricity Spot Market (Trial)" Request to promote the establishment and improvement of a linkage mechanism between demand side resources and power operation regulation, with a focus on promoting innovation and application of new energy storage, virtual power plant vehicle network interaction, microgrids, and other technologies. Encourage emerging market entities such as distributed energy storage, load aggregators, virtual power plants, and new energy microgrids to participate in transactions

The "Electricity Market Supervision Measures" issued in 2024 further clarify the market subject status of virtual power plants and support their participation in electricity spot market transactions At the same time, the Basic Rules for Electricity Market Registration also stipulate the admission conditions for virtual power plants as market entities

With the subsequent revision and promulgation of the Energy Conservation Law of the People's Republic of China, the Electricity Law of the People's Republic of China, and the Renewable Energy Law of the People's Republic of China, it is possible to further clarify the legal status and regulatory measures of virtual power plants from the top-level structure.

3、 Supervision methods and characteristics of virtual power plants in China

（1） Legal regulatory framework guided by policies

The Chinese government has clarified the legal status and development direction of virtual power plants through top-level design such as energy policies and development plans, forming a regulatory system that combines policy and law

1. Based on policy support

In recent years, the Chinese government has clearly stated the strategic significance of virtual power plants in multiple policy documents Several policy documents, represented by the "14th Five Year Plan for Modern Energy System", have pointed out the importance of enhancing the flexibility of the power system, promoting the construction of virtual power plants, and strengthening the grid's ability to absorb volatile renewable energy, providing development directions for the construction and operation of virtual power plants

2. Gradually improving legal norms

Although China has not yet issued specific laws and regulations for comprehensive supervision of virtual power plants, the relevant electricity market laws and regulations already cover the operation of virtual power plants For example, the Electricity Law of the People's Republic of China and the Renewable Energy Law of the People's Republic of China provide legal support for electricity market trading, energy management, dispatch and operation. The electricity market rules, trading norms and other contents in these regulatory frameworks are also applicable to the operation and management of virtual power plants At the same time, local governments have also introduced several local regulations in accordance with national policies to promote the pilot and application of virtual power plants, forming certain regional differentiated regulatory characteristics

（2） Unified management and classified supervision

Due to the complexity and diversity of virtual power plants, the government has established a unified management framework through top-level design to comprehensively plan and supervise the construction, operation, market participation, and other aspects of virtual power plants The "GB/T44241-2024 Virtual Power Plant Management Specification" jointly formulated by the National Energy Administration and local governments will be officially implemented on February 1, 2025. It covers market access standards, technical requirements, grid connection conditions, and market behavior norms for virtual power plants

Local governments flexibly refine and implement management measures for different types of virtual power plants based on central policies, especially in response to differences in local energy structures For example, Shanxi Province has refined and classified the regulatory policies for "load type" virtual power plants and "source network load storage integration" virtual power plants, and can manage different types of virtual power plants more accurately according to their characteristics and functions, effectively avoiding the problems that may arise from a one size fits all management approach

（3） Local supervision and policy pilot

Due to differences in energy structure, economic development level, and electricity market openness among different regions in China, the legal supervision of virtual power plants also exhibits characteristics of differentiation and pilot at the local level

1. Local regulations and policy support

In China, many local governments have formulated local policies and regulations to support the development of virtual power plants based on the national policy framework For example, provinces and cities such as Ningxia and Guangdong have taken the lead in issuing local regulations or policy documents for virtual power plants, encouraging their construction and operation, and providing relevant market access and tax incentives These local policies not only promote the pilot application of virtual power plants, but also provide localized practical experience for the legal supervision of virtual power plants

2. Regulatory exploration of pilot projects

In some pilot projects in certain regions, the regulatory mode of virtual power plants is more flexible. For example, the governments of Shenzhen, Shanghai and other places have provided certain policy testing space within the legal regulatory framework to stimulate innovation and explore the legal needs and regulatory challenges of virtual power plants in actual operation

4、 Key dimensions of virtual power plant supervision

（1） Multi level market access and operational supervision

The market access and operational supervision of virtual power plants are core components of their legal framework As a part of the new power system, virtual power plants should be subject to strict legal supervision for their legality, compliance, and market behavior norms in the electricity market China has systematically regulated the market access mechanism for virtual power plants to ensure their legitimacy, technical capabilities, standardized management, and market transparency in participating in the electricity market

1. Market access system

Firstly, China has clarified the legal status of virtual power plants as market entities through a series of rules The most crucial is the Basic Rules for Electricity Market Registration, which includes virtual power plants as operating entities in the electricity market and allows them to participate in electricity trading and dispatch services This regulation is the core legal basis for market access of virtual power plants, establishing their independent and legal market subject status in the electricity market The legal clarification of the legal identity of virtual power plants not only grants them the right to participate in market transactions, but also enhances the confidence of investors and operators in their market behavior, attracting more capital and enterprises to enter this field

Secondly, legal regulation sets strict technical and management conditions for the admission of virtual power plants, ensuring that only virtual power plants with sufficient capabilities can participate in the market These admission requirements include: technical capabilities, data measurement and transmission requirements, and resource adjustment capabilities

2. Market behavior norms

Virtual power plants participating in the electricity market must comply with relevant regulations on fair competition and price formation mechanisms, especially in the electricity spot market and ancillary service market. The pricing behavior and market trading rules of virtual power plants are subject to the constraints of the Electricity Law of the People's Republic of China and relevant market supervision regulations In addition, virtual power plants need to comply with national and local dispatch management regulations, accept dispatch from power grid enterprises, and ensure the reliability and stability of power supply

3. Accurate data and information disclosure

The accuracy and reliability of data are the foundation of settlement and market scheduling. Virtual power plants must provide accurate electricity and power data to ensure that transactions between market participants are based on accurate market information Regulatory agencies require virtual power plants to provide real-time and historical data, ensuring that transactions between market participants are based on accurate market information, and guaranteeing the fairness and traceability of transactions

Moreover, virtual power plants are required to disclose relevant information to market regulatory agencies and market participants in accordance with regulations Unreasonable and discriminatory conditions shall not be set to restrict the free flow of goods, services, and essential resources. Services shall be provided without discrimination, information shall be disclosed in a standardized manner, and public supervision shall be accepted This requirement enhances the transparency of virtual power plant operations, facilitates market supervision and oversight of other market participants, reduces potential information asymmetry issues in the market, and promotes fair competition in the market

（2） Data Security and Information Privacy Protection

The operation of virtual power plants highly relies on data communication and information management, therefore, data security and information privacy protection are important contents of legal supervision of virtual power plants in China The behavior of virtual power plants in data collection, storage, transmission, and other aspects is jointly regulated by multiple laws

1. Application of the Cybersecurity Law of the People's Republic of China

As an important infrastructure in the energy industry, virtual power plants require strict security measures for their network systems and data communication to prevent security risks such as data leakage and network attacks The data processing system of the virtual power plant needs to pass the national network security level protection system to ensure network security and ensure the normal operation of the virtual power plant

2. Data privacy and personal information protection

In the operation of virtual power plants, it involves personal electricity consumption data and behavioral data of power users According to the Personal Information Protection Law of the People's Republic of China, virtual power plants should follow strict privacy protection when processing user data, and shall not provide user data to third parties without authorization, and must ensure the secure storage and transmission of data At the same time, virtual power plant operators need to audit their data processing activities and promptly report to regulatory agencies and make decisions in the event of a data breach

（3） Integrating environmental protection with sustainable development goals

The regulation of virtual power plants not only involves the electricity market and data security, but also needs to be combined with the country's environmental protection policies and sustainable development goals As an important tool for integrating new energy, the development of virtual power plants directly affects the progress of carbon emission reduction and the efficiency of renewable energy consumption. Therefore, environmental protection requirements need to be combined in legal supervision

Although virtual power plants themselves do not directly generate pollution, the distributed energy systems involved in their operation (such as energy storage batteries, distributed generation equipment, etc.) may have environmental impacts during their lifecycle Therefore, the construction and operation of virtual power plants must comply with the Environmental Protection Law of the People's Republic of China and other relevant environmental regulations Especially in the manufacturing, operation, and disposal of energy storage equipment, virtual power plants need to ensure compliance with environmental regulations and reduce negative impacts on the environment

5、 Conclusion

Virtual power plants, as an innovative technology in modern power systems, are an important component of China's energy transformation and power market reform, providing effective solutions for improving the consumption capacity of new energy and balancing the supply and demand relationship of electricity In the context of global energy transition, the development of virtual power plants not only promotes the optimization of energy structure, but also lays a solid foundation for building a low-carbon, clean, and efficient energy system in the future

The legal regulatory system for virtual power plants in China has multi-level and multi-dimensional characteristics Through policy guidance, the government has provided clear development directions for the construction and operation of virtual power plants Through relevant laws and regulations, the way in which virtual power plants participate in market operations as legal entities has been standardized With the gradual maturity of technology and the improvement of policies, the application scenarios of virtual power plants are becoming increasingly diverse, and their scheduling flexibility and market adaptability are significantly enhanced

In the future, with the further improvement of the legal regulatory system, virtual power plants will play a more important role in energy transformation The coordinated promotion of top-level design, market rules, and technical standards will help promote virtual power plants in China's electricity market, enhance the stability, economy, and sustainable development capabilities of the power system, and promote China's move towards a green and low-carbon energy future


Attachment: List of Important Regulations

1. Legal

Renewable Energy Law of the People's Republic of China

Energy Conservation Law of the People's Republic of China

Electricity Law of the People's Republic of China

Cybersecurity Law of the People's Republic of China

Personal Information Protection Law of the People's Republic of China

Environmental Protection Law of the People's Republic of China


2. Departmental work documents

Basic Rules for Electricity Market Registration (Guoneng Fa Regulatory Regulation [2024] No. 76)

Action Plan for Accelerating the Construction of a New Power System (2024-2027) (NDRC Energy [2024] No. 1128)

Measures for the Supervision of the Electricity Market (Order No. 18 of the National Development and Reform Commission of the People's Republic of China)

Action Plan for Energy Conservation and Carbon Reduction from 2024 to 2025 (Guofa [2024] No. 12)

Guiding Opinions on Energy Work in 2024 (National Energy Development Plan [2024] No. 22)

Guiding Opinions on Strengthening the Construction of Peak shaving Energy Storage and Intelligent Dispatching Capacity in Power Grid

Key Points for Energy Regulatory Work in 2024 (State Energy Development Supervision [2024] No. 4)

Basic Rules for Spot Electricity Market (Trial) (NDRC Energy Regulations [2023] No. 1217)

Electricity Demand Side Management Measures (2023) (NDRC Operational Regulations [2023] No. 1283)

Key Points for Regulatory Work of Southern Regional Electricity Market in 2022, Southern Supervisory Energy Market [2022] No. 36

Key Points for Energy Regulatory Work in 2022 (National Energy Development Supervision [2022] No. 4)

Implementation Opinions on Strengthening the Integration and Interaction between New Energy Vehicles and the Power Grid (NDRC Energy [2023] No. 1721)

Notice on Further Accelerating the Construction of the Electricity Spot Market (NDRC/GTG [2023] No. 813)

Electricity Load Management Measures (2023 Edition) (NDRC Operating Regulations [2023] No. 1261)

Guiding Opinions on Promoting the Development of Energy Electronics Industry (MIIT Liandian [2022] No. 181)

Implementation Plan for Carbon Peak and Carbon Neutrality Supported by Technology (Guokefa She [2022] No. 157)

14th Five Year Plan for Modern Energy System (NDRC Energy [2022] No. 210)

Guiding Opinions on Accelerating the Construction of a Unified National Electricity Market System (NDRC/GTG [2022] No. 118)

Management Measures for Electric Power Auxiliary Services (Guoneng Fa Regulatory Regulation [2021] No. 61)

Regulations on the Management of Grid connected Operation of Electric Power (Guoneng Fa Regulatory Regulation [2021] No. 60)

Action Plan for Peak Carbon Emissions by 2030 (Guofa [2021] No. 23)

Guiding Opinions on Accelerating the Development of New Energy Storage (NDRC Energy Regulations [2021] No. 1051)

Guiding Opinions on Promoting the Integration of Power Source Grid Load Storage and Multi energy Complementary Development "(NDRC Energy Regulations [2021] No. 280)

Key Points of Energy Regulatory Work in 2021 (State Energy Development Supervision [2021] No. 2)

Several Opinions on Promoting the Healthy Development of Non Water Renewable Energy Generation (Caijian [2020] No. 4)

Guidelines for Demand Side Management of Electricity in the Industrial Sector (MIIT Operation [2019] No. 145)

Guiding Opinions on Promoting the Development of "Internet plus" Smart Energy (FGNY [2016] No. 392)

Guiding Opinions on Promoting the Development of Smart Grid (NDRC Operation [2015] No. 1518)


3. Local work documents

Implementation Rules for Virtual Power Plants in Guangzhou

Implementation Plan for Precise Response of Virtual Power Plants in Lingang New Area of China (Shanghai) Pilot Free Trade Zone (Trial)

Management Measures for Precise Response of Virtual Power Plants in Lingang New Area of China (Shanghai) Pilot Free Trade Zone (Trial)

Operation and Management Rules for Virtual Power Plants in Ningxia Hui Autonomous Region

Implementation Plan for Virtual Power Plant Construction and Operation Management in Shanxi Province


Annotations and citations

[1] Shanghai is the first to put into trial operation of a virtual power plant operation system [J]. Electricity and Energy, 2019, 40 (06): 755

[2] Bi Jingyue The Legal Framework of Virtual Power Plants [J]. Chinese and Foreign Energy, 2023, 28 (02): 11-15

[3] New quality productivity of energy - legal thinking of virtual power plant entering reality, posted on WeChat official account "Zhide Law Firm"