The Japanese Ministry of Economy, Trade and Industry (METI) has proposed revisions to the price cap structure in Japan’s balancing market that may materially impact the economics of battery energy storage system (BESS) projects in Japan.

Under proposals presented to METI’s System Review Working Group in late October 2025 (the METI proposal), from April 2026 onward the price cap for premium balancing products (Primary, Secondary-1, and composite products) will be reduced from JPY 19.51 to JPY 7.21 per ΔkW/30min, a reduction of approximately 63%. This harmonizes the cap with the lower-value Secondary-2 and Tertiary-1 products, effectively removing the premium previously assigned to faster-response products in the balancing market. The METI proposal comes against a backdrop of concern that many faster-response balancing market bids have clustered at the price ceiling, leading to high balancing costs. These changes, together with recent changes in the Long-Term Decarbonization Power Source Auction (LTDA) 2025–26 auction guidelines, may signal a shift in METI and Organization for Cross-regional Coordination of Transmission Operators (OCCTO) priorities towards promoting long-duration, long-term capacity, in lieu of fast-response systems in the balancing market with potentially high-value arbitrage upside. This shift may affect Japan BESS project economics and market participation and future investment decisions in Japan’s BESS development.

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Photo of Joseph Kim ‡ Joseph Kim ‡

Joseph Kim is a global project finance and M&A lawyer, Co-Managing Shareholder of Greenberg Traurig’s Singapore office, and head of the firm’s Asia Energy and Infrastructure Practice. Joseph focuses his practice on energy and infrastructure projects, with deep experience in projects involving Japanese…

Joseph Kim is a global project finance and M&A lawyer, Co-Managing Shareholder of Greenberg Traurig’s Singapore office, and head of the firm’s Asia Energy and Infrastructure Practice. Joseph focuses his practice on energy and infrastructure projects, with deep experience in projects involving Japanese and Korean-led cross-border investments. With over two decades of experience in the renewables, conventional and nuclear power projects, Joseph advises first-of-its-kind and large-scale power projects across the globe. Understanding that power sector clients face diverse and complex issues, he develops custom strategies to help clients address their legal needs.

Joseph advises investors, sponsors, export credit agencies, commercial lenders, bilateral and multilateral agencies, and underwriters in connection with financing, acquiring, and developing a wide range of international energy and telecommunications projects. His experience includes matters involving power, upstream liquefied natural gas (LNG), natural resources, and renewable energy projects in Asia, the Middle East, and the Americas.

 Admitted in California and as a Singapore Foreign Lawyer. As a Foreign Legal Consultant Office, the practice in Seoul is limited to legal advice regarding U.S. law, treaties with the U.S., and universally recognized customary international law. We may not render legal advice on Korean law matters.
Photo of Yuko Ino Yuko Ino

Yuko represents international and domestic private investment funds, pension funds, real estate asset managers, and real estate developers and investors in connection with structuring, negotiating, documenting and implementing complex real estate transactions, including non-recourse financing, joint ventures, mergers and acquisitions, and restructuring and…

Yuko represents international and domestic private investment funds, pension funds, real estate asset managers, and real estate developers and investors in connection with structuring, negotiating, documenting and implementing complex real estate transactions, including non-recourse financing, joint ventures, mergers and acquisitions, and restructuring and workouts.

Yuko is consistently recognized in numerous leading legal publications, including Chambers Asia-Pacific and Legal 500 Asia Pacific, for her real estate transactions.

Yuko also advises clients on energy projects and fintech, licensing, disputes (particularly involving foreign countries) and general corporate matters.

Photo of Jared Raleigh Jared Raleigh

Jared Raleigh is an experienced practitioner advising on large-scale and complex infrastructure and energy projects. Based in Singapore from 2011 to 2022, Jared advises on all phases of the development, structuring, and financing of infrastructure and energy projects and has broad experience in…

Jared Raleigh is an experienced practitioner advising on large-scale and complex infrastructure and energy projects. Based in Singapore from 2011 to 2022, Jared advises on all phases of the development, structuring, and financing of infrastructure and energy projects and has broad experience in analyzing, negotiating, and drafting the full suite of project and finance documentation in established and emerging markets.

Jared has had practical experience throughout the Asia Pacific region, having worked for clients on projects in Singapore, Indonesia, Philippines, Vietnam, Japan, Sri Lanka, Mongolia, the Middle East and Australia.

Prior to joining Greenberg Traurig, Jared spent several years as a senior in-house lawyer and M&A executive at global mining, energy, and infrastructure companies, ensuring that he brings an understanding of the business needs of clients and commercial focus to his practice.

Photo of Kazuo Kasai Kazuo Kasai

Kazuo Kasai represents clients in real estate transactions, asset finance, renewable energy projects, and investment funds. He advises equity investors and lenders in real estate financing, representing investment funds on non-performing loan acquisitions, and assisting Japanese Real Estate Investment Corporations with asset acquisitions.

Kazuo Kasai represents clients in real estate transactions, asset finance, renewable energy projects, and investment funds. He advises equity investors and lenders in real estate financing, representing investment funds on non-performing loan acquisitions, and assisting Japanese Real Estate Investment Corporations with asset acquisitions. In addition, Kazuo is experienced in handling various renewable energy projects in terms of project acquisitions and developments, and project finance. Prior to joining Greenberg Traurig, Kazuo was at counsel at a leading international law firm.

Photo of Daniel Senger Daniel Senger

Daniel Senger advises on cross-border project finance transactions and mergers and acquisitions, representing project sponsors, lenders, multilateral development agencies, and export credit agencies. His experience extends across the energy and infrastructure sectors, with particular focus on renewable energy projects, power generation facilities, and…

Daniel Senger advises on cross-border project finance transactions and mergers and acquisitions, representing project sponsors, lenders, multilateral development agencies, and export credit agencies. His experience extends across the energy and infrastructure sectors, with particular focus on renewable energy projects, power generation facilities, and digital and energy transition infrastructure. His practice encompasses, among other things, greenfield project development, refinancing of operational assets and M&A transactions involving such assets.

With over a decade of experience in Asia, he advises on both transactions and ventures inbound into Asia as well as outbound from Asia to the rest of the world. Daniel handles complex international project financings that involve multiple lenders and export credit agencies. His work includes advising on offshore wind projects, battery manufacturing facilities, data centers, natural gas-fired power plants, and LNG infrastructure.

During an extended secondment at the Japan Bank for International Cooperation (JBIC), Daniel played a key role in advising on power generation projects throughout Asia and globally. This experience provided him with insight into how development finance institutions and export credit agencies approach project risk assessment and structuring. Daniel’s practice benefits from his understanding of both lender and borrower perspectives in cross-border transactions.

Daniel is admitted to practice in New York and is a registered foreign lawyer in Japan. He regularly conducts business in both English and Japanese.