Grid-Scale Battery Energy Storage Systems: A Comprehensive Review of Regulatory Frameworks and Markets

Grid-scale Battery Energy Storage Systems (BESSs) are becoming essential components of modern power grids undergoing rapid decarbonisation. This review examines how nine jurisdictions—Great Britain, Germany, Spain, Italy, France, California (USA), Australia, Singapore, and China—are enabling the growth of BESSs, focusing on market access and revenue streams, investment risks and mitigation strategies, support mechanisms, and regulatory conditions. A central finding is that batteries typically become investable only when they can stack revenue from multiple sources, including energy arbitrage, ancillary services, and capacity markets. Regulation proves as important as technology: frameworks that fail to recognise storage as a distinct asset class expose projects to double charging, unclear licensing, and limited market access. Grid connection delays, declining revenues in saturating ancillary service markets, and safety compliance represent significant practical barriers. International experience indicates that BESSs scale fastest when decarbonisation policy is credible and market rules enable diversified, financeable revenue streams.