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Revision of the REMIT Implementing Regulation on data reporting

Energy

The Commission Implementing Regulation on data reporting under REMIT lays down rules for the provision of data to the Agency for the Cooperation of Energy Regulators (ACER) by market participants as required by Regulation (EU) No 1227/2011 on wholesale energy market integrity and transparency (REMIT). Following amendments to REMIT, now also the REMIT Implementing Regulation needs to be adapted.

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Public consultation

ID: 14447

Lobbying Activity

40 responses

EDF Criticizes Complex EU Energy Market Reporting Rules

ELECTRICITE DE FRANCE, 16 Sept 2025

EDF requests a realistic implementation timeline starting only after all technical specifications are published. They urge removing exposure reporting, arguing it exceeds the legal scope of preventing market abuse. They also propose replacing complex algorithm IDs with a simple indicator flag.
This would lower technical compliance costs and prevent regulator interference in commercial hedging strategies.
Energy regulators would lose access to granular data regarding market participants' risk levels and strategies.

Enel urges Commission to limit reporting burdens in REMIT revision

ENEL SpA, 15 Sept 2025

Enel wants to remove production and consumption forecasts from reporting requirements. They suggest shortening reporting horizons to eighteen months to align with industry practice. The company proposes replacing complex algorithm IDs with a simple reporting flag.
This would reduce compliance costs and simplify operational requirements for the company.
Regulators lose granular oversight of trading strategies and internal production forecasts.

Eni urges simplification of REMIT data reporting and exposure thresholds

Eni S.p.A., 16 Sept 2025

Eni requests raising the exposure reporting threshold to 5 TWh/year, reducing the reporting horizon to 18 months, and ensuring at least 12 months for implementation after ACER publishes technical specifications. They propose replacing complex Algorithm ID requirements with a simple algorithm flag.
This would reduce administrative burdens and REMIT-related compliance costs for the company.
Market surveillance capabilities are weakened by reduced data granularity and longer reporting timelines.

Oil and Gas Industry Seeks Extended REMIT Data Reporting Deadlines

International Association of Oil Gas Producers Europe, 16 Sept 2025

The organization requests at least 12 months implementation time after technical specifications are published, raising the exposure reporting threshold to 5 TWh/year, and extending OTC contract reporting deadlines to 20 days. They argue current timelines don't reflect operational constraints.
This would reduce their compliance costs and give them more time to adapt reporting systems.
Market transparency suffers as delayed and limited reporting reduces regulators' ability to monitor trading activity.

RWE Warns Against Excessive Energy Market Reporting Burdens

RWE AG, 15 Sept 2025

RWE recommends shortening the reporting period and excluding forecast data to simplify requirements. They suggest limiting algorithmic tracking to a simple binary indicator and aligning terminology with financial regulations. Finally, they request a one-year implementation period after technical guidelines are finalized.
These changes would significantly lower compliance costs and reduce regulatory complexity for utilities.
Energy regulators would lose the detailed oversight required to identify suspicious trading behaviors.

Eurogas Urges Scaled Back Reporting for Wholesale Energy Markets

EUROGAS, 17 Sept 2025

Eurogas requests an implementation delay of 12 months after technical specifications are final. They also advocate for shortening the exposure reporting horizon to 18 months.
This would lower compliance costs and prevent regulators from misinterpreting commercial strategies.
Regulatory authorities would have less data to monitor potential energy market breaches.

Euronext calls for exemption from duplicate energy trading reports

Euronext, 16 Sept 2025

Euronext requests excluding financial instruments already reported under MiFID II from REMIT exposure reporting. They seek an 18-month implementation period and 12-month delay for Article 6. The organization wants clarification that reporting responsibility stays with market participants, not trading platforms.
This would eliminate duplicate reporting requirements and reduce compliance costs for the exchange.
Energy regulators lose independent position data collection, relying instead on shared financial regulator data.

E.ON Warns New Energy Data Rules Threaten Security of Supply

E.ON SE, 12 Sept 2025

E.ON requests removing burdensome forecasts and algorithmic trading IDs. They advocate for a minimum 18-month implementation period.
This would reduce administrative complexity and prevent unfeasible operational burdens on energy companies.
EU consumers may face higher energy costs and risks to their security of supply.

BP urges removal of production forecast reporting requirements

BP p.l.c., 17 Sept 2025

BP requests removal of requirements to provide production and consumption forecasts, clearer definitions, and at least 18 months implementation time. They argue the proposals go beyond the legal text and contradict EU simplification goals.
This would avoid commercially sensitive disclosures and reduce compliance costs and complexity.
Regulators lose forward-looking data that could help detect market manipulation and abuse.

Securities Exchanges Warn Against Penalising Legitimate Energy Hedging Activity

Federation of European Securities Exchanges, 16 Sept 2025

FESE requests excluding financial instruments already covered by MiFID II from new REMIT exposure reporting requirements. They warn against flagging mismatches between trading positions and physical generation as suspicious behaviour, arguing this misinterprets legitimate risk management.
This would eliminate duplicative reporting costs for derivatives already reported under MiFID II.
Energy regulators lose a potential tool for detecting market abuse patterns.

Energy firm A2A urges EU to slash reporting burdens

A2A, 12 Sept 2025

A2A proposes raising the reporting threshold to five terawatt-hours to exclude smaller firms. They also demand twelve months to adapt systems once technical rules are finalized.
Higher thresholds would allow the company to avoid costly administrative and IT requirements.
Regulators would have less detailed data to monitor and detect market manipulation.

Intercontinental Exchange Urges EU to End Duplicative Energy Reporting

Intercontinental Exchange, Inc., 16 Sept 2025

The group requests excluding energy derivatives already covered by financial regulations from the new reporting rules. They advocate for better data-sharing between regulators and an 18-month implementation window.
This change would lower operational expenses and prevent the need for costly new reporting systems.
European households and businesses might face higher energy bills due to increased industry costs.

Gas Infrastructure Europe calls for streamlined energy market reporting

Gas Infrastructure Europe, 15 Sept 2025

The group requests a harmonized system to avoid double reporting to national and European regulators. They urge extending implementation to 18 months and exempting operators' internal energy purchases from disclosure.
These changes would lower operational costs by removing redundant and complex reporting requirements.
Regulators could lose access to data points intended to provide a complete market picture.

Polish Electricity Association seeks clarity and longer REMIT reporting deadlines

Polish Electricity Association, 12 Sept 2025

PKEE recommends a 12-month implementation period after final guidance is released to adjust systems. They argue the proposed 10-day reporting deadline for complex contracts is too short for accurate processing.
Longer preparation times help power companies avoid the risk of accidental non-compliance.
Energy consumers could face fewer choices if strict deadlines discourage supplier switching.

Enagás Urges Reporting Exemptions for Energy Infrastructure Operators

Enagás S.A., 16 Sept 2025

Enagás proposes an explicit exemption for infrastructure operators from exposure reporting regardless of their energy volumes. They also recommend excluding auctions with no bids from reporting and maintaining flexibility for lifecycle event channels.
These changes would reduce administrative costs and prevent conflicts of interest for operators.
EU regulators lose forward-looking data intended to detect market mismatches and manipulation.

Orlen S.A. calls for realistic energy contract reporting deadlines

Orlen S.A., 11 Sept 2025

Orlen requests maintaining the current reporting exemption for specific consumption units. If this is changed, they argue the deadline for bilateral contracts must be at least 20 days.
Longer timelines help the company manage complex data verification and administrative tasks.
Consumers may face fewer options if strict deadlines discourage supplier switching.

Energy Traders Europe: Reporting Rules Threaten EU Supply Security

Stichting European Federation of Energy Traders (We operate under the name Energy Traders Europe), 16 Sept 2025

Narrow the exposure reporting scope to avoid inflating limited provisions into complex requirements. Exclude sensitive and unpredictable 24-month production and consumption forecasts. Ensure a minimum 18-month lead time from final technical documentation.
This would reduce the reporting burden and prevent complexity for market participants.
EU consumers may face higher energy costs and reduced security of supply.

Europex urges 18-month delay for energy data reporting rules

Europex - Association of European Energy Exchanges, 12 Sept 2025

Europex requests extending the implementation timeline to 18 months for system updates. They want market platforms to report strictly on behalf of participants. They also demand extensive consultations before technical manuals are finalized.
A longer transition period prevents wasted development costs and technical compliance risks.
Market regulators face delays in receiving the enhanced data required for oversight.

European Energy Exchange Urges Simpler EU Energy Data Reporting

European Energy Exchange AG, 16 Sept 2025

EEX recommends excluding financial instruments covered by other laws to avoid duplicative reporting. They request explicit legal recognition of reporting agreements between market platforms and participants. They also oppose mandatory reporting for rare events occurring outside of trading platforms.
This approach would reduce administrative complexity and prevent costly technical system overhauls.
Regulators might have less visibility into trading strategies and niche market activities.

Österreichs E-Wirtschaft warns against disproportionate energy reporting burdens

Österreichs E-Wirtschaft, 12 Sept 2025

The group requests removing exposure reporting obligations and raising the participant threshold. They advocate for simple binary flags for algorithms and extended implementation timelines.
These changes would lower administrative costs and protect sensitive commercial trading strategies.
Energy regulators would have less detailed data for monitoring algorithmic trading and forecasts.

Consultation response

Open Grid Europe GmbH, 12 Sept 2025

Please find enclosed the response of Open Grid Europe GmbH.

Consultation response

GASCADE Gastransport GmbH, 16 Sept 2025

Thank you for the opportunity to share our view on the draft regulation. Please find our points in the attached file. In addition to this, we would like to highlight the following points: - Article 4, paragraph 9c) The consumption unit in Article 2, paragraph 11 is only defined for gas and…

CEZ Warns REMIT Data Rules Threaten EU Energy Security

CEZ, a.s., 12 Sept 2025

CEZ opposes the new reporting rules, claiming they exceed the legal scope of European regulations. They request an 18-month delay after regulators publish the final technical reporting instructions.
Narrower reporting requirements would protect sensitive data and reduce the industry's heavy operational burden.
EU consumers may face higher prices if complex rules discourage market supply and competition.

Consultation response

GAZ-SYSTEM S.A., 16 Sept 2025

GAZ-SYSTEM is a gas transmission system operator in Poland. The company is also the owner of the LNG Terminal. In addition, the company operates the GSA Platform, which is used for the allocation of capacity on interconnectors and provides secondary market reporting. Consequently, it has been…

Consultation response

Elettricità Futura, 16 Sept 2025

EF/Proxigas welcome the opportunity to provide feedback on the Draft Implementing Regulation revising REMIT data reporting rules. Our key recommendations are as follows: Simplification: Administrative burdens on MPs should be further reduced, in line with EU competitiveness objectives. Exposure…

Utilitalia urges higher thresholds for energy exposure reporting

Utilitalia, Imprese Acqua Ambiente Energia, 15 Sept 2025

Utilitalia wants higher thresholds to exclude smaller energy companies from exposure reporting. They suggest shortening the timeframe for reporting future energy production and consumption. They request simplified reporting for automated trading instead of complex identification codes.
This would simplify operations and lower technical compliance costs for energy companies.
Regulators lose access to granular data on specific daily algorithmic trading strategies.

Consultation response

ASOCIACIÓN DE EMPRESAS DE ENERGÍA ELÉCTRICA, 15 Sept 2025

Overall, we are concerned that the draft increases reporting burden without commensurate surveillance benefit. Exposure reporting is the clearest example. The notion of flagging prima facie unjustified trading behaviour implies a de facto hedge benchmark and sanctioning deviations. Forecasts are…

Consultation response

ONTRAS Gastransport GmbH, 12 Sept 2025

Please find attached the response of ONTRAS Gastransport GmbH.

Consultation response

OMI Polo Español S.A., 16 Sept 2025

Thank you for the opportunity to provide feedback on this Commissions proposal. Please find attached OMIEs comments to the proposal.

Consultation response

European Energy Retailers - Network of Independent Energy and Solution Providers, 15 Sept 2025

The association of European Energy Retailers (EER) welcomes the opportunity to provide feedback and expresses its concerns with the REMIT data reporting rules which add bureaucracy without strengthening market integrity. EER is in particular concerned about the exposure reporting under REMIT. As…

Consultation response

ASOCIACION ESPAÑOLA DEL GAS, 15 Sept 2025

We would like to express our appreciation for the opportunity to provide feedback to European Commission about the revision of data reporting rules under REMIT Regulation. This response incorporates our observations and suggestions based on the draft Commission Implementing Regulation and its Annex…

Consultation response

FORTIA ENERGIA S.L., 17 Sept 2025

Fortia Energia S.L. welcomes the opportunity to contribute to the consultation on the draft REMIT Implementing Regulation. In this way, we have identified a drafting inconsistency in the draft REMIT Implementing Regulation concerning the duration threshold for gas storage contracts subject to…

Consultation response

BULGARTRANSGAZ, 16 Sept 2025

Bulgartransgaz is a Bulgarian gas TSO and SSO, registered as REMIT market participant and RRM since 2015. We welcome the opportunity to contribute to the European Commissions public consultation on the draft revision of REMIT Implementing Regulation. While the Commissions efforts to simplify the…

Consultation response

Associazione Nazionale Industriali Gas, 16 Sept 2025

Proxigas welcome the opportunity to provide feedback on the Draft Implementing Regulation revising REMIT data reporting rules. Our key recommendations are as follows: Simplification: Administrative burdens on MPs should be further reduced, in line with EU competitiveness objectives. Exposure…

Consultation response

Commodity Markets Council - Europe, 15 Sept 2025

The draft text does not simplify the regime, but introduces obligations that are duplicative, unclear, and operationally burdensome, with the potential to damage liquidity and weaken security of supply. CMCE calls on the Commission to: (i) limit and clarify exposure reporting, (ii) align reporting…

Consultation response

European Venues and Intermediaries Association, 15 Sept 2025

Industry Comments on the inclusion of lifecycle events into OMP Reporting channels for transactions We have real concerns about the proposed changes in connection with OMP reporting of lifecycle events [LCEs]. Our concern is not limited to OMPs alone; implementing the proposed changes will be…

Consultation response

Vereniging Gasopslag Nederland, 15 Sept 2025

Dear Sir, Please find in the attached file the feedback from the Dutch Gas Storage association. Kind regards Rene van der Vegt

Consultation response

, 12 Sept 2025

Please find attached the response from Thyssengas GmbH

Consultation response

OTE, a.s., 12 Sept 2025

Please find enclosed the response of OTE, a.s., the holder of a license for the activities of the market operator, which includes the electricity and gas market in the Czech Republic.

Consultation response

PRISMA European Capacity Platform GmbH, 10 Sept 2025

Please see attachment