BULGARTRANSGAZ
Bulgartransgaz EAD is a combined operator with business activity transmission and storage of natural gas, maintenance, operation, management and development of underground gas storage.
ID: 730004052231-48
Lobbying Activity
Response to Revision of the REMIT Implementing Regulation on data reporting
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 reporting process and reduce compliance burdens for the industry are recognised and appreciated, several concerns remain regarding specific aspects of the proposed Regulation, particularly in relation to: 1) Requirement for reporting of details about primary capacity allocations, closed without bids and without allocated capacity, despite no links with market signals and abuse; 2) Creation of the OMP List without safeguards for entities that do not acknowledge OMP status; 3) Introduction of new redundant data fields in Table 4 whose content could be derived from existing elements; 4) Exposure reporting by market participants that purchase natural gas or electricity exclusively for their own consumption and do not engage in production, supply, or trading activities; 5) Reporting deadlines defined by product type rather than transaction execution venue (OTC/OMP); 6) Start of application of certain provisions without sufficient consideration for required technical implementations or prior specifications from ACER. The enclosed contribution provides comments, practical examples, alternative solutions and supporting justifications on key aspects of the REMIT Implementing Regulation. Should any further clarification be required, we remain available and can be contacted using the provided contact information. Please, refer to the enclosed file. Thank you for your attention and consideration.
Read full responseResponse to Commission Regulation on inside information platforms and registered reporting mechanisms under REMIT
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 Delegated Regulation setting out requirements for RRMs and IIPs. While the Commissions efforts to simplify rules and reduce compliance burdens for the industry are recognised and appreciated, several concerns remain regarding specific aspects of the proposed Regulation, particularly in relation to: 1) Extensive and overlapping requirements for the RRMs/IIPs, the associated attestation documentation and provisions that undermine the intended fast-track authorisation process of registered RRMs/IIPs; 2) Mechanism for flagging and processing invalid inside information by IIPs; 3) Requirement for maintaining register of invalid records by the RRMs and IIPs, associated with storing and tracking inconsistent and irrelevant data; 4) Formulation of the requirements for equal treatment in the provision of IIP services, which contradict the existing model and discriminate established IIPs, favoring commercial platforms; 5) Proposed approach for orderly substitution and data transfer in the event of RRM/IIP withdrawal; 6) Inclusion of the "Curve Type" data set in the UMM structure. The enclosed contribution provides comments, practical examples, alternative solutions and supporting justifications on key aspects of the Delegated Regulation. Should any further clarification be required, we remain available and can be contacted using the provided contact information. Please, refer to the enclosed file. Thank you for your attention and consideration.
Read full responseMeeting with Ditte Juul-Joergensen (Director-General Energy)
27 Feb 2024 · Energy infrastructure