European Energy Exchange AG

EEX

European Energy Exchange is a leading global exchange for energy and commodity products.

Lobbying Activity

EEX Urges EU to Prioritize Market-Based Energy Security

13 Oct 2025
Message — The revised framework should preserve the primacy of market-based mechanisms. Emergency measures like mandatory gas storage must remain temporary. New mandatory requirements should be avoided to preserve flexibility.12
Why — Avoiding market interventions ensures the exchange remains the primary venue for energy trading.3
Impact — Consumers face higher costs when capacity mechanisms distort price signals and competition.4

European Energy Exchange Urges Simpler EU Energy Data Reporting

16 Sept 2025
Message — 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.123
Why — This approach would reduce administrative complexity and prevent costly technical system overhauls.4
Impact — Regulators might have less visibility into trading strategies and niche market activities.5

EEX urges simpler reporting rules and longer implementation timelines

16 Sept 2025
Message — EEX requests removing the obligation to disclose fee-setting methods to regulators. They oppose mandatory back-up arrangements between platforms and seek longer implementation periods. The exchange also wants to eliminate unnecessary registers for data errors.123
Why — This would reduce regulatory costs and protect the commercial flexibility of platforms.4
Impact — Regulators lose direct access to internal data registers and detailed pricing information.56

Meeting with Marieke Scholz (Head of Unit Competition) and Intercontinental Exchange, Inc. and Europex - Association of European Energy Exchanges

10 Sept 2025 · Discussion on the European energy trading markets

Meeting with Lukasz Kolinski (Director Energy)

21 May 2025 · Discussion on the state of European energy markets

Meeting with Ivo Schmidt (Acting Head of Unit Energy)

21 May 2025 · Meeting the Board member and CEO

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

20 May 2025 · Commodity Derivatives Framework and Savings and Investments Union

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

20 May 2025 · ETS Markets

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

28 Mar 2025 · Review of the functioning of EU commodity derivatives markets

Meeting with Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen), Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

19 Mar 2025 · Energy Markets

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

24 Jan 2025 · Energiepolitik

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

6 Dec 2024 · Energiepolitik

Meeting with Christian Ehler (Member of the European Parliament) and RWE AG and

13 Sept 2024 · Energiepolitik - allgemein

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Intercontinental Exchange, Inc. and

11 Jul 2024 · MiFID commodity review

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

31 May 2024 · Energiepolitik allgemein

Meeting with Kurt Vandenberghe (Director-General Climate Action)

30 May 2024 · future of the European ETS

European Energy Exchange demands market-based pricing for renewable auctions

1 Mar 2024
Message — EEX insists that price remain the main award criterion to keep crucial price signals intact. They suggest treating non-price criteria as prequalification items to avoid potential market imbalances. They also warn against widespread usage of Contracts for Difference to protect market liquidity.123
Why — Prioritising market-based auctions prevents state-run contracts from replacing the exchange's core trading functions.4
Impact — Other market participants may find it difficult to hedge risks if liquidity shrinks.5

Meeting with Nicolás González Casares (Member of the European Parliament, Rapporteur)

21 Sept 2023 · MEP González Casares' Team on Electricity Market Design

Energy exchange EEX urges carbon market expansion for 2040 target

23 Jun 2023
Message — EEX recommends including all economic sectors in the EU Emissions Trading System. They also propose integrating carbon removals and increasing the share of auctioned permits.12
Why — Expanding the emissions trading system would significantly increase the exchange's trading volumes and market relevance.3
Impact — Sectors relying on government subsidies would lose financial support in favor of market-based mechanisms.4

EEX warns mandatory virtual trading hubs will fragment markets

23 May 2023
Message — The group urges removing virtual hubs from the proposal to avoid fragmenting the market. They advocate for market-based hedging and supporting collateral requirements for power purchase agreements.12
Why — This protects their existing commercial trading products from regulatory interference and state-mandated competition.3
Impact — Consumers may face increased energy costs due to inefficient cross-border capacity allocation and fragmentation.4

Meeting with Claudia Gamon (Member of the European Parliament, Shadow rapporteur)

26 Apr 2023 · Electricity Market Design

Response to Amendment to Registry Regulation

14 Feb 2023

The European Energy Exchange (EEX) welcomes the initiative for modernization of IT infrastructure of the Union Registry and related structures. As experienced market operator and appointed EU ETS Common Auction Platform, we appreciate overall increased transparency would merit not only the functioning of the market and its infrastructure but also the trust in its well-functioning and oversight. A resilient, modern and user-friendly infrastructure becomes even more important as the EU ETS will soon cover a significantly larger share of the EUs economy and more sectors will require access to the Union Registry. Generally, the amendments proposed in the Draft Delegated Regulation are a welcome step in this direction. For example, EEX welcomes efforts to bring increased transparency and security whilst preserving efficient processes. In its final report from March 2022, ESMA rightly notes that the registry is a valuable source of information. Implementing the recommendation to improve transparency on intragroup transactions is therefore a logical step. Ideally, such changes are implemented in a unified manner that would not prove overly burdensome and would also allow for implementation by a CCP. Inherently part of the most secure trading option, clearing houses provide important services to market participants in terms of facilitating the transfer of allowances and payments. In order to keep these high standards, this additional information would thus also merit access by CCPs for transfers facilitated by itself. Furthermore, also the amendments which would expand the use of trusted account lists, reduce redundant structures and extend access to the Registry to further European authorities, are welcomed. In addition to these steps already initiated, EEX would like to highlight two further potential improvements which may benefit the efficiency of the overall structures. First, we encourage the Commission to consider how to improve the efficiency of some of the operational parts of the accounts, such as upload and authorisation of multiple transactions. Second, we believe that improvements for the use of allowances as bankable assets by enabling secure and enforceable security interests in allowances within the Union Registry merit further exploration which can contribute to greater cost-efficiency of the European carbon and commodity markets. This could be achieved, for example, by a registry feature for electronic earmarking to continuously identify a security claim regarding an allowance in the registry.
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Meeting with Matthias Ecke (Member of the European Parliament)

27 Jan 2023 · Meinungsaustausch zur Energie- und Industriepolitik

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and Europex - Association of European Energy Exchanges

13 Dec 2022 · Market Correction Mechanism

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

21 Sept 2022 · Energy Markets

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

8 Sept 2022 · Winter preparedness

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

6 Sept 2022 · Short-term and long-term markets for the trading of power and gas, as well as related commodities such as emission allowances

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

14 Sept 2021

EEX welcomes the opportunity to take part in the consultation on the review of the Directive on the promotion of the use of energy from renewable sources. We support the review of the directive, including the reconsideration regarding the renewable energy targets, marking an essential step into the right direction to meet the objectives set under the Green Deal and transform the EU into a carbon neutral economy by 2050. We notably welcome the fact that the proposal focuses on advancing the further market integration of renewables. This includes (i) the promotion of green power purchase agreements (PPA), (ii) strengthening the role of guarantees of origin (GOs) as well as the (iii) reinforcement of higher sustainability criteria regarding biomass. In the following we will further elaborate on the different aspects of the RED II review. (i) We strongly support the proposal for a stronger promotion of PPAs to increase the level of renewable electricity supply within the EU. Financing and marketing renewable energies through PPAs helps to integrate them into the electricity markets as the optimization of market income becomes the guiding parameter and not the optimization of subsidies. Consequently, the electricity market price signals are strengthened and fully reflect the physical reality of the electricity system providing for an economic incentive for a system-friendly dispatch. Additionally, the electricity market price signal becomes the link for the integration of sectors. Today, PPAs have already become an essential part in subsidy-free private renewable investments. Contributing positively to the set-out goals in the Green Deal, EEX will introduce its 10-year power futures in September 2021. By extending its product curve to ten years, market participants can hedge prices and mitigate the counterparty risk resulting from concluded PPAs for a full decade on the exchange and its clearing house (CCP). Providing cost-efficient market based hedging instruments is key for a fast energy transition. It is therefore essential, that such market-based instruments are not crowded out through public actors transferring the risk of mature technologies to taxpayers (ex. CfDs). The removal of unjustified subsidies as well as other regulatory and administrative barriers as proposed by the Commission, including those related to permitting procedures, facilitate an active support towards the energy transition in Europe. (ii) We support the proposal to strengthen the role of GOs regarding the market integration of renewables. As stated in the proposal, the possibility of certain member states to withhold GOs for electricity generators benefitting from subsidies should be removed. A removal would allow renewable electricity generators to benefit from additional market-based remuneration opportunities, supporting the use of PPAs, and eliminating the need of subsidies for mature renewable technologies. However, extending the emission of GOs needs to be accompanied by measures strengthening the role of GOs. Regarding the proposed minimum capacity limit, we would recommend the Commission to allow for finer granularity in the future, as over time, administrative costs may reduce using new technologies and processes. An unnecessarily detailed regulatory framework could inhibit the integration of small-scale renewable installations into the market. (iii) Regarding the support of biomass, we favor the Commission’s proposal. As correctly illustrated, the phase-out of any support to produce electricity from forest biomass in electricity-only-installations is necessary to be aligned with the targets set-out in the Green Deal. Instead, we advise to strengthen the use of biomass for heat-production incl. combined-heat-power to be primarily used to decarbonize industrial processes as well as district heating. Additionally, higher sustainability criteria increase trust in the market through incentivizing adequate production and usage of biomass.
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Response to Revision of EU rules on Gas

10 Mar 2021

EEX welcomes the Commission´s initial impact assessment / roadmap for the hydrogen and gas markets decarbonization package. Scaling up markets for clean hydrogen affects many dimensions that require coordinated European answers and framework conditions. We are convinced energy trading markets are enablers of a hydrogen economy helping to provide a broad access to the energy carrier to diverse actors from all sectors. Also, trading markets for decarbonized gases offer producers an income option beyond subsidies and should play a significant role in the gas package. In our response to DG ENER´s consultation on the IIA/roadmap, we line out why we believe so and what we consider necessary as a regulatory framework.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

EEX welcomes the increase of the 2030 ambition as a pivotal step for Europe to achieve its climate targets and assert its role as global climate action leader. Emissions markets will be a crucial instrument in delivering on Europe’s long-term climate ambitions. EEX has been providing an organised market for European Emission allowances (EUA) since the inception of the EU ETS in 2005. Since 2012, EEX also operates the common EU ETS auctioning platform. Building on this experience, we believe the scheme is key in achieving the EU climate objectives at the lowest possible cost, with focus on using its full potential. Therefore, we strongly support the European Commission’s objective of strengthening the EU ETS with this review exercise. To strengthen the EU ETS and carbon price signal, it is of importance to align the emissions cap with the increased target for 2030. First and foremost, this is achieved by a clear long-term framework for the Linear Reduction Factor (LRF) which contributes to the system’s predictability and functioning of the market in the most efficient way. The longer the LRF is left unmodified, the more rapid decarbonisation will be required. The Market Stability Reserve, based on volume triggers, provides an additional policy to manage volumes and has notably addressed the surplus of allowances since January 2019. The legislative changes agreed in recent years continue to show positive results. In addition, an increased ambition for the EU ETS should be combined with an increased auctioning share. The objective of gradually moving to full auctioning is fundamental to the objective of emissions trading as it guarantees costs of carbon are internalized. This is all the more relevant given that auctioning revenues make a significant contribution to climate action in Europe. Integrating additional sectors into emissions trading at EU level presents important benefits in terms of effectiveness and harmonization. While other climate policy instruments remain important, there needs to be a holistic framework at EU level that incentivizes carbon abatement in a market based and most efficient manner. The expansion of the ETS to sectors such as buildings and road transport will ensure an efficient decarbonisation and provide market actors with a strong price signal to guide their economic activity. The whole market, including all market participants, directly benefit from a larger, more efficient market with increased liquidity. Therefore, the European Commission should aim to integrate these sectors into the EU ETS in the long term. In addition, given that no international climate scheme for maritime currently exists, EEX supports placing at least intra-EU shipping in the EU ETS. The EU ETS plays a vital role as the EU’s primary instrument for reducing greenhouse gas emissions cost-effectively while incentivising innovation and change. Allocation of the Modernisation and Innovation Funds should occur in a consistent manner with the EU’s higher climate targets. The emissions trading price signal is the basis for efficient attainment of greenhouse gas emissions targets, with free market pricing being decisive for this. It is fundamental to the system’s continued success to maintain this approach. Artificial pricing mechanisms such as the use of Carbon Contracts for Difference can lead us away from market principles and risks a negative impact on the carbon market and system integration. Strengthening the carbon price by setting an appropriate cap and LRF should be prioritized as it will ensure the EU ETS carbon price allows low carbon technologies to be competitive in the long run. We discourage alternatives that interfere with the functioning of the primary or secondary markets, such as a discretionary price management mechanism, a carbon price floor or carbon contracts for difference, because of their incompatibility with the core ETS design as a volume-based instrument with free price formation.
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Response to A EU hydrogen strategy

8 Jun 2020

EEX welcomes the Commission´s initiative to publish a dedicated EU hydrogen strategy. Scaling up markets for clean hydrogen affects many dimensions that require coordinated European answers and framework conditions. We are convinced energy trading markets are enablers of a hydrogen economy helping to provide a broad access to the energy carrier to diverse actors from all sectors. In our response to DG ENER´s consultation on the hydrogen strategy roadmap, we line out why we believe so. Given the complexity of the topic, EEX would welcome stakeholder involvement also in the actual EU hydrogen strategy.
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Response to Strategy for smart sector integration

8 Jun 2020

European Energy Exchange (EEX) considers the use of cross-sector potential the decisive factor for the speed and success of the energy transition. An integrated energy system offers the possibility to release system and grid flexibility and to put infrastructure and resources to their best use, i.e. for the market and ultimately for the end consumer. Integrating all forms of decarbonized energy supply and consumption is key to reach the 2030 and 2050 goals. Energy exchanges are the exemplification of sector integration: market participants from different sectors (utilities, municipalities, industrial consumers, etc.) already today trade energy commodities on the markets of energy exchanges - connected through efficient price signals providing for incentives to connecting sectors and providing for the needed trading markets: Meaningful spot market power prices fully reflecting the physical reality of the system incentivize different uses of electric power in different sectors, different forms of low-carbon power production and flexibility providers. As such, they are a connecting link between markets. Already today, renewable energies are integral part of EEX Group´s electricity markets, both on spot as well as on derivatives. Electricity prices reflecting exclusively the physical situation of the system instead of the subsidy level drive system friendly dispatch Far-reaching market-based prices for CO2 for different sectors within the ETS have the power to connect different sectors alongside the power price signals. With that, low-carbon and decarbonized energy carriers gain competitiveness over fossil energy carriers. European markets for Guarantees of Origin (GoOs) for all energy carriers allow for transferring the “greenness” between energy carriers and as such are another link between sectors. If designed accordingly they may also provide a meaningful source of revenues for decarbonized and low-carbon energy carriers. Liquid gas markets integrate renewable gases easily and connect them to power, emission and GoO-markets and as such bring further flexibility into the system. Markets for hydrogen to be established in the future could either be an integral part of the gas markets or tradable on separate markets. Consumption and production of green hydrogen shall be orchestrated through connected energy markets. EEX very much welcomes a European approach to reach an integrated Energy system, particularly we see need for harmonization where possible to allow the development of liquid and integrated European energy markets. Please also refer to EEX´s response on the Roadmap for an EU Hydrogen Strategy for further considerations.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

SUMMARY (full response see attachment) The Roadmap for a Directive on a Carbon Border Adjustment Mechanism names several requirements for such policy. It is expected to ensure that the “price of imports reflect more accurately their carbon content”. It also states that “the complementarity of the measure with internal carbon pricing, in particular the EU ETS, will also have to be assessed, as well as how it relates to the current measures to avoid the risk of carbon leakage. […] The measure should be commensurate with the internal EU carbon price. Against the background of these policy objectives, EEX sees the following key principles for the design of a carbon border adjustment mechanism should it be implemented: Key principles for a carbon border adjustment mechanism A carbon border adjustment mechanism should be as closely as possible integrated with the existing EU Emissions Trading Scheme. The most straightforward way to do this would be the inclusion of imports in the EU ETS as listed as an option in the inception impact assessment. Importers would be required to surrender EU Emission Allowances for goods which they import to the EU. This policy approach has several significant advantages over alternatives, such as an import tax/tariff or product standards:  An inclusion of imports in the EU ETS would ensure full compatibility with carbon pricing in the EU and the existing energy and climate policy framework. The existing infrastructure of the EU ETS could be used for implementation.  The price importers pay would be fully transparent and equal to what EU producers are paying, providing a clear and easily comparable measure for their efforts. They could rely on the liquid and efficient EU emission market to manage their exposure.  Inclusion in the EU ETS provides an optimal basis for increasing cooperation between jurisdictions. Other regions would be encouraged to monitor and track emissions in line with the EU ETS, increasing compatibility between different climate policy regimes globally. The introduction of a carbon border adjustment mechanism for a sector has to be linked to a gradual phaseout of free allocation. The policy objective of such mechanism is to provide an alternative to free allocation and counter some its disadvantages. For reducing administrative complexity, any mechanism should use existing standards, infrastructure and common EU benchmarks already used today for policies to limit carbon leakage. A decrease in free allocation has to be matched with an increase in the auctioning share. Auctioning is the default allocation method for allowances in the EU ETS. It is the most transparent allocation method, providing a transparent, harmonised and non-discriminatory process. The principle of auctioning, and the objective of gradually moving to full auctioning, is fundamental to the objective of emissions trading as it guarantees costs of carbon are internalized. Auctioning revenues make a significant contribution to climate action in Europe. In 2018, revenues for the EU’s Common Auction Platform alone amounted to more than 14 billion Euros. Member States spent or planned to spend close to 70% of these revenues for specified climate and energy related purposes over the course of the year1.
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Response to Climate Law

31 Jan 2020

EEX is the leading energy exchange in Europe and part of EEX Group, the largest electricity exchange, the second largest CO2 exchange and third largest gas exchange in the world. EEX develops, operates and connects secure, liquid and transparent markets for energy and commodity products. At EEX, contracts on power, emission allowances as well as freight and agricultural products are traded or registered for clearing. EEX is part of Deutsche Börse Group. 1. EU Emissions Trading Scheme The expansion of the ETS to other sectors of the economy, such as maritime and road transport, is necessary for at least three reasons: 1) to ensure non-ETS sectors also decarbonise efficiently; 2) to provide market actors with an integrated price signal across industry, energy and transport sectors, and guide their economic activity and decarbonisation efforts; 3) to ensure global connectivity across national carbon markets across the world and pave the way for a global market. 2. Smart sector integration Electricity and carbon emission market prices are critical signals for effectively integrating and connecting different sectors. Energy trading markets can help achieving climate goals by efficiently integrating renewable energies into the power system, providing a price tag for CO2 emissions, helping to efficiently use and produce green gas resources and connecting all these different segments. 3. Climate diplomacy EEX sees as extremely positive that Europe exports its climate action policies best practices to other regions of the world. EEX has been supporting such actions by being an ambassador of, in particular, the EU ETS and carbon markets across the world, as well as concretely helping countries rolling out similar systems in their jurisdictions. 4. Guarantees of origin for gas and electricity Tracking the origin of electricity and gas is key to assess how clean energy generation is, and to support green energy generation installations accordingly and transparently. The current system of European guarantees of origin for power is functioning well but should be further expanded across all European Member States and into non-renewable power, natural gas (including hydrogen) and heating & cooling, to guarantee fair and transparent treatment of energy sources and inform consumers. 5. Gas and gas infrastructure EEX does not consider an “all-electric” scenario for the EU feasible. Natural and renewable gas, in particular, will play a critical role in helping decarbonising the European economy to 2030, 2050 and beyond. To this extent, the existing gas transport infrastructures should be optimised using market-based mechanisms and security of supply, as well as gas price transparency, should be strengthened through market-based competition. 6. Carbon border mechanism EEX agrees on the need to address possible carbon leakage within the European Union, as well as supporting European business competing in the global market by creating a level playing field across different national jurisdictions. The carbon border mechanism proposal should focus on specific pilot sectors. Compatibility and comparability should be its cornerstone. 7. Subsidies and taxation Tax and subsidies policies convergence is crucial to align government and corporate efforts towards climate action. Fair and transparent taxation systems, harmonised across Member States, allow a strong price signal to effectively coordinate market dynamics across the entire energy value chain. This brings transparency to how climate action costs are socialised and benefits the final consumer. 8. Impact assessment It is paramount for the European Commission to carry out an in-depth analysis to establish the impact of different policy mixes on the European economy and society. EEX is happy to support the European commission with figures and considerations on the role energy, commodity and environmental markets can play going forward.
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Meeting with Günther Oettinger (Commissioner)

21 Apr 2017 · digitising energy

Meeting with Dominique Ristori (Director-General Energy)

29 Sept 2016 · European Internal Energy Market