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European Energy Retailers - Network of Independent Energy and Solution Providers

EER

To achieve a well-functioning retail energy market, new suppliers and service providers must be able to enter into and compete in the market on equal terms.

Lobbying Activity

Response to Revision of the REMIT Implementing Regulation on data reporting

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 currently drafted in the Implementing Regulation (Article 6), the very low threshold would include stringent reporting obligations on virtually every supplier in the EU: The Draft IR Article 6 requires quarterly exposure reports (positions + forecasted production + forecasted consumption) with a 24-month forward horizon, first reference quarter Q1 2027, per fuel and delivery zone, and including intra-group transactions. A de-minimis exemption applies only if volumes are below 600 GWh per fuel across all three criteria; this is framed as proportionate and ex-ante (to understand hedging) and distinct from MiFID II Article 58 position reporting. However, the very low threshold de facto would cover all suppliers, including small suppliers, and would lead to new cumbersome reporting obligations, audits, and valuable staff time. This adds costly bureaucracy without clear benefits for market integrity. These additional costs may be passed through to customers. EER therefore asks for: 1. Raising the threshold substantially. Focus exposure reporting on genuinely large market players, not on all suppliers. The higher the reporting threshold, the lower the cost for traders and suppliers (30 TWh would be more reasonable, for example). 2. Keeping reporting obligations to a reasonable amount. Limit how often and how far ahead companies must report; granular forecasts that are costly to produce and of limited value should not be required. 3. Avoiding reporting duplication. Use the data already collected by platforms and national regulators; parallel reporting for the same information must be avoided. In a nutshell, setting a higher threshold and a proportionate reporting regime should help to target real risks, avoid creating cumbersome bureaucracy and keep cost pressure low on all stakeholders.
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Response to Requirements for access to data required for switching electricity supplier

17 Jun 2025

Please find EER's response to the consultation attached.
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

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

30 Sept 2022 · Energy crisis

Meeting with Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

30 Sept 2022 · Electricity Internal Market (notably the discussion on the market design reform) Gas Internal market and security of supply / gas savings Energy system integration follow up (including hydrogen) Energy Taxation

Response to Requirements for access to electricity metering and consumption data

5 Sept 2022

The association of European Energy Retailers (EER) supports the initiatives that the SGTF and, more concretely, the Expert Group 1 have developed towards a more integrated and digital Energy Sector. EER has been actively involved in the work and is in general terms pleased with the outcome and the proposed draft Implementing Act. In this sense, we understand that metering and consumption data is the main lever to foster the energy transition. Consumer empowerment is key for full decarbonization and balancing between demand and renewable generation. Empowerment is possible only through a data-driven engagement for new services such as demand-side flexibility, etc. Without suppliers having access to high-quality, timely (near real time) and granular data, consumers will not benefit from tailored services that help them better understand, manage, and optimize their energy consumption. Smart meters are not really “smart” if the data they generate data ultimately does not benefit and empower consumers as active players in the transition. Following the above, regarding the “Draft Implementing Act” we have a very positive view on the roles and responsibilities definition where an agnostic set of participants is defined. Specially setting a leveled playing field for all eligible parties and defining a framework that will eventually allow the creation of independent data hubs throughout Europe. Integrated data hubs managed by an independent party (the ‘metered data administrator’) are the most efficient way to ensure a leveled playing field for all the different stakeholders. However, we would like to highlight that the “draft Act” relies for the implementation on the DSOs and TSOs, giving them a prevalent role among the other eligible parties. In this sense, we would prefer a more heterogeneous approach where other market participants could also have an important role regarding next steps. This could imply creating other Bodies at EU level such as a Retailers EU Body and foster the cooperation between the different eligible parties. Cooperation between market players is key to achieve an efficient, non-discriminatory, and free of charge access to data – with well-defined data characteristics (granularity, type of data, response times, etc.) and recommended data formats for accessing historic consumption data. The main issues for the future data hubs are not only concerning hub development, protocols & rules but, also, about ownership and hub location. Hubs will not be independent if the ownership of this data is not in an independent entity from other eligible parties.
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Response to Action plan on the digitalisation of the energy sector

9 Sept 2021

European Energy Retailers (EER) welcomes the Commission’s Roadmap on the Digitalization of Energy Action Plan. The Commission should aim at achieving a fair use and access to energy data and boost innovative markets and services by ensuring competitiveness, accessibility and consumer engagement. The following two of the five focus areas outlined in the Roadmap are particularly relevant for (independent) energy retailers and energy solution providers: - Developing a European data-sharing infrastructure to create a competitive market for energy services that value demand-side flexibility and support planning and monitoring of energy infrastructure. - Empowering citizens by providing them with tools for participation in the energy markets, tailored data driven services On data access, a set of minimum services offered by metering system operators providing full access to the collected data for all authorised market participants needs to be defined. Non-discriminatory, timely and efficient access to smart meter data shall be ensured (including the load curve) to all market parties that need the respective information for fulfilling their contractual and regulated duties. Direct access to data for retailers and 3rd-party service providers shall be granted based on consent by the consumer, or as defined by law or contractual agreements. Access to detailed consumption data enabled by smart meters represents an opportunity for consumers to access new services to better manage, control and steer consumption, allowing consumers to access innovative services (especially energy efficiency services). However, consumers in most Member States do not (yet) have access to their historical data or to real-time data. As an example, in France, the case of Linky data access is revealing: Since its launch in 2016, 30 million households have been equipped with the new Linky meter but without having access to all the benefits smart meters can bring to consumers as the data registration processes is particularly complex. It would therefore be useful to simplify the Linky data access regime, in order to allow consumers to reap all the benefits from the technology and enable innovative services. Regarding access to data in clean mobility, electric vehicle data is currently usually managed by OEMs/car manufacturers and other players wishing to offer charging control services cannot access this data. Therefore, in order to support the development of clean, electric mobility, it would be necessary to also facilitate access to this data for third parties. Data-driven services and new business models can accelerate the energy transition. Innovative services which pool flexibility from demand side, generation assets and storage devices (including EV batteries) while engaging customers can significantly help accelerating the energy transition by matching flexibility with all kinds of system needs. There is enormous potential in digitalisation, for example, to improve energy services in buildings, while also reducing overall energy use. Smart energy management can: - help ensure that energy is consumed when and where it is needed - enable demand response - predict, measure and monitor in real-time the energy performance of buildings which allows consumers, building managers, and other stakeholders such as service providers to identify when and where maintenance is needed or where energy savings can be achieved.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

European Energy Retailers (EER - www.europeanenergyretailers.eu) agrees on the need for a revision of the energy taxation directive. Such process should be aimed at: · Guaranteeing consistency with the EU climate policy and 2030/2050 objectives · Avoiding distortions between energy products which are not related to the climate impact or to the energy density of the product · Phasing out environmentally harmful tax expenditures in accordance with the G20 agreements · Removing the tax expenditures in favour of the use of oil/solid products in shipping and road transport, in order to support the technology shift towards cleaner fuels (e.g.: LNG, LPG, e-fuels, electricity, etc.).
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