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Europex - Association of European Energy Exchanges

Europex

Europex represents European energy exchanges and focuses on the regulatory framework for wholesale electricity, gas and environmental markets.

Lobbying Activity

Meeting with Christian Ehler (Member of the European Parliament) and EnBW Energie Baden-Württemberg AG and

12 Dec 2025 · Energiepolitik

Meeting with Andrea Wechsler (Member of the European Parliament) and Stadtwerke München GmbH

5 Nov 2025 · Energy and Industry Policy

Meeting with Kitti Nyitrai (Head of Unit Energy) and FuelsEurope and

3 Nov 2025 · EU Methane regulation import requirements

Europex Urges EU to Prioritise Markets in Security Framework

13 Oct 2025
Topic — The European Commission is revising legislative frameworks to improve energy system resilience.
Message — Market mechanisms must remain the primary tool for ensuring energy system supply. Emergency measures should be strictly limited in time and as last resort. The framework should focus on better coordination instead of new intervention layers.12
Why — Protecting free price formation ensures the long-term viability of energy exchange markets.3
Impact — Consumers may face higher risks if interventions like peak-shaving tighten energy supply.4
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Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

26 Sept 2025 · Energy policy

Europex Urges EU to Simplify Rules for Energy Reporting Platforms

12 Sept 2025
Topic — New rules for authorising and supervising energy data reporting platforms and mechanisms.
Message — The association requests simplified authorisation and a reduction in redundant administrative data submissions. They seek to extend reporting correction deadlines and lower the mandatory system availability targets. They also propose removing complex new data fields like curve types to maintain usability.1234
Why — A simplified process would prevent redundant data submissions and reduce long-term operational costs.567
Impact — Regulators would lose access to a centralized register of errors for monitoring market compliance.8
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Europex urges 18-month delay for energy data reporting rules

12 Sept 2025
Topic — Revision of EU rules for reporting wholesale energy market trading data.
Message — 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.123
Why — A longer transition period prevents wasted development costs and technical compliance risks.4
Impact — Market regulators face delays in receiving the enhanced data required for oversight.5
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Meeting with Marieke Scholz (Head of Unit Competition) and Intercontinental Exchange, Inc. and European Energy Exchange AG

10 Sept 2025 · Discussion on the European energy trading markets

Meeting with Dan Jørgensen (Commissioner) and

2 Sept 2025 · Proposal for the revision of the Capacity Allocation Congestion Management Regulation

Europex urges full CBAM exemption for electricity market coupling

26 Aug 2025
Topic — This consultation explores extending the carbon border adjustment mechanism to downstream products.
Message — Europex requests a full exemption for electricity market coupling to avoid trading disruptions. They also seek long-term regulatory certainty and a reassessment of these rules.12
Why — Exemptions would prevent significant cost increases and preserve existing power market efficiency.3
Impact — Households and industries face higher power bills, particularly in South-Eastern Europe.4
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Meeting with Andrea Wechsler (Member of the European Parliament) and NATURGY ENERGY GROUP

15 Jul 2025 · EU Energy and industry policy

Meeting with Anna Stürgkh (Member of the European Parliament)

14 Jul 2025 · CACM 2.0

Europex urges inclusion of delegated operators in switching rules

17 Jun 2025
Topic — This consultation addresses interoperability and data access requirements for switching electricity suppliers.
Message — Europex proposes including delegated operators to reflect their roles in several European countries. They suggest specific text amendments to ensure these entities can manage registrations and technical testing.12
Why — This change would provide legal recognition for exchanges already performing these administrative tasks.3
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Meeting with Jens Geier (Member of the European Parliament)

2 Apr 2025 · Exchange on the Gas Storage Extension Regulation

Europex demands decentralized energy markets and no price caps

31 Jan 2025
Topic — This consultation seeks to further integrate the Single Market and promote cross-border services.
Message — They want full implementation of existing energy laws and expansion to neighboring nations. They demand the preservation of decentralized market governance and investment in grid infrastructure. Finally, they urge the Commission to avoid new reforms or price caps.1234
Why — Avoiding new reforms protects the existing business models and stability of energy exchanges.5
Impact — Energy consumers lose out on protections against extreme price volatility during supply crises.67
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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 EPIA SolarPower Europe and

13 Dec 2024 · Energy policy

Europex demands flexible emission rules for low-carbon fuel investment

25 Oct 2024
Topic — This consultation defines the methodology for calculating greenhouse gas savings of low-carbon fuels.
Message — The group asks to use actual performance data instead of conservative default values for emissions calculations. They also urge the Commission to allow low-carbon electricity contracts before 2028 to avoid holding back investments.12
Why — This would lower reported emissions for efficient producers and unlock crucial investment capital.3
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Meeting with Christian Ehler (Member of the European Parliament) and RWE AG and

13 Sept 2024 · Energiepolitik - allgemein

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

11 Jul 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

Europex urges price to remain primary renewable auction criterion

1 Mar 2024
Topic — EU initiative to harmonize renewable energy auction design and support wind power.
Message — Europex argues that price must remain the primary award factor to preserve market signals. They suggest treating qualitative criteria as a pre-qualification step rather than a scoring element. Auctions should prioritize cost efficiency and direct connections to wholesale energy markets.123
Why — Prioritizing wholesale market-linked auctions protects the trading volume and relevance of energy exchanges.45
Impact — Other market participants face reduced liquidity and harder long-term hedging due to state-managed contracts.6
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Response to Review of the scope and third-country regime of the Benchmark Regulation

23 Jan 2024

BMR review: call to maintain and improve small commodity benchmark exemption, in case Annex II commodity benchmarks are to remain in scope Brussels, 23 January 2024 | Europex welcomes the Commissions proposal to review the Benchmark Regulation (BMR) with regard to its scope, the use of benchmarks and certain reporting requirements. We explicitly support the approach to reduce the scope of the BMR without a complete overhaul of the regulatory framework. This will especially help users of third-country commodity benchmarks in the EU which are not deemed significant for EU markets. It will also provide for a more proportionate framework for administrators of small commodity benchmarks subject to Annex II that are not contribution-based and could therefore not benefit from the small commodity benchmarks exemption outlined in Article 2(2)(g). This said, we are concerned by the Councils proposal to extend the full scope of the BMR to all Annex II commodity benchmarks, incl. to non-significant benchmarks, based on the argument that this would help to lower price volatility. Indeed, if implemented, this could even have the opposite effect, exacerbating commodity price volatility, with EU users effectively becoming prohibited from using benchmarks which are vital to their day-to-day risk management capability. In addition, it would also put these users at a competitive disadvantage to their peers in other jurisdictions outside the EU. Considering the Councils position, it is important to note that the Commission proposes to delete the current exemption for non-significant commodity benchmarks in Article 2(2)(g) as this would no longer be required, if non-significant commodity benchmarks were no longer in scope. However, should the co-legislators decide differently and keep all or some commodity benchmarks in, incl. non-significant commodity benchmarks, it is crucial to ensure that the exemption is maintained and improved to allow the existing non-significant benchmarks to keep serving as important and widely used references without imposing new, unproportional requirements on them. Indeed, a large number of firms, many of them energy utilities and the wider industry, rely on this type of benchmark for managing their price and volume risks. Morover, the current BMR Annex II definition of commodity benchmarks seems to negate the existence of commodity benchmarks that are not contributor-based. Hence, the small commodity benchmark exemption in Article 2(2)(g) currently only applies to small contributor-based commodity benchmarks but not to small non-contributor-based benchmarks. Should the co-legislators decide that Annex II commodity benchmarks are to be put back in scope, it is crucial to maintain / reintroduce the small commodity benchmark exemption and to ensure that all small commodity benchmarks subject to Annex II can benefit from the exemption (i.e., contributor-based and non-contributor-based commodity benchmarks alike). Finally, and in line with the general policy objective to rationalise the BMR application, we recommend increasing the maximum total notional value of financial instruments referencing the benchmark from 100 million EUR to at least 500 million EUR in Article 2(2)(g). As the notional value is not a common reference for commodity markets due to their inherent price volatility, market participants typically look at lots instead. A higher notional threshold of 500 million EUR would therefore provide some relief / rationalisation, allowing for more flexibility in naturally volatile commodity markets.
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Meeting with Jens Geier (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

12 Jan 2024 · Exchange on industrial and energy policy

Response to Network Code on Cybersecurity

17 Nov 2023

Europex and the All NEMO Committee welcome the opportunity to respond to the Commission consultation on the draft Commission Delegated Regulation establishing a Network Code for Cybersecurity Aspects of Cross-Border Electricity Flows (NC CS). Our membership includes Nominated Electricity Market Operators (NEMOs) as well as Organised Marketplaces (OMPs), which both fall within the scope of the draft NC CS provided that they are identified as high-impact or critical-impact entities. While we generally support the initiative to enhance cybersecurity in the energy system, as far as the current draft is concerned, we call for crucial improvements in relation to stakeholder involvement, planning certainty, alignment with other legislative acts and existing international standards, as well as proper safeguards for sensitive information and more inclusive provisions on cost recovery. For a more detailed feedback please see the submitted PDF.
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Meeting with Maria da Graça Carvalho (Member of the European Parliament, Rapporteur)

6 Oct 2023 · REMIT, third countries office requirement, role of ACER, sanctioning powers for market manipulation cases, publication of inside information, role of energy exchanges

Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

27 Jun 2023 · REMIT (Staff Level)

Meeting with Patrizia Toia (Member of the European Parliament, Shadow rapporteur)

12 May 2023 · REMIT Regulation (meeting held by the APA responsible)

Meeting with Maria da Graça Carvalho (Member of the European Parliament, Rapporteur)

25 Apr 2023 · REMIT

Meeting with Esther De Lange (Member of the European Parliament)

20 Feb 2023 · MiFiR/D - APA

Meeting with Aurore Lalucq (Member of the European Parliament)

16 Feb 2023 · MIFID

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

20 Dec 2022 · ETS

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and European Energy Exchange AG

13 Dec 2022 · Market Correction Mechanism

Meeting with Kadri Simson (Commissioner), Kadri Simson (Commissioner) and

6 Dec 2022 · Market Correction Mechanism.

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur)

4 May 2022 · Gas storage regulation

Response to Prolongation of the optional reverse charge mechanism and the Quick Reaction Mechanism

5 Apr 2022

Europex explicitly welcomes and fully supports the Commission’s legislative proposal to extend the derogation in Article 199a of the VAT Directive allowing Member States to apply the domestic reverse charge mechanism (DRCM) to transactions in electricity, gas, emission allowances and Guarantees of Origin (GOs). We consider this extension to be essential for the integrity and safety of European energy, emissions and GO markets. However, a longer extension would have been preferable beyond the proposed 3.5 years until the end of 2025 past the current sunset date of 30 June 2022. Indeed, a complete deletion of a sunset date would be most useful to avoid the need of regular extensions which require time and resources by both institutional as well as industry stakeholders. Please see our detailed comments below: 1. Prolonging the existing derogation is vital to prevent Missing Trader Intra-Community Fraud in energy and emissions markets in Europe: The DRCM is a vital tool to help prevent Missing Trader Intra-Community (MTIC) fraud in high-volume, high-value energy, emissions and GO markets in Europe which constitute potentially lucrative targets for specialised and skilled VAT fraudsters. In recent years, there have been significant cases of MTIC fraud in Europe, amounting to several billion euros frauded from Exchequers across the region. In addition to the direct financial losses, this had a significant impact on the functioning and reputation of the concerned markets. 2. The derogation should be comprehensively applied by all Member States: Where Member States are applying this derogation, it has proven to be an effective tool in the prevention of MTIC fraud. Currently, however, not all Member States make use of the derogation and not for all products. To reduce the risk of fraud in unprotected markets, Article 199a should be applied across all Member States and in a comprehensive manner – for electricity, gas, emissions and guarantees of origin alike. This will prevent fraud from shifting to markets in unprotected Member States and will ensure that trust is maintained in the integrity and safety of these markets as an essential part of the economic value chain in Europe. 3. Explicit mentioning of GOs issued for heating and cooling: Europex would like to use this opportunity to call for an explicit extension of the derogation to also include GOs issued for heating and cooling. As part of the Clean Energy Package adopted in 2018, Article 19 of the recast of the Renewable Energy Directive (RED II) had been extended to also include Guarantees of Origin (GOs) for renewable gas (including hydrogen and others) as well as heating and cooling. However, Article 199a 1(f) of the VAT Directive currently only includes certificates for supply of natural gas and electricity and does not include these additional GOs.
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Response to Updating the EU Emissions Trading System

5 Oct 2021

Europex welcomes the holistic ‘Fit for 55’ Package as a decisive step towards achieving Europe’s green transition. The package underlines the common understanding that competitive energy and emissions markets must drive decarbonisation efforts to achieve the EU’s green policy objectives at least cost to the economy and consumers, while ensuring a high level of competition and innovation. As Europe’s primary policy tool to combat climate change, the review of the EU ETS plays a fundamental role in delivering the EU’s ambitious 2030 and 2050 decarbonisation targets and broader Green Deal objectives. Such a review must ensure continued commitment to strong market principles that safeguard the undistorted price signals, efficiency, transparency and liquidity of the emissions market. 1. The Commission’s proposal to increase the emissions reduction contribution from those sectors covered by the EU ETS to 61% by 2030 is a natural first step towards achieving the increased decarbonisation targets of 2030 and 2050. This will ensure that market-based mechanisms continue to successfully reduce greenhouse gas (GHG) emissions at least cost. 2.Europex welcomes the increase of the LRF to 4.2% to tighten the annual supply of allowances and bring it in line with the increased decarbonisation targets accordingly. A clear, long-term increase of the LRF is preferable over a one-off rebase of the cap because it avoids big step changes that may impact market predictability or lead to sudden market movements. However, we appreciate that a one-off downwards rebasing of the cap may be implemented as an exceptional measure limited in scope and impact (i.e. not go beyond the “as if the new LRF rate would have applied already from 2021”) and, most importantly, be communicated in a timely manner. 3. An increase of auctioning and a clear phase-out plan to end free allocation will provide the greatest possible predictability for market participants. increased climate ambition should be seen as an opportunity to increase the share of auctioned allowances above 57% as currently set in Article 10. A more concrete free allocation phase-out timeline for all sectors – beyond aviation or those sectors in scope of CBAM - should be included. A linear and continuous increase of the auctioning share would provide the greatest possible predictability to the market and will spur innovation and decarbonisation in the industrial sectors for which its inclusion on the EU ETS havenot yet yielded substantial reductions in emissions. 4. The time horizon for free-allocation phase-out for CBAM sectors should be reduced. 5. Europex welcomes the proposals to update its thresholds to extend the 24% TNAC intake rate and adjust the intake mechanism thresholds, as well as to include aviation emissions and allowances from the maritime sector in the TNAC calculations. 6.The integration of the maritime transport activity into the EU ETS will present important benefits for the reduction of emissions in the shipping sector. In particular, the introduction of full auctioning of allowances will help to efficiently achieve the desired decarbonisation targets in the maritime sector. 7. A new, adjacent ETS for buildings and road transport is an ambitious yet necessary step towards reaching the climate objectives. 8. Europex stresses the importance of carefully deliberating the necessity of introducing potentially market distortive instruments, such as CCfDs, into the EU ETS. CfDs may raise problems for the emissions forward market by interfering with the free price formation of the EU ETS and, thus, may have a major impact on competition and trade across-all sectors included therein. Notably, the need for hedging may decrease if state-backed CCfD instruments artificially secure a future carbon price. This would in turn reduce overall liquidity and interfere with the free price formation, among other. Please refer to our paper (attached) for more details.
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Response to Delegated Act on the Ancillary Activity Exemption

24 Jun 2021

Europex welcomes the opportunity to provide feedback to the Commission’s public consultation on the draft delegated act for amending the ancillary activity exemption (AAE) in MiFID II. We welcome the suggested changes in the draft delegated act and firmly support the proposed text. In particular, Europex supports the discontinuation of the market size test and the annual notification requirement, the introduction of a de-minimis test and the adaptation of the threshold level of the trading and capital employed tests. These measures simplify the calculations and reduce the compliance burden for market participants. The suggested improvements are therefore in line with the MiFID II Quick-Fix objective to remove unnecessary red tape and strengthen the development of European commodity derivative markets. Finally, Europex welcomes that the new Delegated Act will apply shortly after its publication in the Official Journal. This will guarantee an efficient transition to the amended AAE regime and provide the necessary legal certainty to the market.
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Response to Union Renewable Development Platform (URDP)

27 May 2021

Europex welcomes the opportunity to provide feedback to this draft delegated regulation. While the current proposal for the Union Renewable Development Platform (URDP) is designed to facilitate statistical transfers between Member States and the entry into subsequent bilateral negotiations, pursuant to Article 8 RED II, we believe that arranging auctions for statistical transfers would provide greater benefits in terms of efficiency and price discovery. The URDP could be upgraded to this purpose and amendments could be made as necessary in the upcoming RED III proposal. The URDP aims to reduce administrative hurdles related to statistical transfer arrangements between Member States by providing information and indicating potential opportunities for such transfers. The current proposal foresees a non-binding matching mechanism of demand for and supply of statistical transfers, whereby Member States can indicate the volume, price and timeframe and any additional conditions related to the transfer. Auctions, however, would provide several advantages due to their simplicity, transparency and efficiency compared to other allocation methods. At its core, an auction is a selection process designed to allocate specific goods and services in a competitive and efficient manner. There are diverse types of auction designs that can be used depending on the context, but auctions would have a number of advantages over bilateral negotiations, including in the context of statistical transfers: - Efficient price discovery: Unlike bilateral negotiations, the ‘seller’ (in this case the Member State with surplus renewable energy) seeks competing bids from potential buyers. The anonymity of an auction process means that bids will reflect Member States’ true willingness to pay for the relevant statistical transfers, and that the transfer will be valued at a price which more accurately reflect the supply and demand situation. - Pooling of liquidity: Regular auctions, with standardised pre-agreed terms will help to bring together more Member States as potential buyers and sellers of statistical transfers. We believe that the benefits of a standardised auction process that can be run regularly up to 2030 and beyond to help Member States (collectively) achieve the set targets would outweigh any costs related to its initial set-up or other limitations concerning the relatively low number of ‘participants’. - Auctions are a well-established and trusted mechanism that help to achieve a fair, open, and timely procurement process, reducing opportunities for manipulation. Such a method would be politically neutral and help to avoid any potential disputes or discrimination among the Member States. - An expedited transaction timetable as compared to bilateral negotiations. As the information disclosed by the seller on the transfer is standardised, this can help to avoid protracted negotiations. In addition, it sets a clear timeframe for the statistical transfer. As energy market infrastructure providers, our members have broad experience in facilitating auctions in both the energy and emission markets. While we understand that the URDP initiative is at its inception phase, we do see value in enhancing the platform to host auctions in view of contributing to the collective achievement of the Union’s renewable energy target for 2030 and beyond. To this end, Europex believes that an upgraded URDP in the Renewable Energy Directive III could benefit from allocating statistical transfers via auctioning, ensuring that transfers are made in the most efficient, fair, objective and transparent manner.
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Response to Revision of EU rules on Gas

10 Mar 2021

Feedback from Europex, the Association of European Energy Exchanges. The progressive evolution of the gas legislative framework is a necessary prerequisite to ensure gas markets are ready to integrate and foster the use of renewable and low-carbon gases while maintaining a high-level of security of supply and guaranteeing an efficient price formation. Traded markets for hydrogen and other decarbonised gases, supported by dedicated certificates and/or Guarantees of Origin (GOs), will have a key role to play in the decarbonisation of the EU energy system, in line with the European Green Deal and the 2030 and 2050 targets. In addition, traditional natural gas markets will need to remain in place during the transition period and their well-functioning must not be undermined. The future regulatory framework for decarbonised gases should build, to the extent possible, on the successful blueprint of the existing European wholesale gas market, which has established well integrated markets and liquid trading hubs. Although traded markets for renewable and low carbon methane and hydrogen are not yet mature, establishing clear principles in the regulatory framework (including non-discriminatory network access, clear unbundling rules and cross-border interoperability) will support the uptake of decarbonised gases and will help to provide the predictable framework needed for liquid and competitive gas markets. Please see Europex' full feedback in the attached paper.
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Response to Digital Levy

10 Feb 2021

Europex, the Association of European Energy Exchanges, supports the Commission’s overall objective to ensure a fair taxation of the digital economy in line with the wider G20 and OECD discussions and welcomes the opportunity to comment on the scope of the initiative. As stated in the Inception Impact Assessment (IIA), it is important that the Commission accurately determines the scope and definition of digital activities, transactions and entities subject to the digital levy. This is a crucial part of the preparatory work for a legislative proposal, considering the great variety of business models and companies active in the digital economy. While we understand that the initiative is in principle directed at companies conducting digital activities in relation to “social media, online search engines, news and streaming of content, etc. ”, we are concerned that a too broadly defined scope of what constitutes a ‘digital company conducting a digital activity’ will lead to a situation where certain digital financial services might unintentionally fall under the new tax. If accidentally applied to wholesale energy trading, this unintended inclusion could significantly increase the risk management costs of the real economy and eventually lead to higher energy prices for the end-consumer. Europex therefore calls upon the Commission to further refine the definition and clearly specify the scope of the future digital levy for “social media, online search engines, news and streaming of content, etc.” and to ensure that energy trading and financial services do not accidentally become a part of it.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Please see attached paper.
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Response to A EU hydrogen strategy

8 Jun 2020

Europex welcomes the Commission ́s initiative to develop a dedicated EU hydrogen strategy. Scaling up markets for clean hydrogen will require a coordinated European approach in several areas, as well as the establishment of a European regulatory framework. We are convinced that traded markets can and will act as enablers for a future usage of hydrogen on a broader scale. To this end, it will be vital to ensure that hydrogen markets provide competitive, non-discriminatory and fair access to hydrogen, which will underpin the efficient use of hydrogen in all relevant sectors, including those where it still has very limited penetration such as transport, buildings and power generation. Given the importance and complexity of the topic, there should be strong stakeholder involvement in both the development and implementation of the EU hydrogen strategy. Please see our full feedback in the attached paper.
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Response to Action Plan on anti-money laundering

11 Mar 2020

See provided file
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Response to EU emissions trading system – adjusting the auction process for the period 2021-2030

6 Aug 2019

Please see attached file for our detailed feedback. Europex welcomes the opportunity to comment on the proposal for a Commission Delegated Regulation to align the auctioning of allowances with the EU ETS rules for the Fourth Trading Period and with the classification of allowances as financial instruments as published on 9 July 2019. We have taken particular positive note of the following suggested changes: ▪ The simplified procedure for the determination and publication of auction calendars; ▪ The clarification of rules on the distribution of auction volumes in case of multiple auction cancellations; ▪ The clarification of the notification procedure for the voluntary cancellation of allowances. With a view to further improve the efficient functioning of the European emissions market, Europex would like to suggest a number of additional changes to Regulation (EU) No 1031/2010 in the following areas (please see attached file for detailed feedback and suggested amendments): 1) Auction calendar (Arts. 8, 11, 13, 32) 2) Lot sizes (Art. 6) 3) Auction accessibility (Arts. 18-20) 4) Transaction reporting (Art. 36) 5) Structure and level of fees (Art. 51)
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Meeting with Miguel Arias Cañete (Commissioner) and BUSINESSEUROPE and

18 Feb 2016 · Market design