REMIT Exposure Reporting under REMIT 2

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New reporting obligation for market participants with significant electricity or gas positions

The new REMIT Implementing Regulation introduces Exposure Reporting as an additional reporting obligation for certain market participants active in EU wholesale energy markets.

Exposure Reporting is intended to provide ACER with an overview of market participants’ future positions resulting from wholesale energy products. It applies to positions in electricity and natural gas, assessed separately.

According to Article 6 of Commission Implementing Regulation (EU) 2026/256, market participants must report positions resulting from trading wholesale energy products, as well as forecasted volumes of electricity or natural gas production and consumption where required.

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What is REMIT Exposure Reporting?

REMIT Exposure Reporting means the reporting of aggregated future positions resulting from wholesale energy products.

Unlike transaction reporting, Exposure Reporting does not focus on each individual transaction. Instead, market participants above the relevant threshold must report their positions aggregated by month for the required future reporting horizon.

In practice, Exposure Reporting covers positions resulting from wholesale energy products with:

• physical delivery; or
• cash settlement.

This may include, for example, forwards, futures, options and other relevant wholesale energy products.

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Who is subject to Exposure Reporting?

Exposure Reporting applies to market participants whose positions reach or exceed the relevant threshold.

The threshold is:

600 GWh per year

This threshold is assessed separately for:

• electricity; and
• natural gas.

This means that a market participant may be above the threshold for electricity but below the threshold for natural gas, or vice versa.

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Important: How netting applies to the threshold assessment

According to ACER’s current draft Guidance on reporting exposure under REMIT, purchase (+) and sale (−) positions are first aggregated and netted for the relevant commodity, delivery country and delivery month.

The absolute value of the resulting monthly net position is then used for the annual threshold assessment. The absolute monthly values are summed and compared with the 600 GWh per year threshold, separately for electricity and natural gas.

This means that purchase and sale positions may offset each other within the relevant monthly aggregation. However, positive and negative net positions from different months or delivery countries must not be offset against each other when calculating the annual threshold.

Example

For October, the calculation is 30 GWh − 25 GWh = +5 GWh. The value used for the threshold assessment is therefore |+5| = 5 GWh.

For the three months shown above, the contribution to the annual threshold is 5 + 10 + 3 = 18 GWh. The December net short position of −3 GWh is not offset against the positive net positions of October and November because the absolute value of each monthly net position is used.

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What period must be reported?

Positions must be reported aggregated by month for each of the 18 months following the last day of the reference period.

This means that the market participant calculates its open positions on the last day of the reference period and reports the monthly aggregated positions for the next 18 months.

ACER has clarified that the first reporting is expected by 31 October 2027, covering monthly positions from October 2027 to March 2029.

Example

If the reference period ends on 30 September 2027, the market participant calculates its positions as of that date and reports its monthly positions for:

• October 2027
• November 2027
• December 2027
• …
• March 2029

Any later changes to positions are reflected in the next reporting cycle.

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Reporting frequency

Exposure Reporting is expected to be submitted on a quarterly basis.

The first reporting is expected by:

31 October 2027

Afterwards, market participants above the threshold are expected to report their positions quarterly.

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Day-ahead and intraday spot market data

Day-ahead and intraday spot market data should generally not be included for the purpose of Exposure Reporting.

Exposure Reporting is forward-looking and focuses on future positions. ACER indicates that day-ahead and intraday spot market data should not be considered for Exposure Reporting, while forwards, futures and option contracts should be included where relevant.

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Forecasted generation and consumption

Article 6 also refers to information about forecasted volumes of electricity or natural gas production and consumption.

However, ACER indicates that such forecasted generation and consumption data will be requested upon ACER’s request. Market participants should therefore distinguish between:

• regular reporting of positions, where the threshold is met; and
• forecasted production or consumption data, which may be required upon request by ACER.

Further technical guidance and reporting formats are expected from ACER.

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Battery storage and Exposure Reporting

Battery storage should generally be treated as part of electricity exposure reporting.

Where battery-related contracts qualify as wholesale energy products, the resulting positions should be included in the market participant’s electricity exposure calculation.

This may include, for example:

• electricity forwards linked to battery charging or discharging;
• futures or options relating to electricity;
• physical or cash-settled electricity positions connected with the battery’s market activity.

If the market participant reaches or exceeds the 600 GWh per year threshold for electricity, the relevant battery-related electricity positions must be included in Exposure Reporting.

Battery storage should not be treated as a separate exposure category. It is normally included under electricity.

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Practical summary

REMIT Exposure Reporting is a new reporting obligation for market participants with significant electricity or natural gas positions.

The key points are:

• Exposure Reporting applies to aggregated future positions.
• Electricity and natural gas are assessed separately.
• The relevant threshold is 600 GWh per year.
• Purchase (+) and sale (−) positions are netted within the relevant monthly aggregation.
• The absolute value of each monthly net position is used, and the absolute monthly values are summed for the annual threshold assessment.
• Positions are reported monthly for the following 18 months.
• The first reporting is expected by 31 October 2027.
• Day-ahead and intraday spot data should generally not be included.
• Forecasted production and consumption data may be required upon ACER’s request.
• Battery storage positions are generally treated as electricity positions where the related contracts qualify as wholesale energy products.