REMIT Compliance
April 15, 2026
ACER Open Letter on the Implications of Regulation (EU) 2026/256 for Data Reporting (REMIT 2)
Key Changes in REMIT 2 Data Reporting – Deadlines, Formats, New Obligations
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- Objective of Regulation (EU) 2026/256: It concerns the implementation of Articles 7c(2), 8(1a), 8(2), and 8(6) of Regulation (EU) No 1227/2011, which governs the integrity and transparency of the wholesale energy market and replaces Regulation (EU) No 1348/2014.
REMIT 2: Key Dates
| Date | Meaning |
|---|---|
| 9 April 2026 | Publication of Implementing Regulation (EU) 2026/256 in the Official Journal of the EU. |
| 29 April 2026 | Entry into force of the recast REMIT IR. From this date, several new obligations already apply, in particular new reporting deadlines. |
| 29 October 2026 | ACER plans to publish guidance and electronic formats for several new reporting areas, including Exposure Reporting, continuous transaction reporting, final customer reporting ≥ 600 GWh/year and exogenous data for OMPs. |
| 1 January 2027 | Exposure Reporting becomes applicable. However, the first report is due later. |
| 29 April 2027 | ACER guidance/formats for several reporting areas of the second wave, e.g. capacity mechanisms, balancing, gas storage, trade-matching systems and Inside Information Reporting. |
| 29 October 2027 | First major reporting wave: new rules/formats for continuous transaction reporting, including electricity/gas supply, electricity storage, transportation capacity and certain final customer contracts. |
| 31 October 2027 | First report for Exposure Reporting. Thereafter, reporting is quarterly. |
| 29 April 2028 | Second reporting wave: including capacity mechanisms, balancing services, gas storage, imbalance settlement data and Inside Information Reporting under the new requirements. |
| 1 July 2028 | Hydrogen Reporting becomes applicable. |
| 31 January 2029 | First Hydrogen Reporting deadline, covering the period from 1 July 2028 to 31 December 2028. |
REMIT 2: Key Changes
1. New reporting deadlines from 29 April 2026
The most important short-term change concerns the reporting deadlines:
| Contract type | New deadline |
|---|---|
| Standard contracts | T+2, i.e. within 2 business days |
| Non-standard contracts | T+10, i.e. within 10 business days |
| Lifecycle events | Same deadline as the underlying contract: T+2 or T+10 |
Note:
ACER expects reporting parties to comply with the new reporting deadlines from 29 April 2026.
This means that, for transactions where the conclusion of the trade, the placing of the order, the end of the auction/gate closure, or a lifecycle event takes place before 29 April 2026, the old reporting deadlines continue to apply.
Example:
If a non-standard contract is concluded on 28 April 2026, i.e. one day before the entry into force of the new REMIT IR rules, the old one-month reporting deadline still applies, and the transaction must be reported by 28 May 2026 at the latest.
However, if the transaction takes place on 29 April 2026, it must be reported by 13 May 2026 at the latest.
The reporting deadline for LNG market data remains unchanged: LNG data must be reported as close to real time as technologically possible once a transaction has been finally agreed or bids or offers have been placed.
See Open Letter on the Implications of Regulation (EU) 2026/256 on Data Reporting, §8.
2. New definitions of “transaction” and “lifecycle event”
The regulation introduces new definitions:
Transaction now includes trades, orders, bilateral contracts, their execution and lifecycle events.
Lifecycle event includes, for example, amendment, cancellation, correction, early termination or execution of a trade, order or bilateral contract.
ACER considers these definitions largely to be a confirmation of existing reporting practice.
3. New distinction between standard and non-standard contracts
The definition is simplified:
| Category | Meaning |
|---|---|
| Standard contract | A contract traded on an Organised Marketplace |
| Non-standard contract | A contract outside an Organised Marketplace, i.e. OTC/bilateral |
Important: Even if a bilateral contract is based on a product that could be traded on an exchange, ACER generally considers it to be non-standard if it is concluded outside an OMP.
See Open Letter on the Implications of Regulation (EU) 2026/256 on Data Reporting, §7, page 7.
See Draft Version TRUM 8, §9, page 7.
4. Transition from old to new formats
The existing reporting formats under Implementing Regulation (EU) No 1348/2014 will partly continue to apply until the new rules actually become applicable.
Important points:
- Transactions that have already been reported do not have to be reported again in the new format.
- Lifecycle events after the transition date must be reported under the new rules.
- Transactions concluded before the transition date but reported only after that date must comply with the new requirements.
- Backloading obligations apply to certain new periodic reports.
5. New obligations for OMPs from 29 April 2026
Organised Marketplaces will have new or extended obligations:
- Reporting of certain secondary capacity allocations, even if they were concluded outside the OMP but registered on the OMP.
- Reporting of unsuccessful primary capacity allocations where bids were submitted but no allocation took place.
- Provision of reported data to market participants upon request.
- Retention of reported data for at least 5 years.
- If an OMP reports on behalf of a market participant, the market participant should not report the same data separately to ACER.
6. System-generated orders will come, but not immediately
System-generated orders generally fall within the definition of an order book. However, reporting will only start upon request by ACER. According to the Open Letter, ACER does not plan to require this reporting already from 29 April 2026.
7. New obligation to provide exogenous data to OMPs
From 29 October 2027, market participants must provide the OMP with information that is not already available to the OMP but is required for reporting.
Examples:
- Algorithm ID
- DEA client information
- Sub-clients
- Final beneficiary
- Transfer price or price in case of secondary allocation
This information must be made available to the OMP no later than the relevant reporting deadline.
8. Electricity Storage is treated like Electricity Supply
Contracts relating to electricity storage are generally to be treated like contracts for the supply of electricity.
According to ACER, Electricity Storage Systems, such as batteries, should be treated like consumption or production units insofar as they function as such. The related trading activity is therefore considered equivalent to trading in the supply of electricity.
ACER clarifies:
- Electricity storage systems are not considered delivery points.
- Depending on their function, electricity storage systems may be treated as production or consumption units.
- For Electricity Storage Systems with a capacity of more than 10 MW, a REMIT reporting obligation generally applies. This applies both to individual storage units exceeding 10 MW and to several storage units that together exceed 10 MW.
See §8.
9. New Exposure Reporting
Exposure Reporting will become a new reporting stream.
Important points:
- Applicable from 1 January 2027
- First report due by 31 October 2027
- Quarterly reporting thereafter
- Threshold: positions of 600 GWh or more per year
- Separate assessment for electricity and natural gas
- Assessment once per year at the end of the calendar year
- Market participants do not have to submit the calculation automatically, but must be able to demonstrate it upon request
10. LNG Reporting will be changed
LNG Market Data will initially continue to be reported via TERMINAL.
From 29 October 2027, LNG Market Data shall be reported via RRMs to ARIS. Reporting will then be based on a new electronic format, as the new Table 1 becomes applicable from that date.
See Open Letter on the Implications of Regulation (EU) 2026/256 on Data Reporting, §12.
11. New periodic reporting obligations from 2028
From 29 April 2028, several new periodic reporting obligations will apply, including:
- Capacity mechanisms
- Balancing services in the electricity market
- Gas storage contracts with a duration of 12 months or longer
- Derivatives relating to gas storage
- Imbalance settlement data in the electricity sector
- Reporting of Inside Information under the new requirements
12. Changes to Fundamental Data Electricity
For electricity fundamental data, the main new element is:
- TSOs must report imbalance settlement data.
- This should include, among other things, imbalances, final positions, allocated volumes and, where applicable, imbalance adjustments.
- Reporting is required monthly, no later than the last day of the third month following the month of the imbalance settlement.
Example:
Data for March must be reported by the end of June.
13. Changes to Fundamental Data Gas
Several changes apply to gas fundamental data:
- The reporting responsibility for LNG and storage data will in future lie solely with the LSO or SSO.
- Market participants should no longer report this information themselves from 29 April 2028.
- Planned and unplanned unavailability announcements will no longer have to be reported as Fundamental Data.
- However, publication as Inside Information remains relevant.
14. Inside Information Reporting will be expanded
REMIT II has added new Wholesale Energy Products to the scope of REMIT, namely Hydrogen and Electricity Storage. ACER clarifies that the obligation to publish Inside Information is also relevant for these new products.
The obligation to disclose Inside Information applies independently of whether the specific reporting obligation for these products has already started or will only start at a later date.
From 29 April 2028, Inside Information Reports must be reported according to the new requirements. Reporting shall be continuous, generally T+1 after publication or modification, in accordance with the Delegated Regulation on RRMs and IIPs.
15. Hydrogen Reporting will start from 2028
Hydrogen Reporting will start later:
- Applicable from 1 July 2028
- First report due by 31 January 2029
- Annual reporting thereafter
- Certain Hydrogen Supply, Storage and Transportation transactions are affected
- There are exemptions, e.g. for hydrogen production up to 50 MW or certain geographically confined hydrogen networks
Short Summary
The most important points are:
From 29 April 2026, new reporting deadlines apply: T+2 for Standard Contracts and T+10 for Non-Standard Contracts.
From 2027, new formats, Exposure Reporting and extended OMP obligations will be introduced.
From 2028, new periodic reports, new Inside Information Reporting requirements, changes to Fundamental Data and Hydrogen Reporting will follow.
Note:
- ACER expects reporting parties to comply with the new reporting timeframes starting from April 29, 2026. This means that for transactions where the trade conclusion, order placement, auction end (gate closure), or lifecycle event occurs before April 29, 2026, the old reporting timeframes still apply.
- For example, if a non-standard contract is concluded on April 28, 2026 (one day before the new REMIT IR comes into effect), the old one-month reporting timeframe still applies, and the transaction must be reported by May 28, 2026 at the latest.
However, if the transaction occurs on April 29, 2026, it must be reported by May 13, 2026 at the latest.
Impact on Hydrogen Reporting
Starting July 1, 2028, market participants active in the hydrogen market will be required to submit annual reports on their transactions. Further details will be published by the end of 2027.
ACER will continue to work with market participants and competent authorities to ensure a smooth transition to the new requirements and provide the necessary additional guidance.
Conclusion
The new rules under Regulation (EU) 2026/256 require a comprehensive adjustment of data reporting in the wholesale energy market. The most significant changes include the transition to new reporting formats and the introduction of additional reporting obligations for hydrogen and storage transactions. Market participants should prepare for the transitional periods and specific reporting requirements.