15.09.2025 – Key changes from the draft of the new REMIT 2 Implementing Regulation

New Reporting Obligations

  • Exposure Reporting (Art. 6)
    • Quarterly reporting of:
      • Trading positions in electricity & gas
      • Forecasted generation
      • Forecasted sales to end customers
    • Reporting horizon: 24 months into the future.
    • Threshold: market participants with < 600 GWh/year (separately for electricity and gas) are exempt.
    • Start: Q1 2027 (first reports due by end of April 2027).
  • Hydrogen Reporting
    • From 1 July 2028 annual reporting of supply, transport and storage transactions.
    • Simplified datasets (few fields).
    • Exemptions: small producers (≤ 50 MW), local networks, end consumers < 600 GWh/year.
  • Balancing Transactions
    • New mandatory requirement, to be reported monthly and in aggregated form.
    • Reason: more complete market monitoring.
  • Gas Storage
    • Introduction of “periodic reporting” for contracts ≥ 12 months (monthly reporting).
  • Electricity storage
    • To be treated as electricity supply, no separate category.

    Deadlines and Reporting Intervals

    • OTC Contracts
      • Deadline shortened from 1 month → 10 working days after contract conclusion.
    • Trades on OMPs
      • Deadline extended from D+1 → D+2 (relief due to higher liquidity & IT workload).
    • LNG Data
      • Must be reported “as close as possible to real time”.

    Simplifications & Relief

    • New category “periodic reporting” → less frequent reporting (e.g. gas storage, hydrogen, balancing).
    • Ad hoc reporting expanded
      • Upstream pipelines, gas storage <12 months, redispatching contracts, voice-broker orders.
    • Large consumer contracts (≥ 600 GWh):
      • OTC reporting moved from continuous → semi-annual.

    New Data Fields / Clarifications

    • LNG-specific fields (e.g. vessel, terminal, price formulas).
    • Algorithm ID for algo-trading.
    • Identification for Direct Electronic Access (DEA).
    • Additional fields for PPAs (e.g. asset type, contract mechanism).
    • New Table 5 for trade-matching systems (SIDC etc.).

    Inside Information & Reporting Channels

    • Inside information only via IIPs (Inside Information Platforms).
    • Transaction, exposure and fundamental data exclusively via RRMs.
    • ACER may in future request original contracts (not only reported data).

    Fundamental Data Reporting

    • TSOs must additionally report imbalance settlement data monthly.
    • LNG system operators: reporting now aggregated (due to virtual tank systems), no longer obliged to report planned/unplanned outages (already covered via inside information).

    Legal Clarifications

    • Definitions updated (e.g. “Organised Marketplace” removed, as already regulated in REMIT 2024).
    • Responsibilities along the reporting chain clarified (Participant → OMP → RRM/IIP → ACER).

    Key Dates & Transitional Periods

    • 12-month transitional period: old Annex & Art. 3 from 1348/2014 apply in parallel after entry into force.
    • Staggered deadlines (Art. 17):
      • 6 months after entry into force: Exposure Reporting (Art. 6).
      • 12 months after entry into force: LNG data (Art. 7(2)), OTC reporting (10 working days).
      • 12 months after entry into force: Continuous Reporting (Art. 3), Large consumer OTC (Art. 4(2)).
      • 18 months after entry into force: Balancing, Gas storage, Redispatching, Trade-matching systems (Art. 4(3)–(7), Art. 9, Art. 11(4)).
      • 1 July 2028: Hydrogen Reporting (Art. 4(8)).
    • 1 November 2030: ACER review → assessment whether hydrogen reporting rules need to be adapted.

     

    ACER-REMIT-2 Implementierungs-Regulation Timeline

     

    Further information: Wholesale energy markets – data reporting rules (revision)