Practical guidance on REMIT reporting for LNG market participants — covering data collection via the TERMINAL platform, fundamental & transaction data rules, EU delivery scope, and ship unavailability disclosure.
LNG market participants must submit data to ACER via the TERMINAL platform as part of REMIT obligations. ACER publishes a daily LNG price assessment and benchmark based on reported data, ensuring market transparency.
Under REMIT II, reporting requirements are being strengthened. Market participants are expected to submit certain LNG transaction data on the same day (by 18:00 CET), with future integration into Registered Reporting Mechanisms (RRMs).
Latest updates (2026) align LNG reporting with REMIT II and updated ACER guidance (version 3.1).
Market participants or LNG System Operators (LSOs) must report data for each LNG facility in accordance with REMIT.
Data of unloading and reloading
Volumes unloaded or reloaded pre ship
The name of the terminal customer
Name & size of the ship using the facility
The LNG Participant Activity report contains details of all of the movement of LNG into and out of the facility by a market participant within a gas day. Deadline: dates of unloading/reloading and volumes per ship must be reported to the Agency no later than the working day following unloading or reloading.
Market participant
Name of the terminal customer (if different from the market participant)
To be provided in advance of the month to which it relates. The planned usage report provides a monthly forecast of expected usage of the facility for the month ahead.
26 Mar 2026 — Data reporting procedures
(See questions 3.2.5, 3.2.7, 3.2.8)
The reporting of contracts for the supply of liquefied natural gas (LNG) should not be different from any other contract for the supply of natural gas.
The EIC W code of the LNG terminal is used as the reporting of the delivery point. Most contracts for the delivery of LNG at EU LNG terminals are non-standard contracts.
There are two cases for reporting LNG contracts:
If the contract does not have a defined quantity or price, you must send two messages:
See FAQ on transaction reporting — Questions 3.1.2, 3.1.21, 3.1.22, 3.1.24, 3.1.49.
If the non-standard contract has a defined (fixed) price and quantity, it should be reported with Table 1 for Non-Standard BILCONTRACT contracts with outright price and volume (as per normal pipeline gas supply contracts with outright price and volume).
Deadline: the contract should be reported within 1 month from when price and volume are known.
See FAQ on transaction reporting — Question 3.1.22, Scenario 6.
Any change between the contractual volume and the final delivery volume should be reported as a lifecycle event with Action type “M” (Modify). Deadline: within 1 month from when price and volume are changed.
The key element of the geographical scope is that the delivery point of the electricity or natural gas must be in the EU.
Conversely, contracts for the supply of electricity or natural gas produced/generated outside the EU but delivered within EU borders are within the scope of REMIT.
Example — OLT offshore terminal of Toscana (Italy)
Bilateral OTC contract for the delivery of LNG at the OLT offshore LNG terminal of Toscana. The product is delivered in the EU — the LNG is delivered in EU territorial waters (Italian, an EU Member State). Whether delivery occurs at an offshore or onshore facility is not relevant to its qualification as ‘delivery in the EU’.
As far as LNG supply contracts are concerned, the Agency considers any delivery or offloading of LNG in any LNG facility (including the flanges connecting the LNG vessel to the LNG terminal) as ‘delivery in the EU’ — provided the delivery of the product takes place in the EU.
Source: ACER Guidance on REMIT Application, 6th Edition, p. 20.
| Scenario | Reportable? | Notes |
|---|---|---|
| EIC W — LNG terminal delivery point | Yes | Used for LNG terminals as delivery points. |
| Delivery at LNG terminal in EU | Yes | Always reportable under REMIT. |
| Contract outside EU (no EU delivery) | No | Not reportable unless LNG is delivered into the EU. |
| Transportation contract (no balancing zones) | No | Not reportable if it does not involve balancing zones. |
| Virtual gas storage | No* | Not reportable unless ownership transfer of gas occurs. |
| Delegation to RRM | Yes | Reporting can be delegated to RRMs or system operators. |
* Virtual gas storage is generally not reportable, but becomes reportable if the arrangement involves an actual transfer of ownership of the gas between parties.
The concept of ‘transportation of electricity or natural gas’ in the EU shall be interpreted by NRAs as including at least one bidding zone/delivery point located inside the EU:
All transportation of electricity or natural gas (including LNG) between bidding zones or specific delivery points that are (totally or partially) geographically located in the EU territory.
All transportation of electricity or natural gas (including LNG) from a bidding zone or point geographically outside the EU to a bidding zone or delivery point located (totally or partially) inside the EU.
Example — Transportation contract for delivery at the EU border
Situation: A market participant bought yearly firm transportation capacity of natural gas in order to import gas from Russia into the EU. The contract stipulates that the entry point is in a Russian location and the delivery point is at the border between Ukraine and Slovakia.
Assessment: This contract is a wholesale energy product pursuant to Article 2(4)(c) of REMIT, as it fulfils all relevant criteria: it relates to transportation in the EU — the delivery point of the natural gas to be transported is the border between Slovakia and Ukraine, which is partially located in the EU (Slovakia is an EU Member State, Ukraine is not).
Source: ACER Guidance on REMIT Application, 6th Edition, p. 21.
Reporting obligations apply to:
Market participants
Third parties acting on their behalf
Organised market places (OMPs)
Trade reporting systems
Trade repositories
Competent authorities
Acting on their own account and on their own behalf — pure principal transaction (i.e. on the decision of the firm).
Acting on their own account and on behalf of a client — i.e. on the order of another market participant.
Acting on the account and on behalf of a market participant — pure agency transaction.
Acting on a third entity’s account and on their own behalf.
Any restriction or unavailability of LNG vessels that may impact the market must be disclosed.
MoP, TRUM, schemas, and FAQs
26 Mar 2026 — Data reporting procedures
17 Dec 2024 — Transaction Reporting User Manual
Implementing Regulation (EU) 2026/256