Key REMIT reporting concepts for the electricity market and electrical battery storage — covering transportation contracts, nominations, ENTSO‑E fundamental data, and battery storage transaction and inside information reporting with updated 2026 timelines.
This page explains the most important REMIT reporting concepts for the electricity market and electrical battery storage. It clarifies the differences between electricity transportation contracts, electricity nominations, and ENTSO-E fundamental data, and provides practical guidance on transaction reporting, fundamental data, and inside information for battery storage activities.
Aligned with: MoP v10 (26 Mar 2026), TRUM v7.0 (17 Dec 2024), and ACER's Open Letter of 09 Apr 2026 on Implementing Regulation (EU) 2026/256.
Canonical sources — linked once here to reduce link clutter throughout the page.
MoP, TRUM, schemas, and all official reporting guidance.
26 Mar 2026 — data reporting procedures and requirements.
17 Dec 2024 — Transaction Reporting User Manual.
Implications of Implementing Regulation (EU) 2026/256.
Storage deal → physical power right → electricity supply contract.
Electricity market transparency data.
These topics are related, but they represent different "data buckets" under REMIT and electricity market transparency.
Agreements that define the terms for using the transmission network (e.g., cross-zonal capacity rights). They describe how the network can be used and how capacity is allocated or transferred.
Operational schedules describing how much electricity is scheduled to flow over a given period. Reporting focuses on final nominations between bidding zones, identifying the market participant and scheduled quantity.
A broad set of electricity system transparency data covering capacity and use of facilities for production, consumption, and transmission — including planned and unplanned unavailability (NTC values, physical flows, outages, generation/load data).
Battery storage arrangements can function like electricity supply (when power is delivered/withdrawn under contractual rights) and can also create inside information obligations (e.g., outages or major capacity changes).
ACER FAQ Q3.1.20: If the holder of the contract is able to take physical power, the arrangement is treated as a contract for the supply of electricity and is reportable.
ACER's 09 Apr 2026 open letter clarifies that wholesale energy products relating to electricity storage should be treated like wholesale energy products relating to electricity supply.
REMIT does not introduce a "battery-specific minimum size" rule. However, ACER provides threshold guidance that materially affects reporting expectations:
| Topic | Practical interpretation for batteries |
|---|---|
| Final-customer carve-out (600 GWh/year) | Contracts to final customers below 600 GWh/year are not wholesale energy products. ACER indicates storage systems generally do not fall under "final consumers" because they are designed to transfer electricity back to the grid or a utility. |
| Small-unit logic (≤10 MW) | The ≤10 MW production-unit threshold (reportable only upon reasoned request by ACER and on an ad-hoc basis, unless concluded on OMPs) applies also to electricity storage systems due to their nature. |
| Delivery point | The storage unit itself is not a delivery point for transaction reporting. |
| Market venue & timelines | OMP-traded activity follows standard timeframes; OTC activity follows non-standard timeframes. |
Lifecycle events follow the same logic: T+2 for standard, T+10 for non-standard.
ACER interprets the recast definitions as a practical simplification for timeframes:
OMP vs OTC is the primary decision point for the deadline, even though Table 1 vs Table 2 is driven by contract structure and whether price/quantity are known.
OMP orders/trades and contracts/executions where price and quantity are specified (including BILCONTRACT and EXECUTION cases).
Non-standard framework contracts where price and/or quantity are not fully fixed at conclusion, with later execution reporting.
| Scenario | Deadline | Table | Notes |
|---|---|---|---|
| OMP order or trade (incl. storage products) | T+2 | Table 1 | Treat as "standard" (OMP). |
| OTC bilateral with fixed price & quantity | T+10 | Table 1 | Often as BILCONTRACT. |
| OTC framework (price/qty not fixed) | T+10 | Table 2 | Later executions in Table 1 linked to Table 2 ID. |
| Lifecycle event | T+2 (OMP) / T+10 (OTC) | Same table | Depends on original record venue. |
Battery storage can influence supply/demand balance, so unavailability and major operational constraints may constitute inside information depending on materiality.
ACER's MoP specifies three XML schemas for inside information web feeds. For electricity unavailability events:
Used when market participants publish urgent market messages (UMMs) reporting planned or unplanned electricity unavailability of any size likely to significantly affect wholesale energy prices.
MoP Annex VII also explains UMM thread ID and versioning, enabling transparent updates to an event via consecutively published UMMs.
TRUM defines Data Field (30) Transaction timestamp as the date and time of: the contract execution or order submission, or the modification, cancellation, or termination.
Lifecycle events keep previously reported records accurate over time.
Timing: Apply T+2 for lifecycle events relating to OMP (standard) and T+10 for OTC (non-standard).