ACER Update 2 November 2026

ACER publishes revised REMIT reporting guidance: what changes and when

TRUM v8.0, a new transaction reporting Guideline, exposure reporting and six new XML formats: what ACER published on 29 October 2026, the new reporting deadlines and the dates that apply to you

On 29 October 2026 ACER published the first set of its revised REMIT data reporting documents. The package is addressed to market participants, organised marketplaces (OMPs) and registered reporting mechanisms (RRMs). It follows the 2024 revision of REMIT by Regulation (EU) 2024/1106 and Commission Implementing Regulation (EU) 2026/256 of 30 January 2026.

ACER describes the change as three phases between October 2027 and July 2028. The Regulation itself names four application dates, and the earliest of them is 1 January 2027. Reporting parties who plan against the headline date alone will be working with a timetable that is two months out at the start and ten months out at the end.

What ACER has published

All documents are available on ACER's REMIT reporting guidance page, together with a changes catalogue and an implementation timeline.

Document	Status	What it covers	Applies from
Transaction Reporting User Manual (TRUM) v8.0	Updated	Technical field-level reporting instructions. Annex I, also dated 29 October 2026, covers lifecycle events in Table 1 and Table 2.	29 October 2027
Guideline on REMIT transaction reporting	New	Reporting obligations and definitions: the "what, who and when" of transaction reporting. Published with an annex on energy derivative reporting under REMIT and EMIR.	29 October 2027
Guidance on reporting exposure under REMIT	New	Threshold assessment, position calculation and quarterly exposure reports.	1 January 2027
Q&As on REMIT transaction reporting	Updated	Questions and answers that replace the former FAQs.	29 October 2027
Electronic formats (XML schemas)	New	Six formats, listed below.	29 October 2027

The six electronic formats are:

Standard contracts: electricity and natural gas (Table 1)
Standard contracts: LNG (Table 1)
Non-standard contracts (Table 2)
Electricity transportation contracts (Table 3)
Natural gas transportation contracts (Table 4)
Exposure reporting

What changes in transaction reporting

From 29 October 2027 the revised framework changes the deadlines and the classification rules that reporting parties apply every day. The main source is the Guideline on REMIT transaction reporting, in particular sections 2.1.5 and 2.1.6.1.

Topic	Until 29 October 2027 (TRUM v7.0)	From 29 October 2027
Standard contracts	No later than the following working day (T+1)	No later than two working days after the conclusion of the trade (T+2)
Non-standard contracts	Generally within one month	No later than 10 days after execution (T+10)
Bilateral contracts outside an OMP	A contract admitted to trading at an OMP could also qualify as a standard contract when traded outside the OMP	Classified as non-standard contracts. A contract admitted to trading at an OMP is one that is visible to the market, and a bilateral deal usually involves customisation.
Reporting table	Table 1 and Table 2 serve different reporting purposes	Non-standard contracts with a fixed price and quantity are still reported in Table 1; the table alone does not determine the deadline. Contracts with a defined but not fixed price, quantity or delivery profile go in Table 2, and each execution in Table 1 within 10 days.
Document structure	Policy principles and field-level instructions combined in the TRUM	The Guideline sets out the "what, who and when"; the TRUM focuses on technical instructions.
LNG and lifecycle events	LNG in Annex VIII, lifecycle events in Annex VII	LNG in Chapter 5 and Annex III, lifecycle events in Annex I (see the changes catalogue)

Note: The Guideline states the non-standard deadline as 10 days, not 10 working days. The Guideline is non-binding; submissions must follow the TRUM. This overview is not a field-by-field comparison of TRUM v7.0 and v8.0.

Application dates under the recast Regulation

The final article of Implementing Regulation (EU) 2026/256 sets out when each provision applies. The documents published on 29 October 2026 are the guidance that the Regulation required ACER to deliver by that date. ACER's implementation timeline gives the full schedule.

Application date	Provisions	ACER guidance due
1 January 2027	Article 6, exposure reporting	29 October 2026, delivered
29 October 2027	Article 3, Article 4(2), Article 7(2), Article 8(5), Article 10(6) and the Annex	29 October 2026, delivered
29 April 2028	Article 4(1), 4(3) to 4(7), Article 9, Article 11(4), Article 12(5), 12(9) and 13(2)	29 April 2027
1 July 2028	Article 4(8), hydrogen	29 October 2027

Until each date arrives, reporting continues under Regulation (EU) No 1227/2011 and Implementing Regulation (EU) No 1348/2014. The recital states the sequence plainly: exposure reporting first, then LNG market data, then the remaining obligations, among them imbalance settlement data, periodic transaction reporting, reporting by trade-matching systems and reporting by inside information platforms.

Note: The documents published now are not yet the applicable rulebook. TRUM version 7.0 and its annexes remain in force until 29 October 2027, and for LNG the Guidance on reporting LNG market data version 3.1 applies until the same date. The validity dates of each document are listed on ACER's guidance page.

Exposure reporting from 1 January 2027

Article 6 of Implementing Regulation (EU) 2026/256 introduces an obligation that has no equivalent in the current framework. Market participants report their positions, not their transactions. The details are set out in the Guidance on reporting exposure under REMIT.

Date	What happens
End of 2026	Cut-off for the first threshold assessment: positions at year-end 2026, including trades on 31 December, for delivery in 2027
From 1 January 2027	Market participants perform the threshold assessment
30 September 2027	Cut-off for the first report (reference quarter Q3 2027)
31 October 2027	First exposure report due, covering delivery from 1 October 2027 to 31 March 2029

Frequency. Once per quarter, due no later than the last day of the month following the end of the reference period. No backloading is required.
Content. Net positions in wholesale energy products with physical delivery or cash settlement within the 18 months following the last day of the reference period, irrespective of where and how the activity is conducted, including intragroup transactions.
Breakdown. Per commodity (electricity; natural gas including LNG), per delivery country, per delivery month and by contract type (forwards, futures, options), with intragroup and non-intragroup positions shown separately. Months without activity are reported as "NA", balanced positions as zero.
Excluded. Spot trades (day-ahead and intraday) and contracts with a delivery period of one week or less (Exposure Guidance, section 3.1).
On request. Forecast monthly production and consumption volumes per delivery point or zone.
Threshold. Positions are aggregated per commodity and delivery month, and the absolute monthly values are summed. This is not a simple sum of purchases and sales. Electricity and natural gas are compared separately against 600 GWh per year; at or above the threshold, the market participant reports for that commodity. The assessment is annual and is not repeated during the year (Exposure Guidance, section 2.2).
System operators. Transmission, distribution, storage and LNG system operators report only on ACER's request.
Submission. Exposure reports are submitted via a registered reporting mechanism chosen by the market participant, using the REMITExposure electronic format. One RRM should be used for all exposure reports in a given quarter (Exposure Guidance, sections 6.2 and 7).

Important: Three dates sit on one obligation. Article 6 applies from 1 January 2027, the threshold assessment uses positions at year-end 2026, and the first report is due on 31 October 2027. The data has to be capturable well before the filing date.

Periodic reporting for large consumption units

Article 4(2) of Implementing Regulation (EU) 2026/256 applies from 29 October 2027 and brings a population into scope that has not reported before.

Transactions relating to the supply or storage of electricity or the supply of natural gas to a single consumption unit with a technical capability to consume 600 GWh per year or more are reported every six months, no later than the last day of the first month of the following semester, unless the transaction was concluded on an organised marketplace. Where it was concluded on an organised marketplace it falls under Article 3 and the marketplace reports it.

ACER's implementation timeline gives the first deadline as 31 January 2028, covering 29 October 2027 to 31 December 2027, and marks executions reporting as required.

One sentence in the Regulation creates work outside the reporting system: the supplier shall obtain confirmation from its final customers about the technical capability of the consumption unit to consume 600 GWh per year or more. That is a contractual and commercial process, not a data mapping task, and it has to produce evidence that can be kept.

Note on the threshold: The figure of 600 GWh appears twice in the Regulation and measures different things. In Article 6(5) it is an exemption threshold for exposure reporting, assessed on positions, separately for electricity and gas. In Article 4(2) it is the technical consumption capability of a single consumption unit, and it triggers a supplier obligation.

Derivatives already reported under EMIR

The Guideline is published with an annex on the reporting of energy derivative transactions under REMIT and EMIR (Regulation (EU) No 648/2012). It addresses the exemption that avoids double reporting.

Where the details of a derivative contract have already been reported under Article 9 of EMIR, or under Article 26 of MiFIR, the obligation to report those details under REMIT is deemed fulfilled. ACER states that the exemption applies as soon as the details have been reported, regardless of which entity reported them. It extends to lifecycle events, including modifications, compressions, terminations and novations, where these have been reported under Article 9 of EMIR. ACER receives the information from trade repositories, approved reporting mechanisms, competent authorities under Article 26 of MiFIR, or ESMA.

The exemption has a boundary that is easy to miss. REMIT requires systematic reporting of the orders underlying a trade, and EMIR does not cover orders. The obligation to report orders therefore remains, and it is fulfilled by the organised marketplace where the trading occurs, on behalf of all market participants active on its platform. A marketplace may also submit the trade details under REMIT if it agrees to do so, but in that case the counterparties' obligations under EMIR remain.

Two further points from the annex:

A derivative that is not a financial instrument under Annex I Section C points (4) to (10) of MiFID II, but is a wholesale energy product under REMIT, is reported under REMIT. ACER gives two examples: a physically settled electricity forward traded on an organised trading facility, and a bilateral physical baseload or peak load swap.
The scope of the term intragroup transaction may differ between REMIT and EMIR. A transaction exempted from EMIR reporting as intragroup may still be reportable under REMIT, on ACER's reasoned request for bilateral non-standard transactions, or continuously by the marketplace if it was concluded there.

The annex currently covers reporting under Article 9 of EMIR only. ACER states that it intends to add material on Article 26 of MiFIR at a later stage.

Documents replacing the Manual of Procedures

The first set changes which documents reporting parties work from, and the changes do not all take effect on the same day. The mapping below follows ACER's changes catalogue.

Existing document	Replaced by	Published	Applies
Parts of TRUM v7.0 (chapter 3, Annex III, Annex IX), Q&As on REMIT, FAQs on transaction reporting	Guideline on REMIT transaction reporting	29 October 2026	29 October 2027
FAQs on REMIT transaction reporting v17.0	Q&As on REMIT transaction reporting, 18th edition	29 October 2026	29 October 2027
Manual of Procedures on REMIT data reporting	Annexes to the Guidance for inside information platforms and registered reporting mechanisms, and new electronic formats	27 November 2026	29 October 2027
Mapping between Implementing Regulation tables and electronic schemas	Annexes to the Guidance for IIPs and RRMs	27 November 2026	29 October 2027
ARIS data validation rules, both documents	Annex to the Guidance for IIPs and RRMs on validation rules, and an updated technical specification	27 November 2026	29 October 2027
Requirements for registered reporting mechanisms	Guidance for inside information platforms and registered reporting mechanisms	27 November 2026	29 October 2027
Annex II to the TRUM, XML trade examples	Updated Annex II	Q3 2027, to be confirmed	Q4 2027, to be confirmed

The Manual of Procedures is discontinued in two steps, on 29 October 2027 and on 29 April 2028, after which it ceases to exist. Phase 2 introduces two new manuals in its place: a Fundamental data reporting user manual and an Inside information data reporting user manual.

Note: The documents that define how a registered reporting mechanism and an inside information platform operate are not in the set published on 29 October. They arrive on 27 November 2026.

Delegated Regulation (EU) 2026/255 governs the authorisation and supervision of inside information platforms and registered reporting mechanisms. Its Articles 3 to 8 and 10 to 39, including both annexes, apply from 29 October 2027. Article 9 requires ACER, no later than 29 November 2026 and after consulting stakeholders, to provide guidance on eight items:

the technical process for the testing phase under Article 5(1)
the application process for platforms and mechanisms that are already registered, under Article 8(1)
the data validation principles and processes under Article 12(1) and (2), including technical specifications for the verification of data
the security measures under Article 13(1)(d)
the format of the report on unplanned downtime or disruption under Article 18(3)
the flagging process under Article 24(4), where applicable
the mechanisms to identify completeness, omissions and obvious errors, under Article 23(1) for platforms and Article 27(1) for mechanisms
the format of the annual report under Article 33(1)

The second item is the one to note. The Regulation provides for an application process for platforms and mechanisms that are already registered, which means existing registrations are not carried over automatically.

For inside information the timetable is already fixed: from 29 April 2028 disclosed inside information is reported to ACER by the inside information platform on behalf of market participants, continuously, within one working day of disclosure.

Checklist for reporting parties

Separate the four application dates in the plan. Exposure reporting from 1 January 2027, continuous reporting and large consumption units from 29 October 2027, the periodic and fundamental data provisions from 29 April 2028, hydrogen from 1 July 2028 (implementation timeline).
Prepare for the new deadlines. T+2 working days for standard contracts and 10 days for non-standard contracts from 29 October 2027 (Guideline, section 2.1.5).
Review how bilateral trades are classified. Contracts concluded bilaterally outside an OMP are generally non-standard, even if a similar contract is traded on an OMP.
Run the first exposure threshold assessment now. It is based on positions at year-end 2026, separately for electricity and natural gas (Exposure Guidance, section 2.2).
Decide where position data will come from. Exposure reporting needs forward positions for 18 months, by month, by country and by contract type, with intragroup positions identified. This is not an extract from transaction reporting.
Assess the 600 GWh thresholds separately. One is an exemption from exposure reporting, the other triggers a supplier obligation for large consumption units. Both need an annual assessment and a record of it.
Set up the customer confirmation process. Article 4(2) requires the supplier to obtain confirmation from final customers about the consumption capability of the unit.
Review the EMIR interface. Confirm which derivative transactions are covered by the exemption, and confirm that the order reporting that falls outside it is handled by the marketplace.
Plan the 27 November documents into the same project. The RRM and IIP rules, the validation rules and the related electronic formats arrive then, not now.

How we help

remitcloud connects market participants to ACER reporting through a single interface. Exposure reports are submitted through a registered reporting mechanism, and the revised framework adds data that does not originate in trade capture: forward positions for exposure reporting, confirmations from final customers for large consumption units, and the separation of what is covered by the EMIR exemption from what is not. We map these to the new electronic formats and to the application date that governs each of them, and we follow the guidance for registered reporting mechanisms and inside information platforms as ACER publishes it.

Note: The reporting obligation stays with the market participant. A registered reporting mechanism submits the data, and ACER's own guidance repeats that the participant remains responsible for the accuracy of what is reported.

Prepare for the revised REMIT reporting framework. Talk to us about the application dates that affect your reporting and the data you will need for each of them. Contact us

FAQ

When does the revised REMIT reporting framework start to apply?
In four steps. Exposure reporting under Article 6 applies from 1 January 2027. Continuous reporting and the periodic reporting for large consumption units apply from 29 October 2027. A further group of provisions, including trade-matching systems, fundamental data and inside information reporting, applies from 29 April 2028. Hydrogen reporting applies from 1 July 2028. See ACER's implementation timeline.

Do the documents published on 29 October 2026 apply now?
No. They are the guidance for the provisions that apply later. TRUM version 7.0 and its annexes remain in force until 29 October 2027, and for LNG market data the Guidance version 3.1 applies until the same date. The Guidance on reporting exposure under REMIT applies from 1 January 2027.

What are the new reporting deadlines for transactions?
From 29 October 2027, standard contracts are reported no later than two working days after the trade, and non-standard contracts no later than 10 days after execution (Guideline on REMIT transaction reporting, section 2.1.5).

Who has to submit the exposure report, and how?
Market participants whose positions are at or above 600 GWh per year, assessed separately for electricity and for natural gas, once per quarter. The first report is due on 31 October 2027 and is submitted via the participant's chosen RRM. Transmission, distribution, storage and LNG system operators report only on request (Exposure Guidance).

What has to be reported for large consumption units?
Transactions relating to the supply or storage of electricity or the supply of natural gas to a single consumption unit with a technical capability of 600 GWh per year or more, where the transaction was not concluded on an organised marketplace. Reporting is every six months, and ACER gives the first deadline as 31 January 2028. The supplier must obtain confirmation from its final customers about the consumption capability of the unit.

Does a derivative reported under EMIR have to be reported under REMIT as well?
No. Where the details have been reported under Article 9 of EMIR or Article 26 of MiFIR, the REMIT obligation for those details is deemed fulfilled, regardless of which entity reported them. The exemption does not cover orders. Order reporting remains under REMIT and is carried out by the organised marketplace (REMIT and EMIR annex).

Does an existing registered reporting mechanism have to apply again?
Delegated Regulation (EU) 2026/255 provides for an application process for inside information platforms and registered reporting mechanisms that are already registered, and requires ACER to publish guidance on that process by 29 November 2026. The authorisation and supervision provisions themselves apply from 29 October 2027.

What happens to the Manual of Procedures?
It is discontinued in two steps, on 29 October 2027 and on 29 April 2028. Its content moves to the Guidance for inside information platforms and registered reporting mechanisms, published on 27 November 2026, and to two new manuals introduced in phase 2 for fundamental data and for inside information.

Sources

Note: This summary has been compiled from the documents published by ACER on 29 October 2026 and the underlying EU regulations and reflects our understanding. It is provided for informational purposes only and is not legally binding. We do not take any legal responsibility for the accuracy or completeness of the information. For legal or regulatory matters, please refer to the official ACER documentation.