Switzerland will implement its own regulatory framework for energy market transparency and integrity starting in 2026, with the introduction of the new Federal Act on Supervision and Transparency in the Wholesale Energy Market – commonly referred to as Swiss REMIT. This law aligns closely with the EU’s REMIT Regulation but is tailored to the Swiss energy market.

Below is an overview of what changes are coming and how market participants – especially those based outside of Switzerland – should prepare.

What is Swiss REMIT?

Adopted in March 2025, Swiss REMIT establishes a legal framework for the monitoring of wholesale electricity and gas trading activities. The new law requires market participants to:

• Register with the Swiss regulator (ElCom)
• Report wholesale energy transactions and orders
• Publish inside information
• Comply with market abuse prohibitions (e.g. insider trading, market manipulation)

Official text:
Federal Act (Fedlex)  DE, FR, IT

When does it apply?

Swiss REMIT is expected to enter into force in 2026, with a transitional phase and specific compliance deadlines.

📑 What needs to be reported?

Market participants will be required to report the following data to ElCom:

This includes reporting on LNG terminals, storage capacities, and cross-border capacity bookings.

🌍 Foreign companies: Representation requirement

Non-Swiss market participants must appoint a local representative in Switzerland. This representative will act as the official contact for all regulatory communications with ElCom – similar to the new EU REMIT II requirement for non-EU entities.

⚖️ Penalties for non-compliance

Swiss REMIT introduces significant sanctions for violations, including:

• Fines of up to 15% of Swiss annual turnover
• Criminal penalties for market manipulation or deliberate insider trading
• Reputational damage and regulatory enforcement

✅ How remitcloud.de can help

At remitcloud.de, we offer complete Swiss REMIT compliance support:

• Automated reporting of transactions, fundamental data, and inside information to ElCom
• ACER-style IIP platform for public disclosure
• Swiss representative service for non-domestic market participants
• LNG, gas storage, electricity and cross-border capacity reporting
• Early compliance guidance & transition support

📣 Be proactive – prepare for 2026

Swiss REMIT introduces a new era of transparency and regulation in the Swiss energy market. Early preparation ensures seamless compliance, lower risk, and reduced operational burden.

📩 Get in touch with our team for a consultation or live demo:
✉️ info@remitcloud.de | 🌐 www.remitcloud.de

The 39th edition of ACER’s REMIT Quarterly, covering the fourth quarter of 2024, provides several key updates:

• Data Reporting Enhancements
  ACER has been refining data reporting processes in line with the revised REMIT framework. Notably, two joint roundtable meetings were held on 26 and 28 November 2024 with Registered Reporting Mechanisms (RRMs), Inside Information Platforms (IIPs), Associations of Energy Market Participants (AEMPs), and Organised Market Places (OMPs). These sessions focused on the upcoming revision of the REMIT Implementing Regulation and shared updates on data reporting guidance.
• Expert Group Meetings
  The 3rd and 4th meetings of the Expert Groups on Wholesale Energy Market Data Reporting and on Wholesale Energy Market Integrity and Transparency were convened. These groups play a pivotal role in advising ACER on REMIT-related matters, ensuring effective market surveillance and data reporting.
• Hydrogen Market Transparency
  Market participants in the hydrogen sector are reminded of their obligations to disclose inside information, promoting transparency and integrity as this market evolves.

ACER draws the attention of market participants to the obligation under Regulation (EU) 2017/1938 on measures to safeguard the security of gas supply, as revised by the Regulation (EU) 2024/1789, which will be applicable as of 5 February 2025. This said provision entails that hydrogen market participants are expected to start registering with their relevant NRAs as of this date, in order to fulfil their obligations in relation to the disclosure of inside information. Nonetheless, the Agency reminds that the reporting of hydrogen related wholesale energy products as per Article 8 of Regulation (EU) 1227/2011 on wholesale energy market integrity and transparency (REMIT), as revised by Regulation (EU) 2024/1106, is not expected to commence until the Commission Implementing Regulation (EU) 1348/2014 on data reporting is revised.

• Guidance Updates
  ACER has updated its guidance documents on REMIT transaction reporting, highlighting trends in data reporting and recognizing the top five reporting entities.
• REMIT Breach Cases
  By the end of Q4 2024, ACER had 390 REMIT breach cases under review, reflecting ongoing efforts to monitor and enforce compliance in wholesale energy markets.
• Trading Activities Summary
  The report provides a summary of 2024 trading activities on Organised Market Places, offering insights into market dynamics over the year.

These developments underscore ACER’s commitment to enhancing transparency, integrity, and oversight in Europe’s wholesale energy markets.

Link: acer.europa.eu

The document “Evaluation of Responses to the Public Consultation of ACER on the Revision of the Annex of the REMIT Implementing Regulation” provides a comprehensive review of feedback from stakeholders regarding proposed changes to the REMIT Implementing Regulation Annex.

Below is a concise summary:

Purpose of the Document

The report evaluates input from a public consultation process aimed at revising the Annex of the REMIT Implementing Regulation (IR). This process ensures the data reporting framework aligns with market evolution and regulatory needs while considering feedback from stakeholders like market participants, regulatory bodies, and organized marketplaces.

Key Highlights

1. Consultation Background:
   • Regulation (EU) 2024/1106 introduced amendments to REMIT in May 2024, necessitating updates to the Implementing Regulation by May 2025.
   • ACER conducted a consultation from June to September 2024 to gather stakeholder input.
2. Stakeholder Participation:
   • A total of 92 stakeholders, including market participants, organized marketplaces, and national regulators, contributed feedback.
   • Responses highlighted a general preference for maintaining simplicity and minimizing administrative burdens.
3. Key Feedback Themes:
   • Alignment with Market Evolution: Stakeholders recommended flexibility in reporting requirements, avoiding unnecessary additions to data fields unless clearly justified.
   • Data Reporting Formats: Strong opposition was voiced against transitioning from XML to alternative formats like JSON due to potential costs and system disruptions.
   • Algorithmic Trading and System-Generated Orders: Concerns were raised about the feasibility and clarity of proposals to flag algorithmic trading or differentiate system-generated orders.
   • Delivery Profiles: Suggestions were made to refine the reporting of delivery intervals without excessive restructuring of existing tables.
4. Recommendations and Challenges:
   • Simplification: Stakeholders emphasized maintaining a lean data structure while ensuring data quality.
   • Consistency: Calls were made for a unified approach to naming conventions and data fields across markets and trading platforms.
   • Implementation Timelines: Adequate lead time (e.g., 12 months) was requested for implementing any changes to allow stakeholders to adapt systems.
5. Next Steps:
   • ACER plans to use the consultation feedback in discussions with the European Commission.
   • Further stakeholder engagement is expected, including roundtable meetings to finalize proposed changes.

Notable Insights from Responses

• Stakeholders were divided on adding new data fields, with many arguing that existing fields could be optimized to avoid complexity.
• There was broad support for optimizing the use of ACER codes for entity identification while reducing redundant fields.
• Algorithmic trading and direct electronic access (DEA) reporting were identified as areas requiring clearer definitions and limited additional reporting obligations.

Evaluation of responses to the public consultation of ACER on the revision of the Annex of the REMIT Implementing Regulation

The two versions of Annex VIII of the “Transaction Reporting User Manual” (TRUM) by the Agency for the Cooperation of Energy Regulators (ACER) provide guidelines for reporting liquefied natural gas (LNG) supply contracts under the REMIT regulation. Below are the main differences between Version 1.0 (March 13, 2024) and Version 1.1 (September 30, 2024):

Key Differences

1. Clarifications and Refinements:
   • Version 1.1 includes additional clarifications regarding reporting requirements for LNG supply contracts, especially for spot and portfolio contracts and associated transactions.
   • New examples and scenarios have been added to help market participants better understand the requirements.
2. Adaptations to Regulatory Changes:
   • The updates reflect amendments in the REMIT regulation to ensure that the guidelines align with the latest regulatory requirements.
   • References to updated documents and supplementary guidance were incorporated to maintain consistency with other ACER publications.
3. Structural and Formatting Improvements:
   • The structure of the document has been revised to enhance readability and usability.
   • Sections have been reorganized, with headings and subsections adjusted for easier navigation.

Summary

Version 1.1 of Annex VIII of the TRUM offers expanded and refined guidance on reporting LNG supply contracts under REMIT. These updates aim to provide market participants with clearer instructions and ensure that the guidelines remain compliant with current regulatory standards.

For more detailed insights, consulting the specific sections of each version is recommended. Let me know if you’d like further assistance!

Version 1.1

Version 1.0

Version 1.1 vs. Version 1.0