New REMIT Fees (from 2025)

On 8 September 2025, the European Commission adopted Decision (EU) 2025/1771, which introduces a new fee framework for ACER’s REMIT-related tasks.

1. Structure

RRMs (Registered Reporting Mechanisms) pay annually:

• Flat registration fee: EUR 15,000

• Transaction records fee component: based on data volumes and clusters (see below)

• Risk position reporting fee: EUR 250 per report

• IIPs (Inside Information Platforms): fixed annual fee of EUR 15,000

2. Fees for transaction records (per data cluster)

a) Market participants on organised markets:

• 1–100 records → EUR 250

• 101–1,000 → EUR 500

• 1,001–10,000 → EUR 1,000

• 10,001–100,000 → EUR 2,000

• 100,001–1m → EUR 4,000

• 1m–10m → EUR 8,000

• 10m–100m → EUR 16,000

• 100m–1bn → EUR 32,000

• 1–2bn → EUR 64,000

• 2bn → EUR 96,000

b) Market participants outside organised markets:

• 1–10 records → EUR 250

• 11–100 → EUR 500

• 101–1,000 → EUR 1,000

• 1,001–10,000 → EUR 2,000

• 10,001–100,000 → EUR 4,000

• 100,001–1m → EUR 8,000

• 1m–10m → EUR 16,000

• 10m → EUR 32,000

3. Transitional provisions

• 2025: one-off surcharge of EUR 7.6 million, allocated to RRMs according to the number of market participants (EUR 467.17 per MP).

• 2026: additional possible surcharge up to EUR 23.5 million, allocated according to data clusters.

Links:
Decision – EU – 2025/1771 – EN – EUR-Lex

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.

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  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”.

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  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.

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  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.).

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  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).

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  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).

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  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).

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  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.

   

  

   

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

REMIT 2 Draft – Key Deadlines

The EU’s revised REMIT Regulation (EU No. 1227/2011) — commonly referred to as REMIT II — was adopted in early 2024 and introduces significant changes to strengthen transparency, market integrity, and enforcement in Europe’s wholesale energy markets.

Here’s what’s coming and how remitcloud.de helps ensure compliance.

🔍 Key Changes at a Glance

1. EU Representative Requirement for Third-Country Market Participants

Companies based outside the EU will be required to appoint an official EU representative. This representative must be registered with ACER and the competent national regulatory authority (e.g. Bundesnetzagentur in Germany) and serve as the formal point of contact for compliance and enforcement matters.

➡ Our solution: remitcloud.de offers a full EU representative service, including mandate setup, registration, address provision, and regulatory communication.

2. Expanded Reporting Obligations

REMIT II adds new categories of reportable data and strengthens existing ones, particularly regarding:

• Fundamental data (e.g. electricity, storage, LNG terminals, capacity constraints)
• Order and transaction reporting in greater detail and frequency
• Standardized formats, validation rules, and deadlines

➡ Our solution: As a certified RRM, we support the complete ACER reporting scope – TRUM, UMM, fundamental data, and more – including automated validation and integration.

3. Stronger Regulatory Powers

ACER and national regulators will be granted broader powers to investigate and enforce compliance across borders, with streamlined cooperation mechanisms.

➡ Our solution: We provide proactive alerts, audit-proof data logs, and support throughout inspections or regulatory requests.

💡 What It Means for You

Whether you’re already reporting under REMIT or preparing to enter the EU market, REMIT II brings new legal, technical, and procedural requirements. Non-compliance may result in enforcement actions, delays, or market access issues.

✅ Why Remitcloud.de?

We provide an integrated, cost-efficient REMIT compliance platform:

• ✅ Full support for ACER and ElCom reporting
• ✅ Publication of inside information via certified IIP
• ✅ EU representative service for third-country entities
• ✅ LNG and storage reporting included
• ✅ Custom integrations & flexible automation
• ✅ Significantly more affordable than many competitors

📩 Stay Ahead of REMIT II

The new regulation will impact all market participants in the EU and beyond. Now is the time to assess your readiness and secure a partner with the tools and expertise to guide you.

📧 Reach out to us for a consultation or live demo:
info@remitcloud.de | www.remitcloud.de