Last Update
14. May 2026
REMIT in Switzerland / REMIT 2 / BATE
Common questions on identifying and publishing inside information under REMIT.
Information
- REMIT 2 and its related reporting and registration requirements also apply to market participants with their registered office/place of domicile in Switzerland.
- Based on Art. 26abis of the Electricity Supply Ordinance (ESO), the same information on wholesale electricity trading that must be reported under ACER REMIT must also be sent to ElCom at the same time and in the same format. ElCom evaluates this data and contacts the market participants concerned if irregularities are identified.
- ElCom Links:
What is BATE?
- BATE – Swiss Federal Act on the Supervision and Transparency of Wholesale Energy Markets (Bundesgesetz über die Aufsicht und Transparenz in den Energiegrosshandelsmärkten)
Overview:
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- BATE is the Swiss counterpart to the EU REMIT regulation (Regulation (EU) No 1227/2011) and is often referred to as Swiss REMIT. It establishes a legal framework for supervision and transparency in the Swiss wholesale electricity and gas markets. Its objectives are to ensure fair competition, prevent insider trading and market manipulation, and strengthen trust in the integrity of the markets. BATE applies to all market participants active in Swiss wholesale energy products, including non-Swiss entities involved in Swiss trading.
- The following electricity and gas contracts are included, provided they are relevant to the market (See BATE Article 3(b)):
- Supply
- Distribution
- Transmission
- Storage
- Derivatives
Key Provisions:
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- Registration and Reporting
- Registration with the Swiss Federal Electricity Commission (ElCom) is required before engaging in transactions or placing trade orders.
- Participants must report wholesale energy transactions, trade orders, and fundamental data about their facilities to ElCom.
- Insider Information
- Insider information that could significantly impact energy prices must be published via approved platforms.
- Publication may be delayed under certain conditions, but the delay must be reported to ElCom.
- Market Manipulation & Abuse
- Insider trading and market manipulation are prohibited, with enforcement including fines, temporary market bans, and criminal penalties for serious violations.
- Inside Information Platforms
- Platforms must be registered and approved by ElCom.
- Market participants using these platforms must ensure that the information is secure, accurate, and efficiently published.
- Penalties for Non-compliance
- Severe violations can result in financial penalties of up to 15% of the previous year’s turnover.
- ElCom has the authority to impose sanctions and take corrective measures to restore market integrity.
- International Cooperation
- BATE defines rules for cooperation with foreign regulators, sharing of information, and maintaining market integrity across borders.
- Swiss participants also subject to EU REMIT must provide the same information to ElCom in the same format and at the same time.
- Registration and Reporting
Implementation:
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- The law was adopted by the Swiss Parliament on March 21, 2025.
- Following the referendum period ending on July 10, 2025, BATE is expected to enter into force in 2026, including transitional periods and implementing provisions to be defined by the Federal Council.
- BATE closely aligns with EU REMIT requirements but includes specific adaptations for the Swiss market to ensure transparency and fair competition in the wholesale energy markets.
Key Milestones for BATE Implementation
- March 21, 2025: The Federal Act on the Supervision and Transparency of Wholesale Energy Markets (BATE) was adopted by the Swiss Parliament.
- July 10, 2025: The deadline for the referendum period expired with no referendum launched, meaning the law stands confirmed.
- 2026 (expected): BATE is anticipated to enter into force during 2026, triggering the reporting and transparency obligations for market participants.
🕒 Implementation Notes
- Although the law itself has been adopted and the referendum period finished in mid‑2025, the exact effective date will be set later, typically when the implementing ordinance is finalized.
- The Swiss Federal Council launched a consultation on the implementing ordinance (VATE) from January 28 to May 5, 2026. This ordinance will define practical details such as reporting formats, deadlines, registration procedures, etc.
- Once the ordinance is finalized and published, the specific compliance deadlines and transitional periods for market participants will become clear.
📌 Practical Implications
- Market participants should prepare for 2026 compliance, including registration with ElCom, reporting processes, and publication of insider information, in line with Swiss BATE requirements.
- Further detailed deadlines (e.g., for phased implementation of reporting, gradual enforcement, or data format requirements) will be set once the implementing ordinance is formally issued.
How can a market participant submit REMIT reports and insider information in Switzerland?
- Market participants must submit their REMIT reports (transactions and fundamental data) as well as insider information (market-relevant confidential information) through approved platforms.
- To ensure correct, secure, and legally compliant reporting, participants should use a provider that offers both a REMIT reporting platform and an Inside Information Platform (IIP).
- Webware Internet Solutions GmbH provides both platforms, which have been officially approved and licensed by the Swiss Federal Electricity Commission (ElCom):
- REMIT Reporting Platform for submitting transactions and fundamental data: remitcloud.de
- Inside Information Platform (IIP): inside-information.de