Exposure Reporting in REMIT 2
Exposure Reporting is a new, regular mandatory report on positions, generation and consumption forecasts, intended to give ACER a better overview of market risks.
📌 Definition
Market participants must report quarterly to ACER:
- their trading positions (open positions in power and gas),
- their forecasted generation (power plants, RES facilities, etc.),
- their forecasted consumption / sales to end customers.
The report must cover 24 months ahead (rolling forecast).
🎯 Purpose
- ACER wants to better understand how exposed market participants are to price fluctuations.
- This enables earlier detection of market risks, bottlenecks and potential market manipulation.
- It is therefore not about single transactions but about the overall picture (exposure).
📊 Scope & Exemptions
- Obligation applies only to market participants with annual volume of ≥ 600 GWh (separately for power and gas).
- Smaller actors are exempted in order to reduce administrative burden.
- Reports are provided in aggregated form (no single transactions).
📅 Start date
6 months after entry into force of the new REMIT IR.
First reporting: Q1 2027 (due end of April 2027).
A concrete example for a power trader “Alpha Energy” with annual consumption of 800 GWh.
Power trader
- Annual consumption: 800 GWh (⇒ above 600 GWh → exposure reporting obligation).
- Business model: buys power on exchanges (EEX), via OTC and supplies to end customers.
- Must report quarterly to ACER.
Trading positions (position data)
Presentation of open positions in power contracts (e.g. futures, forwards, OTC):
| Market segment | Long (bought) | Short (sold) | Net position | Period |
|---|---|---|---|---|
| EEX Futures Q2 2027 | 300 GWh | 50 GWh | +250 GWh | Apr–Jun 2027 |
| OTC Forward 2027 | 400 GWh | 500 GWh | –100 GWh | Calendar year 2027 |
| Spot Market March 2027 | 50 GWh | 80 GWh | –30 GWh | March 2027 |
ACER sees: trader is in the next quarter net long, in 2027 slightly short.
Forecasted generation
If “Alpha Energy” operates its own plants (e.g. wind, solar, gas CHP), it must report the expected production:
| Plant | Expected generation Q2 2027 | Expected generation 2028 |
|---|---|---|
| Wind farm North | 120 GWh | 480 GWh |
| Solar park South | 30 GWh | 100 GWh |
| Gas power plant | 60 GWh | 200 GWh |
| Total | 210 GWh | 780 GWh |
Forecasted consumption / sales
If “Alpha Energy” operates its own plants (e.g. wind, solar, gas CHP), it must report the expected production:
| Customer / segment | Forecast 2027 | Forecast 2028 |
|---|---|---|
| Industrial customers (5 contracts) | 400 GWh | 410 GWh |
| Municipal utilities / resellers | 250 GWh | 260 GWh |
| Household customers (portfolio) | 150 GWh | 155 GWh |
| Total | 800 GWh | 825 GWh |
Reporting obligations
-
Report quarterly to ACER via a RRM (Registered Reporting Mechanism).
-
First reporting for Q1 2027 → submission end of April 2027.
Thus ACER sees:
-
“Alpha Energy” is in 2027 slightly under-supplied (short), meaning it still needs to purchase power on the market.
-
From 2028 onward, its own generation already covers ~95% of sales.
-
Risk: dependency on gas and the spot market.