REMIT Exposure Reporting under REMIT 2
New reporting obligation for market participants with significant electricity or gas positions
The new REMIT Implementing Regulation introduces Exposure Reporting as an additional reporting obligation for certain market participants active in EU wholesale energy markets.
Exposure Reporting is intended to provide ACER with an overview of market participants’ future positions resulting from wholesale energy products. It applies to positions in electricity and natural gas, assessed separately.
According to Article 6 of Commission Implementing Regulation (EU) 2026/256, market participants must report positions resulting from trading wholesale energy products, as well as forecasted volumes of electricity or natural gas production and consumption where required.
What is REMIT Exposure Reporting?
REMIT Exposure Reporting means the reporting of aggregated future positions resulting from wholesale energy products.
Unlike transaction reporting, Exposure Reporting does not focus on each individual transaction. Instead, market participants above the relevant threshold must report their positions aggregated by month for the required future reporting horizon.
In practice, Exposure Reporting covers positions resulting from wholesale energy products with:
- physical delivery; or
- cash settlement.
This may include, for example, forwards, futures, options and other relevant wholesale energy products.
Who is subject to Exposure Reporting?
Exposure Reporting applies to market participants whose positions reach or exceed the relevant threshold.
The threshold is:
600 GWh per year
This threshold is assessed separately for:
- electricity; and
- natural gas.
This means that a market participant may be above the threshold for electricity but below the threshold for natural gas, or vice versa.
Important: Positions must not simply be netted for the threshold assessment
For the threshold assessment, market participants should not simply offset long and short positions against each other.
ACER clarifies that the threshold should be assessed as the sum of absolute monthly values resulting from positions in wholesale energy products, separately for electricity and natural gas.
Example
| Month | Long positions | Short positions | Net position | Absolute value for threshold assessment |
|---|---|---|---|---|
| October 2027 | 300 GWh | 250 GWh | +50 GWh | 550 GWh |
| November 2027 | 200 GWh | 100 GWh | +100 GWh | 300 GWh |
| December 2027 | 150 GWh | 180 GWh | -30 GWh | 330 GWh |
In this example, the net position for October would be only +50 GWh. However, for the threshold assessment, the relevant value would be 550 GWh, because long and short positions are considered as absolute values.
Therefore, the threshold assessment must be based on the relevant absolute monthly values, not only on the net position.
What period must be reported?
Positions must be reported aggregated by month for each of the 18 months following the last day of the reference period.
This means that the market participant calculates its open positions on the last day of the reference period and reports the monthly aggregated positions for the next 18 months.
ACER has clarified that the first reporting is expected by 31 October 2027, covering monthly positions from October 2027 to March 2029.
Example
If the reference period ends on 30 September 2027, the market participant calculates its positions as of that date and reports its monthly positions for:
- October 2027
- November 2027
- December 2027
- …
- March 2029
Any later changes to positions are reflected in the next reporting cycle.
Reporting frequency
Exposure Reporting is expected to be submitted on a quarterly basis.
The first reporting is expected by:
31 October 2027
Afterwards, market participants above the threshold are expected to report their positions quarterly.
Day-ahead and intraday spot market data
Day-ahead and intraday spot market data should generally not be included for the purpose of Exposure Reporting.
Exposure Reporting is forward-looking and focuses on future positions. ACER indicates that day-ahead and intraday spot market data should not be considered for Exposure Reporting, while forwards, futures and option contracts should be included where relevant.
Forecasted generation and consumption
Article 6 also refers to information about forecasted volumes of electricity or natural gas production and consumption.
However, ACER indicates that such forecasted generation and consumption data will be requested upon ACER’s request. Market participants should therefore distinguish between:
- regular reporting of positions, where the threshold is met; and
- forecasted production or consumption data, which may be required upon request by ACER.
Further technical guidance and reporting formats are expected from ACER.
Battery storage and Exposure Reporting
Battery storage should generally be treated as part of electricity exposure reporting.
Where battery-related contracts qualify as wholesale energy products, the resulting positions should be included in the market participant’s electricity exposure calculation.
This may include, for example:
- electricity forwards linked to battery charging or discharging;
- futures or options relating to electricity;
- physical or cash-settled electricity positions connected with the battery’s market activity.
If the market participant reaches or exceeds the 600 GWh per year threshold for electricity, the relevant battery-related electricity positions must be included in Exposure Reporting.
Battery storage should not be treated as a separate exposure category. It is normally included under electricity.
Practical summary
REMIT Exposure Reporting is a new reporting obligation for market participants with significant electricity or natural gas positions.
The key points are:
- Exposure Reporting applies to aggregated future positions.
- Electricity and natural gas are assessed separately.
- The relevant threshold is 600 GWh per year.
- For the threshold assessment, positions must not simply be netted.
- ACER refers to the sum of absolute monthly values.
- Positions are reported monthly for the following 18 months.
- The first reporting is expected by 31 October 2027.
- Day-ahead and intraday spot data should generally not be included.
- Forecasted production and consumption data may be required upon ACER’s request.
- Battery storage positions are generally treated as electricity positions where the related contracts qualify as wholesale energy products.