REMIT 2: Exposure Reporting
Frequently Asked Questions Regarding the Identification and Disclosure of Inside Information Under REMIT.
What is REMIT Exposure Reporting?
REMIT Exposure Reporting is the reporting of aggregated future market positions resulting from wholesale energy trading, together with relevant generation and consumption forecasts where required, in order to give ACER an overview of the participant’s exposure in electricity and natural gas markets.
Links: Article 6(1) of Implementing Regulation (EU) 2026/256
Does Exposure Reporting replace transaction reporting?
No. Exposure Reporting is an additional reporting obligation. Transaction reporting continues to apply separately where transactions are reportable under REMIT.
Is the 600 GWh threshold based on net positions?
No. For the threshold assessment, positions should not simply be netted. ACER refers to the sum of absolute monthly values resulting from positions in wholesale energy products.
Are electricity and gas assessed together?
No. Electricity and natural gas are assessed separately. A market participant may be above the threshold for electricity but below the threshold for gas.
Are day-ahead and intraday transactions included?
Day-ahead and intraday spot market data should generally not be included for the purpose of Exposure Reporting.
When does Exposure Reporting start?
Article 6 applies from 1 January 2027. The first reporting is expected by 31 October 2027, covering monthly positions from October 2027 to March 2029. ACER’s REMIT implementation timeline also refers to exposure data guidance and go-live in October 2027.
How should REMIT Exposure Reporting be handled for battery storage?
Battery storage positions should be included in REMIT Exposure Reporting as electricity positions, provided the related contracts qualify as wholesale energy products. If the market participant reaches or exceeds the 600 GWh/year electricity threshold, the relevant positions must be reported to ACER.
For batteries, this means electricity-related positions, for example:
- electricity supply / offtake contracts linked to battery charging or discharging;
- forwards, futures and options relating to electricity supply;
- physical or cash-settled electricity positions connected with the battery’s market activity;
- relevant long-term or forward-looking contracts for delivery in future months.
Expose Reporting: Practical Summary
Exposure Reporting is a new REMIT reporting obligation for larger market participants with relevant annual positions of 600 GWh or more in electricity or gas. It does not concern each individual transaction, but an aggregated view of future positions.
In practical terms, it covers:
Start date and frequency:
- Positions resulting from trading wholesale energy products shall be reported:
- once per quarter (the ‘reference period’), and
- no later than the last day of the month following the last day of the reference period.
- Article 6 of the recast REMIT Implementing Regulation applies from 1 January 2027.
The first reporting shall take place in October 2027. Afterwards, market participants above the threshold should report their positions quarterly. - What must be reported in the first submission?
For the first reporting by 31 October 2027, market participants should report their monthly positions for the period from October 2027 to March 2029, i.e. the 18 months following the last day of the reference period. - ACER is expected to provide the relevant formats and guidance.
Reporting content:
- Positions from energy contracts
Exposure Reporting applies to positions resulting from wholesale energy products with physical delivery or cash settlement, especially forwards, futures and options. Day-ahead and intraday spot market data should not be included. - Electricity and gas assessed separately
The reporting threshold is assessed separately for electricity and natural gas, including LNG.
For example, if a market participant exceeds the threshold for electricity but not for gas, only electricity positions must be reported. - Threshold: 600 GWh per year
Market participants with positions below 600 GWh per year do not have to report their positions.
Market participants with positions equal to or above 600 GWh per year must report. The threshold assessment is performed annually at the end of the calendar year for the following year. - How the threshold is calculated?
According to ACER’s draft guidance, purchase (+) and sale (−) positions are first netted within the relevant monthly aggregation (i.e. for the same commodity, delivery country and delivery month). The absolute value of the resulting monthly net position is then taken. These absolute monthly values are summed over the year to assess the 600 GWh threshold, separately for electricity and gas. Net positions from different months or delivery countries are not offset against each other — only the netting within a single month is taken into account before the absolute value is applied. - Forecasts for generation and consumption
Forecasted volumes of electricity or natural gas production and consumption may also become relevant. However, ACER indicates that such forecasts must be reported only upon ACER’s request.
Note: This FAQ collection has been compiled from various sources and reflects our understanding. It is provided for informational purposes only and is not legally binding. We do not take any legal responsibility for the accuracy or completeness of the information. For legal or regulatory matters, please consult a professional.