Last Update
13. May 2026
VATE Switzerland: Reporting Obligations and Deadlines from 2027
Important Changes, Deadlines, and New Requirements
VATE: New Rules for the Swiss Energy Wholesale Market Starting in 2027
The VATE specifies, among other things, which market participants must register with the Swiss Federal Electricity Commission (ElCom), which transactions must be reported and what deadlines apply. It also governs the publication of inside information, the reporting of risk positions and several transitional periods.
Who is covered by the rules?
The BATE distinguishes between participants in the Swiss market and participants in the European market that are domiciled or resident in Switzerland. Different obligations apply to each group.
The VATE excludes certain contracts from the scope of the rules. These include, in particular, contracts for the supply or distribution of electricity or gas to end customers with an annual consumption capacity of less than 600 GWh, provided the contracts are concluded for the end customer’s actual consumption. Under certain conditions, the consumption of affiliated companies is included in the calculation (Article 2 VATE).
Who reports transactions?
Responsibility depends on the type of contract and whether it is traded on an organised market:
| Transaction or event | Responsible for reporting to ElCom |
|---|---|
| Standard contract traded on an organised market | Operator of the organised market |
| Standard contract traded outside an organised market | Swiss market participant; reporting may be delegated |
| Non-standard contract | Swiss market participant; reporting may be delegated |
| Lifecycle event involving a standard contract, carried out outside an organised market | Swiss market participant |
Under the VATE, a product is classified as a standard contract if it is admitted to trading on an organised market. The place where the contract is actually concluded does not, by itself, determine its classification (Articles 1 and 17 VATE).
What reporting deadlines apply?
The draft provides for the following deadlines for ongoing reports:
| Contract type | Reporting deadline |
|---|---|
| Standard contract | 2 working days |
| Non-standard contract with a fixed price per unit and a fixed energy volume | 10 working days |
| Other non-standard contract | 30 working days |
The deadline starts at different times depending on the product. For supply contracts and certain derivatives, it starts when the transaction takes place. For transport contracts, it starts when the allocation results are announced (Article 19 VATE).
Periodic reporting applies to certain contracts. These include some supply contracts with large end customers, as well as certain contracts related to system stability and gas. Other categories only have to be reported at ElCom’s reasoned request (Articles 20–21 VATE).
Reporting risk positions
Participants in the Swiss market must report risk positions for the following 18 months. The information must be aggregated monthly, broken down by electricity and gas and by delivery point or zone, and separated into intragroup and non-intragroup positions.
The reporting dates are 30 April, 31 July, 31 October and 31 January. An exemption is available where cumulative risk positions for electricity or gas are below 600 GWh per year (Article 22 VATE).
Transitional deadlines in the draft
| Requirement | Proposed deadline |
|---|---|
| Registration of Swiss market participants | Submit the application by 28 February 2027 to continue trading until ElCom has made a decision |
| Information about a representative in Switzerland, where required | By 1 June 2027 |
| Reporting of standard contracts by organised markets | Reporting may be deferred until 31 May 2027 |
| OTC standard contracts and non-standard contracts where the participant already reports to ACER | Reporting may be deferred until 31 October 2027 |
| The same contract categories for other participants | Reporting may be deferred until 31 December 2027 |
| First report of risk positions | 31 October 2027 for the third quarter of 2027 |
The draft provides for later reporting start dates for certain product groups: electricity storage contracts and related derivatives from 1 November 2027; certain gas products from 1 May 2028; and hydrogen-related products from 1 July 2028 (Articles 34–39 VATE).
Publication of inside information
Inside information must generally be published through an authorised platform. The draft allows publication to be deferred until 31 December 2027. For market participants already publishing under EU rules when the ordinance enters into force, the transitional deadline is shorter: 31 May 2027 (Article 35 VATE).
Fees
The draft provides for a fixed annual fee of CHF 250 for participants in the Swiss market who were registered for the entire preceding year. A variable supervisory fee may also apply. Administrative fees are generally calculated according to the time spent, at a proposed hourly rate of CHF 100 to CHF 250 (Articles 26–32 VATE).
What companies should review now
Companies should first determine whether their products and transactions fall within the scope of the BATE and whether they qualify as participants in the Swiss or European market. They should then check which party is responsible for reporting, whether reporting needs to be delegated and which transitional deadlines apply to their contracts.
As the current VATE version is provisional, companies should also refer to the definitive text and to the forms, guidance and technical requirements published by ElCom.
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.