Revision of the REMIT Implementing Regulation on data reporting

We welcome the opportunity to comment on the draft REMIT II Implementing Act and support the aim of strengthening transparency and integrity. However, we would like to highlight that the proposal raises some concerns. Please find our detailed comments in the attached file.

Balkan Gas Hub is the Bulgarian gas exchange and therefore falls under the categories of both OMP and PPAT. We manage the BGH IIP platform and have been engaged in REMIT reporting since the establishment of our organized market in 2019. We appreciate the opportunity to contribute to the European Commissions public consultation on the draft revision of the REMIT Implementing Regulation.

Fortia Energia S.L. welcomes the opportunity to contribute to the consultation on the draft REMIT Implementing Regulation. In this way, we have identified a drafting inconsistency in the draft REMIT Implementing Regulation concerning the duration threshold for gas storage contracts subject to periodic reporting: Article 4(5)-(6) states: concluded for a period of 12 months or longer (12).

FESE supports the Commissions simplification and burden reduction agenda, as well as its commitment to streamlining regulatory obligations and reducing compliance costs for the industry. In light of these objectives, the current language for the introduction of position reporting arrangements in REMIT for certain commodity derivatives, known as exposure reporting, raises significant concerns.

Eni would like to express its appreciation for the opportunity to provide feedback to the European Commission about the revision of data reporting rules under REMIT Regulation. Our detailed response here attached touches upon the following key points: i) Simplification: Proposals to further to reduce administrative burdens on MPs and REMIT ACERs costs.

BKW Energie AG welcomes the opportunity to provide feedback on the draft Implementing Regulation on Data Reporting under REMIT II. We support the goal of improving transparency and market integrity, but we see a risk that the current proposal imposes obligations that go beyond the REMIT II mandate, add unnecessary complexity, and may undermine the efficiency and competitiveness of European energy markets.

Euronext broadly supports the simplification and burden reduction agenda. In light this, the current language for the introduction of position reporting arrangements in REMIT for certain commodity derivatives, known as exposure reporting (Article 6), raises significant concerns.

AB Amber Grid, the Lithuanian natural gas Transmission System Operator (TSO) and a Registered Reporting Mechanism (RRM), ensures the secure and reliable operation of the national gas transmission system and provides transparent and timely data in line with REMIT obligations.

The European Energy Exchange (EEX) welcomes the opportunity to contribute to the consultation on the draft REMIT Implementing Regulation. EEX is committed to the most effective and efficient implementation of REMIT II. Therefore, in the attached documents, we aim to provide constructive feedback, recommendations and rationale to ensure proportionality, legal clarity, and operational feasibility.

EDF Group welcomes the opportunity given to concerned stakeholders to provide feedback on the REMIT II draft implementing act. EDF Group is committed to the importance of having sector-specific regulation for the energy sector and its objective of market transparency and integrity.

Fortum welcome and appreciate the opportunity to give feedback on the REMIT II Implementing Regulation on Data Reporting. Generally, Fortum is concerned that the draft regulation increases the reporting burden without providing a corresponding surveillance benefit.

IOGP Europe welcomes the Commissions intention to enhance market transparency and accelerate ACERs supervisory capabilities. At the same time, we believe that achieving these objectives should be balanced with realistic deadlines that reflect operational constraints and ensure that compliance remains achievable for all market participants.

Enagás welcomes the opportunity to contribute to the public consultation on the draft REMIT Implementing Regulation. This summary highlights the most relevant points. Additional analysis and legislative proposals are included in the attached document. 1.

Intercontinental Exchange (ICE) response to the European Commission Consultation on the draft REMIT Implementing Regulation and Delegated Regulation. Intercontinental Exchange Inc., on behalf of itself and its subsidiaries (ICE), appreciates the opportunity to comment on the European Commissions draft REMIT Implementing Regulation and Delegated Regulation.

EF/Proxigas welcome the opportunity to provide feedback on the Draft Implementing Regulation revising REMIT data reporting rules. Our key recommendations are as follows: Simplification: Administrative burdens on MPs should be further reduced, in line with EU competitiveness objectives. Exposure Reporting: Requirements are disproportionate.

Bulgartransgaz is a Bulgarian gas TSO and SSO, registered as REMIT market participant and RRM since 2015. We welcome the opportunity to contribute to the European Commissions public consultation on the draft revision of REMIT Implementing Regulation.

We submit this response to the European Commission regarding the draft Commission Implementing Regulation on data reporting under REMIT II. While we fully support the goal of enhancing the integrity and transparency of wholesale energy markets, we believe the current draft goes beyond its legal mandate and introduces a disproportionate and unfeasible operational burden on market participants.

Uniper welcomes and appreciates the opportunity to comment on the framework of revised REMIT (REMIT II) and especially the draft REMIT II Implementing Act (REMIT IA) and its' Annex to support the aim of strengthening transparency and integrity, and would like to provide critical feedback on the draft regarding the REMIT II IA highlighting concerns about legal clarity, operational feasibility, and the scope of…

Thank you for the opportunity to share our view on the draft regulation. Please find our points in the attached file. In addition to this, we would like to highlight the following points: - Article 4, paragraph 9c) The consumption unit in Article 2, paragraph 11 is only defined for gas and electricity and not for hydrogen.

Energy Traders Europe welcomes the opportunity to comment, as we have serious legal, operational, and technical concerns with the proposal. To ensure feasibility and alignment with REMIT II, we suggest several adjustments, for which detailed explanations and practical examples are included in the Annex.

Proxigas welcome the opportunity to provide feedback on the Draft Implementing Regulation revising REMIT data reporting rules. Our key recommendations are as follows: Simplification: Administrative burdens on MPs should be further reduced, in line with EU competitiveness objectives. Exposure Reporting: Requirements are disproportionate.

District Heating Company Legionowo Ltd. welcomes the European Commissions proposal to introduce a threshold of 600 GWh per year, below which market participants would not be required to submit the requested information under exposure reporting (i.e. data covering trading activity, forecast generation, and forecast consumption of energy). We consider this measure to be proportionate and appropriate, as it: 1.

GAZ-SYSTEM is a gas transmission system operator in Poland. The company is also the owner of the LNG Terminal. In addition, the company operates the GSA Platform, which is used for the allocation of capacity on interconnectors and provides secondary market reporting. Consequently, it has been granted Organized Marketplace (OMP) status.

Thank you for providing the opportunity to give feedback on the draft REMIT II Implementing Regulation on Data Reporting (hereinafter the IA). In our reaction we would like to raise our concerns regarding a number of items in the IA as we believe that some components go beyond the Level 1 legislation and also creates additional burdens for the market participants, therewith increasing the cost for the sector and…

We would like to thank you for the opportunity to provide feedback on the draft legislation. SEEBURGER AG is an independent RRM and transmits market participants' reports to ACER. It is also important to us to work with our customers to ensure good data quality. The proposed changes will require extensive adjustments on our part as an RRM and also for all market participants.

We are grateful for the opportunity to provide the European Commission with feedback on the revision of the data reporting rules under REMIT. While we welcome the Commissions engagement with stakeholders, we believe the draft requires further amendments to prevent market participants from facing an excessive reporting burden. 1.

Gas Infrastructure Europe (GIE) has consistently supported transparency in energy markets, not only through regulatory compliance but also by leading voluntary initiatives such as AGSI and ALSI. These platforms have become trusted tools for market participants and institutions, reinforcing GIEs commitment to open and reliable data. We strongly believe that transparency must be both effective and proportionate.

We welcome the opportunity to comment on the draft REMIT II Implementing Act. While we support the aim of strengthening transparency and integrity to ensure feasibility and alignment with REMIT II Level 1, we suggest adjustments. As member of Energy Traders Europe, we endorse the associations contribution to this public consultation.

On behalf of JAO SA, we welcome the opportunity to comment on the draft Implementing Regulation under REMIT II. We would like to provide the following observations: 1. Scope of reporting obligations For OMPs, reporting obligations should apply onto transactions and orders concluded on their platforms, as set out in Articles 7 and 11 of the draft.

SEFE Group welcomes the opportunity to comment, as we have serious legal, operational, and technical concerns with the proposal. To ensure feasibility and alignment with REMIT II, we suggest several adjustments, for which detailed explanations and practical examples are included in the Annex.

Overall, we are concerned that the draft increases reporting burden without commensurate surveillance benefit. Exposure reporting is the clearest example. The notion of flagging prima facie unjustified trading behaviour implies a de facto hedge benchmark and sanctioning deviations.

The association of European Energy Retailers (EER) welcomes the opportunity to provide feedback and expresses its concerns with the REMIT data reporting rules which add bureaucracy without strengthening market integrity. EER is in particular concerned about the exposure reporting under REMIT.

This is feedback of Equias B.V., the operator of CMS, a REMIT RRM support over 1000 enegy wholesale market participants. Please find attached two documents (possibly uploaded in two steps). Our country of origin is Netherlands (not sure if this was selected correctly in the form further down: app.country.nld)

We are grateful for the opportunity to provide the European Commission with feedback on the revision of the data reporting rules under REMIT. While we welcome the Commissions engagement with stakeholders, we believe the draft requires further amendments to prevent market participants from facing an excessive reporting burden.

Overall, we are concerned that the draft increases reporting burden without commensurate surveillance benefit. We have serious legal, operational, and technical concerns with the proposal. To ensure feasibility and alignment with REMIT II, we suggest targeted adjustments. REMIT safeguards market integrity, not corporate stability.

We welcome the opportunity to provide feedback on the proposed changes. We recognise the need to update the current REMIT legislation, including the Delegated Act and the Implementing Regulation, as well as their respective annexes. We appreciate the effort put in from the European Commission and ACER to dialogue with market participants.

The draft text does not simplify the regime, but introduces obligations that are duplicative, unclear, and operationally burdensome, with the potential to damage liquidity and weaken security of supply. CMCE calls on the Commission to: (i) limit and clarify exposure reporting, (ii) align reporting timelines to reduce complexity, and (iii) rebalance the allocation of responsibility between OMPs and market…

Industry Comments on the inclusion of lifecycle events into OMP Reporting channels for transactions We have real concerns about the proposed changes in connection with OMP reporting of lifecycle events [LCEs]. Our concern is not limited to OMPs alone; implementing the proposed changes will be equally challenging for market participants.

The European Network of Transmission System Operators for Gas (ENTSOG), founded in line with the Regulation (EC) 715/2009, has played a key role in facilitating the integration of European gas markets, ensuring technical interoperability, and supporting the security of supply through coordinated infrastructure planning.

We would like to express our appreciation for the opportunity to provide feedback to European Commission about the revision of data reporting rules under REMIT Regulation. This response incorporates our observations and suggestions based on the draft Commission Implementing Regulation and its Annex published 18th August 2025.

FGSZ Ltd. wishes to provide comments on the draft Implementing Regulation under REMIT, focusing on two main points of concern. First, we wish to draw attention to a perceived discrepancy between the explanatory memorandum and the relevant provision regarding reporting obligations for balancing contracts for the supply of natural gas.

Implementing Act In respect of the ad-hoc reporting where the market based redispatching mechanisms have been included - we take this opportunity to highlight that the definition of the respective contracts as "insignificant may not be appropriate nor consistent with the same Commission document, where it is stated that market-based redispatching could potentially lead to market manipulation, so those transactions…

Overall, we are concerned that the draft increases reporting burden without commensurate surveillance benefit. Exposure reporting is the clearest example. The notion of flagging prima facie unjustified trading behaviour implies a de facto hedge benchmark and the sanctioning of deviations from it.

On behalf of Gasunie Deutschland Transport Services GmbH, we thank you for the opportunity to comment on the draft Delegated Regulation under REMIT. We support the goal of harmonising the processes for authorisation and supervision of Inside Information Platforms (IIPs) and Registered Reporting Mechanisms (RRMs).

EnBW Energie Baden-Württemberg AG welcomes the opportunity to comment on the draft REMIT II Implementing Regulation. While we fully support efforts to strengthen market transparency and integrity, we are concerned that the current draft of the IR will increase burden on market participants without real benefit on market functioning and integrity.

We appreciate the request for stakeholder feedback on the draft REMIT II Implementing Act and support the aim of strengthening transparency and integrity. However, we have concerns with Some of the proposals. In our view, this will increase the burden, with potential impact on security of supply to the EU and ultimately result in additional costs for consumers.

Firstly, we thank the European Commission for the opportunity to provide feedback. In this note, TSOs provide constructive feedback to improve the REMIT Implementing Regulation (IR). Our detailed proposals are set out in the Attachment. We respectfully urge the Commission to review these points in detail and ensure the final REMIT IR is both effective and workable.

Thank you for the opportunity to provide feedback on the draft Commission Implementing Regulation on data reporting implementing Article 7c(2), Article 8(1a), Article 8(2) and Article 8(6) of Regulation (EU) No 1227/2011 of the European Parliament and of the Council on wholes ale energy market integrity and transparency and repealing Commission Implementing Regulation (EU) No 1348/2014 and its Annex.

We would like to thank the European Commission for providing stakeholders with the opportunity to contribute to this public consultation. This approach underscores the Commissions commitment to transparency and collaboration. In particular, we value the opportunity to support the design of a streamlined and effective reporting framework that is both practicable and proportionate to stakeholders capacities.

E.ON welcomes the opportunity to comment on the draft REMIT II Implementing Act and supports the aim of strengthening transparency and integrity, but wants to highlight that the proposal raises legal, operational, and technical concerns and requires adjustments. Detailed technical requests and practical examples are included in the Annex.

A2A welcomes the opportunity to provide feedback on the Draft Implementing Regulation revising REMIT data reporting rules. Our key recommendations are the following: Simplification: Administrative burdens on MPs should be further reduced, in line with EU competitiveness objectives.

Summary for the response In response to the European Commissions feedback collection on the REMIT Implementing Regulation, NaTran highlights the following key points: - Designation of organised marketplaces (Articles 8(9)(12)): Inclusion on the OMP list should be carefully assessed on a case-by-case basis to ensure that only relevant entities are considered.

The implementation of the new Regulation concerning data reporting under REMIT raises several practical issues that require further clarification to ensure consistent and accurate compliance across market participants. In our response, we draw attention to the following issues: 1. Lack of standardised data formats; 2. Timeline for implementation and final guidance; 3. Clarification of definitions (Article 2); 4.

Dear all, CEZ Group welcomes the opportunity to comment on the draft REMIT II Implementing Act and supports the aim of strengthening transparency and integrity, however we highlight that the proposal raises legal, operational, and technical concerns. Please find our response in the attachement. Best regards, CEZ Group

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Consultation Response on the Draft REMIT II Implementing Regulation: We welcome the opportunity to comment on the draft REMIT II Implementing Regulation. However, the proposal contradicts the EUs broader competitiveness and simplification agenda particularly the Omnibus initiative to reduce administrative burdens and strengthen the resilience of EU businesses.

We fully understand and support the Commissions intention to enhance market transparency and accelerate ACERs supervisory capabilities. At the same time, we believe that achieving these objectives should be balanced with realistic deadlines that reflect operational constraints and ensure that compliance remains achievable for all market participants.