Rethinking Gas Storage in the Review of the Security of Supply Framework

Full Eurogas position here. 

Eurogas argues the current Gas Storage Regulation, introduced as an emergency response to the 2022 crisis, should not become a permanent feature of the EU energy framework beyond its expiry in December 2027. 

Given the current geopolitical context and continued supply uncertainties, we acknowledge the need for the EU to ensure a robust, reliable and operational security of supply framework. However, from a market perspective, it is clear that the current Gas Storage Regulation and its mandatory filling obligations are not the appropriate instruments to ensure the required long-term resilience.

To ensure a future Security of Supply framework that balances resilience, affordability and well-functioning markets, Eurogas recommends that the following principles are considered: 

• Avoid extending the current Gas Storage Regulation beyond 2027 and allow storage bookings, injections and withdrawals to be driven primarily by market signals. 

• Reserve market interventions for sustained or systemic security of supply risks that cannot be addressed through normal market functioning. 

• Strengthen the conditions for well-functioning gas markets by preserving contractual flexibility, improving infrastructure interconnections and supporting investment certainty. 

• Improve security of supply assessments through better integration of gas and electricity risk and adequacy planning. 

• Consider voluntary strategic gas reserves as an emergency measure available to Member States, while ensuring they remain separate from commercial storage operations and are activated only in clearly defined crisis situations. 

• Ensure that any future security of supply measures respect Member State specificities and avoid a one-size-fits-all approach at EU level. 

Among the options to consider for long-term security of supply, strategic gas reserves could be considered as a last-resort instrument. This option could help strengthening resilience without interfering with normal functioning, by holding reserves separately from commercial stocks and releasing volumes only under predefined emergency conditions.

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