Position Paper
10.04.2025
Eurogas Recommendations on Gas Storage Regulation
Read the full paper here.
Eurogas recognises the critical role of gas storage in ensuring security of supply (SoS), particularly during times of crisis. However, the European energy landscape has significantly evolved since 2022, warranting a reassessment of emergency measures. While the EU Gas Storage Regulation was important in managing gas supply during the initial shock, storage obligations carry the risk of further exacerbating the problem of high and volatile wholesale gas prices. Maintaining rigid and prescriptive storage obligations beyond the crisis period will maintain inefficiencies and unintended market distortions.
To help mitigate these unintended consequences, Eurogas' key recommendations include:
For the 2025 Filling Season:
- Clear and early communication on applicable flexibility provisions;
- Member States not to introduce additional requirements beyond the EU Storage Regulation;
- Clear timelines for possible postponement of storage targets (i.e. to 1 December).
On the potential prolongation of the Storage Filling Regulation beyond 2025:
- Amending the target setting methodology for a lower target, reflective of regional security of supply conditions;
- Removing intermediary filling trajectories;
- Strengthening and expanding existing derogations in case the target-setting methodology remains unchanged.
On implementing measures for storage filling requirements:
- Prioritising market-based storage filling;
- Preserving market efficiency and ensuring transparency in filling instruments;
- Coordination and information sharing among Member States, TSOs, SSOs & market area managers.
On the security of supply fitness check:
- The Storage Regulation should be subject to a thorough impact assessment to evaluate its economic, security and market implications before a prolongation is considered.
Download the full paper below.
