Position Paper
20.09.2023

JEAG Letter on REMIT II Trialogues

The Joint Energy Associations Group (JEAG) welcomes that the EU Commission (“EC”) has tabled its legislative proposal for a review of REMIT (Regulation on Wholesale Energy Market Integrity and Transparency – “REMIT II”) as this has contributed to an improvement in the integrity and transparency of EU wholesale energy markets. This reform should ensure that any changes are clear and implementable without causing disproportionate costs, while enhancing transparent and well-functioning energy markets. This paper summarises our views on the changes proposed by the Council and EU Parliament (“EP”) to REMIT II, in particular:

  • Market participants need to know how to comply with the new REMIT II framework based on clear,
    binding implementation rules issued by the EU Commission and non-binding ACER guidance.
  • Market participants require a sufficient implementation time of 18 months for new obligations.
  • Market participants should always be able to balance their (intermittent) production portfolio or
    to hedge their energy price risks.
  • REMIT II should not raise market access barriers negatively impacting the competitiveness and
    liquidity of EU energy markets.
  • National regulatory authorities (“NRAs”) should remain solely competent and responsible for the supervision, investigations and sanctions to avoid the creation of a double layer of oversight and enforcement.