What Is REMIT II and Why It Matters?
On 7 May 2024, the European Union introduced a revised framework for wholesale energy market transparency through REMIT II (Regulation (EU) 2024/1106). The new regulation marks a significant shift in how Organised Market Places (OMPs) interact with the Agency for the Cooperation of Energy Regulators (ACER).
One of the most important changes is that OMPs now carry a direct legal obligation to report orders and trades to ACER. However, the technical specifications for these updated reporting fields are still being developed. This has left many OMPs and market participants asking the same question: What should we do now during this transition period?
The Current Legal Requirement for REMIT II Reporting
Although REMIT II is in force, the operational requirements for data reporting remain governed by the existing REMIT Implementing Regulation (EU) No 1348/2014. This remains the legal standard until it is formally revised by the European Commission.
ACER has made its position clear:
“Data reporting will continue based on Commission Implementing Regulation (EU) No 1348/2014, until the Implementing Regulation has been revised.”
— ACER.europa.eu
Similarly, the industry FAQ from Equias and EVIA reinforces this:
“Article 4 of the REMIT Implementing Regulation will continue until the REMIT Implementing Regulation has been revised.”
— EVIA FAQ, July 2024
In other words, your current reporting processes remain valid. OMPs must continue using the ACER XML format, the TRUM, and the Manual of Procedures until new technical guidelines are published.
Reporting under REMIT II
Until the new Implementing Regulation / Regulatory Technical Standards (RTS) for REMIT II are formally adopted, Organised Market Places (OMPs), brokers, and market participants must continue reporting in line with ACER’s official guidance under Implementing Regulation (EU) No 1348/2014.
ACER has confirmed in its REMIT Q&As that data reporting will remain under the existing rules until updated requirements take effect. Therefore, expanding the scope of reporting at this stage is not advisable. Official Q&A guidance can be found here: ACER REMIT Q&As.
Maintain Record-Keeping
OMPs – retain all order and transaction data for at least five years, ensuring it is retrievable for ACER or NRA review.
Brokers – ensure accurate order and execution records are stored for five years, in line with Article 7 of Implementing Regulation (EU) No 1348/2014.
Market participants – maintain complete trade records, including bilateral transactions, for at least five years as per Article 8(4) of Regulation (EU) No 1227/2011.
Prepare for REMIT II Requirements
OMPs – review and strengthen direct reporting channels to ACER, identify data quality gaps, and prepare for extended reporting fields.
Brokers – align order capture and enrichment processes with new data standards expected under REMIT II.
Market participants – ensure internal systems can capture and transmit all required fields once RTS is published; non-EU participants should plan for RRM registration or collaboration with an RRM.
The Impact of REMIT II on Market Practices
Why REMIT II Changes the Landscape for OMPs
REMIT II aims to improve the quality, speed, and reliability of market data. ACER’s goal is to enhance its oversight of market abuse by placing the reporting duty directly on OMPs rather than relying on third-party intermediaries.
This means OMPs face new regulatory risks if they are unprepared. The transitional period should be used to:
– Upgrade system capabilities
– Review data capture processes
– Strengthen compliance and reporting governance
– Validate your RRM strategy and external dependencies
Key Takeaways for OMPs and Market Participants
– Continue reporting under REMIT Implementing Regulation (EU) No 1348/2014.
– OMPs are now legally responsible for reporting directly to ACER.
– Ensure full record-keeping for a minimum of five years.
– Begin preparing for short implementation timelines after ACER publishes updates.
Resources for Further Guidance
ACER Q&A on REMIT II Transition
EVIA / Equias REMIT II FAQ – July 2024
Official REMIT II Regulation (EU) 2024/1106
Reg-X Recommendations:
Reporting under REMIT II
Until the new Implementing Regulation / Regulatory Technical Standards (RTS) for REMIT II are formally adopted, firms should continue reporting in line with ACER’s official guidance under Implementing Regulation (EU) No 1348/2014.
ACER has confirmed in its REMIT Q&As that data reporting will remain under the existing rules until the updated requirements take effect. Therefore, expanding the scope of reporting at this stage is not advisable. Official Q&A guidance can be found here: ACER REMIT Q&As.
Maintain Record-Keeping
Firms must retain all trade and order data for at least five years, as required by Article 8(4) of Regulation (EU) No 1227/2011 and Article 7 of Implementing Regulation (EU) No 1348/2014, ensuring accessibility for ACER or other competent authorities.
Prepare for REMIT II Requirements
Use the interim period to strengthen systems for direct OMP-to-ACER reporting, review data capture processes, and address any gaps ahead of the RTS release. Non-EU OMPs should begin planning for RRM registration or partnering with an existing RRM.
How Reg‑X Can Help
At Reg‑X Innovations, we support OMPs, RRMs, and market participants through all phases of regulatory change. Our solutions are designed to support compliant reporting, effective governance, and durable system readiness.
Whether you need to audit your reporting flows, strengthen internal record-keeping, or prepare for future ACER updates, our regulatory experts are here to assist.
Contact us at [email protected]
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