The Evolving REMIT II Timeline and What It Means for Market Participants
Introduction
The REMIT II timeline has been a major topic across the energy trading and regulatory landscape, but as many firms have noticed, timelines have shifted.
Back in October 2025, we shared our expectations around the upcoming REMIT II changes. Now, nearly six months on, key deadlines have passed without the long-awaited Implementing Regulation. This raises an important question:
When is REMIT II actually going live, and what should market participants prepare for?
In this update, we break down:
The original REMIT timeline
What has been delivered under REMIT II so far
Revised expectations for implementation
The key changes expected in XML schemas and reporting
A Recap: The Original REMIT Timeline
2011 — REMIT I Introduced
Regulation (EU) 1227/2011 established the foundation for energy market integrity, targeting:
Insider trading
Market manipulation in wholesale energy markets
2014 — Reporting Framework Established
Implementing Regulation (EU) 1348/2014 introduced:
Transaction and order reporting
Fundamental data reporting
ACER’s ARIS reporting system
2015–2016 — Reporting Goes Live
7 October 2015 — Reporting begins for standard contracts and orders
7 April 2016 — Reporting expands to non-standard contracts and fundamental data
REMIT II: What Has Been Achieved So Far?
2022–2023 — Reform Phase
Driven by the EU energy crisis, the European Commission proposed strengthening REMIT through:
Enhanced ACER supervisory powers
LNG market monitoring
Cross-border enforcement
Oversight of algorithmic trading
April 2024 — REMIT II Adopted
Regulation (EU) 2024/1106 introduced key changes:
Stronger ACER powers
Mandatory order-book reporting by OMPs
LNG market monitoring
Oversight of third-country participants
Algorithmic trading controls
May 2024 — Entry Into Force
As of 7 May 2024:
REMIT II became legally binding
However, technical reporting requirements remained unchanged
Where Are We Now? The Missing Piece
The critical next step, the new Implementing Regulation is still pending, which continues to shape the evolving REMIT II timeline.
Current Status (2024–2026)
ACER and the European Commission are working on:
A new Implementing Regulation (replacing 1348/2014)
Updated TRUM (Transaction Reporting User Manual)
New XML schemas
Additional reportable data types
Revised REMIT II Timeline
Given the delay in publication and typical implementation lead times, the REMIT II timeline has shifted significantly:
Expected Implementing Regulation: by Q2 2026
Estimated implementation period: at least 12 months
Likely go-live: post-Q2 2027
In practical terms, firms should now plan for REMIT II reporting changes no earlier than 2027.
What Will Change? Key REMIT II Reporting Updates
Once the Implementing Regulation is published, TRUM tables and XML schemas will be significantly updated as part of the evolving REMIT II timeline.
Here are the most important expected changes:
1. New Reporting Entity Roles
REMIT II is expected to introduce clearer role definitions across:
Organised Market Places (OMPs)
Persons Professionally Arranging Transactions (PPAETs)
Potential new fields:
reportingEntityRole
arrangingEntityID
executionVenueID
Impact: Greater transparency on who executes, arranges, and reports trades.
2. Expanded Order Book Reporting
With OMPs now responsible for order-book reporting, expect:
More granular order data
Full lifecycle tracking
New attributes may include:
orderEventType
orderModificationFlag
algorithmicTradingIndicator
orderSubmissionChannel
3. Algorithmic Trading Oversight
REMIT II introduces monitoring similar to MiFID II.
Expected additions:
algorithmID
algoTradingFlag
automatedDecisionIndicator
Impact: Enhanced detection of manipulation and automated strategies.
4. More Advanced Trade Linking
To track complex trading strategies:
executionChainID
parentOrderID
childOrderID
5. LNG Reporting Expansion
Stronger LNG market monitoring will require new data fields:
lngCargoID
lngTerminalID
lngVolume
lngDeliveryWindow
6. Expanded Contract Metadata
More detailed contract classification, including:
tradingVenueType
deliveryMechanism
settlementIndex
contractStrategy
7. Enhanced Participant Identification
Stricter identification requirements, including:
Increased use of LEIs
Clearer counterparty classification
Possible additions:
participantRole
participantCountry
marketParticipantType
8. New Transaction Lifecycle Events
Beyond current action types (N, M, E, C), we may see:
R — Replace
T — Terminate
S — Suspended
9. Additional Timestamps
More granular timing fields:
orderCreationTime
orderModificationTime
executionTime
clearingTime
Impact: Improved detection of high-frequency trading behaviour.
10. Enhanced Price & Volume Structures
Future schemas may support:
priceCurve
volumeProfile
Multi-leg pricing
Use case: Complex and structured energy derivatives.
What Should Firms Do Now?
Despite the delay in the REMIT II timeline, preparation remains critical.
We recommend:
Reviewing current REMIT reporting architecture
Preparing for schema redesign and data model expansion
Monitoring ACER updates closely
Engaging early with RRMs and OMPs
How Reg-X Can Help?
At Reg-X, we support firms in meeting the enhanced requirements of REMIT II, from expanded reporting obligations and stricter data quality standards to strengthened market monitoring and surveillance, ensuring you remain compliant as regulatory expectations evolve.
Final Thoughts
REMIT II may be running behind schedule, but its impact will be significant.
As the REMIT II timeline continues to evolve, the shift is not just regulatory, it’s structural. From algorithmic trading oversight to LNG transparency and enhanced data granularity, REMIT II represents a major evolution in energy market reporting.
The key takeaway:
The deadline may have moved, but the complexity has increased.
