Europex and its members have been strong supporters of a centrally coordinated European market surveillance system since its early inception and continue to deeply value REMIT’s contribution to the transparency and integrity of European wholesale markets in electricity and gas. Given the lessons learnt from more than ten years of implementation, the constant evolution of the REMIT ecosystem and the energy markets themselves, we welcome that a targeted update of REMIT is being considered.
REMIT and its accompanying implementing regulation form a complex legislative framework which has been refined over the years through comprehensive and continuously updated ACER guidance as well as a steadily growing number of REMIT cases. This evolution has relied heavily on close cooperation with stakeholders and has grown into a highly specialised ecosystem with a large variety of actors. The REMIT framework covers both spot markets, which are primarily used for the physical delivery of gas and power and the balancing of the grid, as well as certain financial instruments (i.e. gas and power derivatives) which are used by market participants to protect themselves against price fluctuations. While the Commission proposal in part aims to build on this evolution, we would like to call attention to several amendments which are inconsistent, reach far beyond the initial scope of REMIT or create unnecessary barriers to trading on European wholesale energy markets.