Publications
- Consultation Responses
- Position Papers
- Press Releases
- Reports
ESMA Consultation Paper on the review of RTS 1 /RTS 2
We believe it is crucial that the illiquid market and Large-In-Scale (LIS) transactions waiver methodologies will consider the unique characteristics of commodity trading, one of them being the important role of pre-arranged trading for the development of on-screen trading.
ACER public consultation on harmonised allocation rules for long term transmission rights in accordance with the FCA Regulation
We support ACER’s approach to delete Article 59(5) of the proposal, which proposes a cap on remuneration of LTTRs in case of fallback allocation. We do not see adequate justification to extend the HAR Article 59 compensation caps to LTTR remuneration during decoupling events.
All TSOs’ Proposal for Amendment of Pricing Methodology
Europex fully supports the EU target design for balancing energy markets, including the implementation of cross-border marginal pricing. However, during the transition to the European balancing platforms, we acknowledge the potential risks of ‘exaggeratedly high’ balancing prices, as described by the TSOs.
ACER public consultation on the high-level approach for the identification of alternative bidding zone configurations to be considered for the bidding zone review
Bidding zones are a fundamental part of the electricity market design in Europe. Adequate attention must be paid to the development of alternative bidding zone configurations as well as their assessment.
Feedback on the draft Climate, Energy and Environmental Aid Guidelines (CEEAG)
To ensure that the policy objectives set out in the Green Deal get delivered at least cost and that the EU’s internal market principles are upheld, State Aid rules need to find the right balance between supporting decarbonisation projects and minimising distortion of competition and trade in the Internal Energy Market.
ESMA Consultation on Technical Standards for Commodity Derivatives – MiFID II Recovery Package
We welcome the opportunity to provide feedback to ESMA’s draft proposals for the review of RTS 21 and ITS 4 as well as the proposal for new technical standards for position management controls. Europex’ members have gained extensive experience with the implementation of the MiFID II position limit regime and position management provisions.
‘Fit for 55’ package: a coherent, competitive and innovation-friendly market framework must drive 2030 decarbonisation efforts
The ‘Fit for 55’ Package underlines the common understanding that competitive energy and emissions markets must drive decarbonisation efforts at least cost to the energy system and consumers while ensuring a high level of competition and innovation.
Fit for 70% RES? The role of the electricity market in a high-renewables energy system in 2030
We believe that a 2030 energy system that can meet these challenges must be characterised by undistorted and freely forming price signals from the energy market, efficient use of within-zone and cross-zonal transmission to balance supply and demand locally and regionally as well as increased use of storage and flexibility on the demand side.
ACER Consultation on the Draft Framework Guideline on sector- specific rules for cybersecurity aspects of cross-border electricity flows
Together with the All NEMO Committee, we welcome this opportunity to provide input on ACER’s draft Framework Guideline on electricity sector-specific rules for cybersecurity and
Draft Delegated Act on MiFID II Ancillary Activity Exemption
Europex welcomes the opportunity to provide feedback to the Commission’s public consultation on the draft delegated act for amending the ancillary activity exemption (AAE) in
Consultation on the Hydrogen and Gas Markets Decarbonisation Package
Europex fully supports this review of the legislative framework to design competitive decarbonised gas markets and ensure that gas markets contribute to the decarbonisation of
Call for Harmonised Implementation of the Clean Energy Package: Independent Aggregation Rules to Unlock Full Potential of Demand-side Flexibility
Independent Aggregators (IAs) have the potential to provide an additional means of accessing the market for small producers and end consumers, including prosumers, small-scale RES
Public consultation on reasoned amendments to CACM 2.0
The Capacity Allocation & Congestion Management (CACM) Guideline provides a vital set of rules for the operation of cross-border electricity markets and sets the basis
Review of the Harmonised Allocation Rules for long-term transmission rights and regional annexes
Europex does not see adequate justification to extend the HAR Article 59 compensation caps to LTTR remuneration during decoupling events.
Carbon Contracts for Difference (CCfDs) and their potentially distortive effects on emission markets: call for a comprehensive impact assessment
Carbon Contracts for Difference (CCfDs) have been broadly discussed as a potential instrument to support energy-intensive industries in developing and deploying low-carbon technologies. In its
Auctioning of statistical transfers: a more efficient tool for Member State cooperation on renewable energy targets for RED III
Europex welcomes the opportunity to provide feedback to this draft delegated regulation. While the current proposal for the Union Renewable Development Platform (URDP) is designed
ENTSO-E Consultation on Options for the Design of European Electricity Markets in 2030
Europex appreciates ENTSO-E’s efforts to trigger a constructive debate on market design and has provided input on selected questions. Significant volumes of RES-E are already
Targeted consultation on the review of the Directive on financial collateral arrangements
We see benefit in adding the emission allowances to the definition of financial instruments in the FCD, making it also more closely aligned to the financial instruments definition in Annex 2 of Directive 2014/65/EU (MiFID II).
VAT rules for financial and insurance services
Europex welcomes the opportunity to contribute to the present consultation. In our response, we highlight that the regime on VAT rules for financial services subject
ACER consultation on cross-zonal capacity allocation methodologies for Hansa, Core and Baltic CCRs
Europex welcomes this opportunity to respond to ACER’s public consultation on cross-zonal capacity allocation methodologies for Hansa, Core, and Baltic CRRs. Regarding the timeframe, we
Joint industry letter on the importance of linking the UK ETS with the EU ETS
Europex has joined with over 40 leading industry associations to call on the EU and UK to begin the process of linking the EU Emissions
The Digital Levy
Europex supports the Commission’s overall objective to ensure a fair taxation of the digital economy in Europe in line with the wider policy objectives set
Block Bids – A new approach for the allocation of long-term transmission rights
Europex welcomes the opportunity to comment on this joint TSO and NRA consultation on the so-called ‘block bids’ approach to LTTR allocation. We provide below
CACM 2.0 – feedback to ACER scoping issues
Europex and the All NEMO Committee appreciate the opportunity to engage in this dialogue concerning the review of CACM GL. The rules established in CACM
The European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies
Europex welcomes the opportunity to contribute to the present consultation and expresses its general support for the Commission’s good intention to facilitate the access and