Quick summary

REMIT II, the 2024 revision of the EU's wholesale energy market integrity rules, widens the scope of covered products and participants, mandates new reporting infrastructure, and strengthens ACER's oversight. The result is a heavier, faster and more automated compliance burden. This article sets out what changed and what it means in practice for energy traders, producers and other market participants.

Introduction

Wholesale energy trading in the EU sits at the intersection of energy and financial regulation. Since 2011, the Regulation on Wholesale Energy Market Integrity and Transparency, known as REMIT, has prohibited market abuse in electricity and gas markets and required participants to register and report market data so regulators can detect manipulation.

The energy crisis, the rise of algorithmic trading and the arrival of new energy carriers exposed the limits of that original framework. In response, the EU adopted Regulation (EU) 2024/1106, widely called REMIT II, which entered into force on 7 May 2024 (European Commission, 2024). For market participants across Denmark, the Nordics and the wider EU, it raises the bar on what must be reported, how, and to whom.

What REMIT and REMIT II cover

REMIT exists to give participants and consumers confidence that wholesale electricity and gas prices reflect genuine supply and demand rather than manipulation. It does this through two main pillars: prohibitions on insider trading and market manipulation, and obligations to register as a market participant and report transactions, orders and certain fundamental data.

REMIT II keeps that structure but extends and sharpens it. According to ACER (2024), the revision broadens the regulation's scope to cover energy storage, hydrogen, electricity balancing and relevant financial instruments, and it aligns the rules more closely with the EU's financial market legislation. The reason this alignment matters is that energy and financial markets now overlap heavily, and inconsistent rules between them created gaps that REMIT II is designed to close.

REMIT II treats wholesale energy markets less as a standalone sector and more as part of the same surveillance landscape as financial markets.

Takeaway: REMIT II keeps the original framework's two pillars but widens them to new products, participants and instruments.

What changed under REMIT II

Several structural changes stand out. ACER (2024) gains direct investigatory powers in cross-border cases involving two or more Member States, complementing rather than replacing the powers of national regulators. This closes a long-standing weakness, where market abuse spanning several countries was hard for any single national authority to pursue.

Reporting infrastructure changes too. Organised marketplaces now carry a direct legal obligation to report orders and trades to ACER for standardised contracts, rather than relying on participant-initiated arrangements. The disclosure of inside information moves onto mandatory Inside Information Platforms, replacing the previous discretionary approach, and REMIT-related data must flow through registered platforms and reporting mechanisms.

The practical effect is a shift from a system that depended partly on participants' own arrangements to one with defined, supervised channels for both trade data and inside information.

Takeaway: REMIT II hard-wires reporting into supervised platforms and gives ACER real reach across borders.

New and tighter reporting obligations

The detail of the new regime sits in secondary legislation, which raises the operational demands further. A revised Implementing Regulation on data reporting, together with its accompanying rules, expands what must be submitted and tightens deadlines, and the updated framework is set to take effect in 2026 (Baker McKenzie, 2026).

One notable addition is forward-looking exposure reporting, intended to give ACER visibility of participants' market positions so it can spot suspicious behaviour, such as a producer expecting significant generation but not appearing to hedge it. To keep the burden proportionate, a minimum threshold of 600 GWh a year applies, assessed separately for electricity and gas, below which the exposure obligation does not bite (Kromann Reumert, 2025). Certain requirements, notably for hydrogen, are phased in over time.

The reason this matters is that reporting under REMIT II is no longer only a record of what has already happened, it increasingly asks participants to expose what they expect to happen.

REMIT II shifts reporting from a backward-looking record towards forward-looking disclosure of positions and exposure.

Takeaway: The new obligations are broader, faster and more predictive, with thresholds to keep smaller participants in proportion.

What this means operationally

For most market participants, the challenge is less about understanding the prohibitions and more about meeting the data and process demands. Broader scope means more contracts and instruments to capture. Faster deadlines mean less time to validate and submit. Mandatory platforms mean integrating with specific reporting channels rather than improvising.

That points towards three priorities: complete and accurate trade and order capture, a high degree of automation so reporting keeps pace with trading, and clear internal governance over who is responsible for what. Top-tier legal analysis stresses that REMIT II ultimately demands stronger internal governance, more automation and tighter contractual discipline from participants in EU energy markets (Baker McKenzie, 2026).

Takeaway: Compliance under REMIT II depends mainly on data quality, automation and governance, not on legal interpretation alone.

Compliance as a systems problem, not a policy one

The deeper point is that REMIT II compliance is built into systems, not bolted onto them. As trading becomes faster and more automated, the only realistic way to capture every order and trade, time-stamp it, and report it through the right channel on time is for the trading and reporting systems to do it by design.

This is where regulation meets engineering. A trading platform that records a complete, auditable data trail and integrates cleanly with the required reporting infrastructure turns REMIT II from a recurring manual burden into a largely automatic byproduct of normal operation. The participants that struggle tend to be those treating reporting as a separate, after-the-fact task rather than a property of the systems they already run.

Takeaway: The participants best placed under REMIT II are those whose trading systems generate compliant, auditable reporting automatically.

Conclusion

REMIT II represents a clear step up in the EU's supervision of wholesale energy markets. It widens scope to new products and participants, mandates supervised reporting and disclosure channels, introduces forward-looking exposure reporting, and gives ACER genuine cross-border reach. The direction is unmistakable: more data, reported faster, through defined platforms, under closer scrutiny.

For energy companies across the EU, meeting that standard is largely a systems and data challenge. Those that build complete capture, automation and governance into their trading and reporting platforms will absorb REMIT II as part of normal operation, while those relying on manual processes will find the new regime increasingly hard to sustain.

FAQ

What is REMIT II?

REMIT II is the 2024 revision of the EU's Regulation on Wholesale Energy Market Integrity and Transparency, adopted as Regulation (EU) 2024/1106 and in force from 7 May 2024. It updates the original 2011 framework to reflect more complex and automated energy markets, broadening the scope of covered products and participants and strengthening reporting and oversight.

Who does REMIT II apply to?

It applies to participants in EU wholesale electricity and gas markets, including traders, producers, suppliers and, under the revision, a wider range of actors such as balancing service providers and those dealing in energy storage, hydrogen and relevant financial instruments. Organised marketplaces also carry direct reporting obligations for standardised contracts.

What are the main new obligations under REMIT II?

Key changes include mandatory use of Inside Information Platforms for disclosing inside information, direct reporting of orders and trades to ACER, and forward-looking exposure reporting designed to reveal participants' market positions. A revised Implementing Regulation expands the data to be submitted and tightens deadlines, with some requirements phased in over time.

What is exposure reporting?

Exposure reporting requires participants to disclose forward-looking information about their market positions, so ACER can identify potentially suspicious behaviour, such as expected generation that does not appear to be hedged. A minimum threshold of 600 GWh a year, assessed separately for electricity and gas, keeps smaller participants outside the obligation.

How should companies prepare for REMIT II?

The priorities are complete and accurate capture of trades and orders, automation so reporting keeps pace with trading, and clear internal governance over responsibilities. In practice this means integrating trading and reporting systems with the required platforms so that compliant, auditable reporting is generated automatically rather than assembled manually after the fact.

Sources

• REMIT II explained - Baker McKenzie - 2026 - https://www.bakermckenzie.com/en/insight/publications/2026/04/european-union-remit-ii-explained
• What energy traders and wholesale producers need to know about REMIT II - Kromann Reumert - 2025 - https://kromannreumert.com/en/news/what-energy-traders-and-wholesale-producers-need-to-know-about-the-upcoming-remit-ii
• Wholesale energy market integrity and transparency - European Commission - 2024 - https://energy.ec.europa.eu/topics/markets-and-consumers/wholesale-energy-market/wholesale-energy-market-integrity-and-transparency_en
• About REMIT - ACER - 2024 - https://www.acer.europa.eu/remit/about-remit