The EU-wide framework that protects consumers and businesses from energy market manipulation and insider trading is commonly known as “REMIT”. This framework counts on many parties collecting and monitoring data, all working together to ensure the integrity of Europe’s wholesale energy markets. National regulators are responsible for enforcing REMIT.
Today, ACER releases its annual reports on energy market surveillance, concerning:
- Persons professionally arranging transactions (PPATs): analysing their preparedness to detect and report suspicious energy market activities. PPATs are trading intermediaries such as energy exchanges, organised market places (OMPs) or brokers, who arrange or facilitate transactions in wholesale energy products.
- National energy regulatory authorities (NRAs), focusing on their analysis of suspicious transaction and order reports (STORs) submitted by PPATs, their enforcement actions and penalties.
Both reports are mandated by the 2024 revised REMIT Regulation which also expanded obligations for PPATs.
What are ACER’s key findings and recommendations?
ACER highlights the important role of PPAT market surveillance and NRA enforcement under the REMIT framework.
ACER’s analysis shows that the number and quality of suspicious breaches submitted by PPATs in 2025 increased significantly, reaching 204 reports - double the previous year’s figure. In parallel, NRAs made steady progress in screening, prioritising and closing cases.
For persons professionally arranging transactions (PPATs), ACER identified key areas in their surveillance practices where further improvements are needed:
- Strengthen functional independence and professionalisation of surveillance teams, including through appropriate training.
- Reduce over-reliance on basic monitoring tools in favour of more targeted ones.
- Expand surveillance coverage to potential breaches under REMIT Articles 3 and 4 (in addition to Article 5), across all markets and products.
- Proactively engage with market participants.
- Ensure timely and complete reporting of suspicious behaviour, focusing on effectiveness rather than formal compliance alone.
For follow-ups by national regulators, ACER recommends:
- Strengthening PPATs’ analysis of market behaviour by providing more detailed assessments of market participants’ conduct and its impact on the market.
- Further enhancing NRAs’ capacity (staff and IT resources) to manage the growing volume and complexity of cases.
- Maintaining and expanding engagement between NRAs and PPATs to further improve reporting quality.
- Ensuring timely communication with ACER to support effective coordination and case handling.
