REMIT 2026: New reporting obligations for wholesale energy companies

Key data

Wholesale energy market companies have a new compliance obligation active since 30 January 2026. The Commission Implementing Regulation (EU) 2026/256 substantially updates the technical and procedural framework for data communication to ACER, repealing the previously applicable Regulation 1348/2014.

This is not a minor adjustment: the new regulation modernizes the formats, deadlines and procedures for reporting transactions, orders and fundamental data from the wholesale market. Any company operating in these markets that has not updated its systems is already at risk of non-compliance.

What does this regulation establish?

Regulation 2026/256 develops Articles 7 quater (paragraph 2) and 8 (paragraphs 1 bis, 2 and 6) of the Regulation (EU) No 1227/2011 (REMIT), which regulates the integrity and transparency of the wholesale energy market in Europe.

In concrete terms, it establishes:

• Updated technical requirements for data communication to the European regulator (ACER).
• Procedural requirements on how, when and in what format data must be sent.
• New reporting formats for transactions, orders and fundamental market data.
• Communication deadlines renewed compared to the previous framework.

The following table summarizes the comparison between the previous and new framework:

Economic and operational impact

The impact of this regulation is primarily operational and technological. Affected companies must bear adaptation costs in three areas:

• Technological infrastructure: updating or replacing data communication systems to comply with the new technical formats required by ACER.
• Internal processes: review and adaptation of reporting workflows, including the capture, validation and submission of transactions, orders and fundamental data.
• Regulatory compliance: training of teams responsible for reporting and, where appropriate, hiring specialized advisory services.

The risk of inaction is twofold: regulatory sanctions for non-compliance with reporting obligations to ACER, and reputational risk with regulators and market counterparties. The regulation does not specify penalty amounts in its implementing text, but non-compliance with REMIT has historically resulted in enforcement proceedings by national regulators.

Who does it affect?

The regulation directly affects all companies participating in wholesale energy markets in the European Union. Specifically:

• Electricity retailers operating in wholesale markets.
• Natural gas retailers in wholesale markets.
• Producers and generators of energy selling in organized or bilateral markets.
• Traders and financial intermediaries with positions in wholesale energy products.
• Transport and distribution companies with reporting obligations under REMIT.
• Any market participant required to report transactions, orders or fundamental data to ACER in accordance with Regulation (EU) 1227/2011.

Practical example

A Spanish electricity retailer operating in the wholesale market (MIBEL) and reporting its transactions and orders daily to ACER under the Regulation 1348/2014 scheme must, from 30 January 2026, send that same data in the new technical formats established by Regulation 2026/256.

If this company has not updated its reporting platform, each transaction or fundamental data sent in the old format may be considered a breach of communication obligations to ACER. This involves reviewing with its technology provider whether the reporting system already incorporates the new data schemas, and if not, prioritizing that update urgently given that the regulation is already in force.

What should companies do now?

1. Verify the status of your reporting systems: check whether the technological platform used to communicate data to ACER is already adapted to the new formats of Regulation 2026/256. If not, contact your provider immediately.
2. Review internal data flows: identify which transactions, orders and fundamental data are subject to reporting under Articles 7 quater and 8 of REMIT, and verify that they are correctly captured with the new requirements.
3. Consult ACER or the national regulator: review the technical guides published by ACER on REMIT to confirm the exact formats and deadlines applicable from January 2026.
4. Update internal compliance procedures: document changes in reporting processes and train teams responsible for energy regulatory compliance.
5. Assess the risk of retroactive non-compliance: given that the regulation entered into force on 30 January 2026, review whether reports sent since that date comply with the new technical requirements and, if not, take corrective measures.