Dear Partners,

In connection with the regulatory acts published in the Official Journal of the European Union on 9 April 2026, we provide you with the following information:

    ·        Commission Implementing Regulation (EU) 2026/256 of 30 January 2026 on data reporting implementing Article 7c(2), Article 8(1a), Article 8(2) and Article 8(6) of Regulation (EU) No 1227/2011 of the European Parliament and of the Council on wholesale energy market integrity and transparency and repealing Commission Implementing Regulation (EU) No 1348/2014 (“Recast REMIT IR”); and

·         Commission Delegated Regulation (EU) 2026/255 of 30 January 2026, supplementing Regulation (EU) No 1227/2011 of the European Parliament and of the Council as regards the necessary details for the authorisation and supervision of inside information platforms and registered reporting mechanisms by the European Union Agency for the Cooperation of Energy Regulators (“Delegated Regulation on RRMs and IIPs”).

 In this context, ACER has also published two open letters:

• Open letter on the implications of Regulation (EU) No 2026/256 on data reporting;
• Open letter on the implications of Commission Delegated Regulation (EU) 2026/255 on RRMs and IIPs.

Key changes under the Recast REMIT Implementing Regulation

The Recast REMIT IR repeals Commission Implementing Regulation (EU) No 1348/2014 and introduces important changes:

• New definitions, including for standard contract, non-standard contract, transaction, lifecycle event, etc.;
• Updated scope and new reporting categories based on reporting frequency: ad-hoc, upon request, periodic and continuous;
• Extended reporting scope, including:
• Additional reportable details within existing data streams;
• Newly reportable data types and transactions, including exposures; gas storage contracts; derivatives related to gas storage (options, futures, forwards, swaps, etc.); electricity storage contracts; hydrogen supply, storage and transportation contracts; transactions related to capacity mechanisms; transactions related to balancing services in electricity markets and others;
• Updated reporting timeframes for both standard (<D+2) and non-standard contracts (<D+10);
• Lifecycle events for standard contracts must be reported within (D+2);

Lifecycle events for non-standard contracts must be reported within (D+10);

Current ACER’s interpretation is that if a lifecycle event is linked to a transaction executed on an OMP, the reporting deadline remains (D+2), regardless of where the event occurs.

• Revised responsibilities regarding the reporting of fundamental data on the usage of LNG Terminals and gas storage facilities;
• New obligations for OMPs, including the responsibility to report transactions carried out or registered on their platforms;
• Obligations of Market Participants to provide information not already available to the OMP;
• Data retention requirements: Market Participants, RRMs, IIPs and OMPs must retain REMIT data for a period of 5 years;
• Obligations of Market Participants to report information on their exposures via RRM on quarterly basis;
• Enhanced ACER powers, including the ability to request additional information from Market Participants, RRMs, IIPs and OMPs.

Key elements of the Delegated Regulation on RRMs and IIPs

The Delegated Regulation introduces a new authorization regime for RRMs and IIPs and specifies operational, technical and governance requirements; requirements relating to security, data validation, and data quality; introduces supervision mechanisms and establishes a process for withdrawal and orderly substitution of reporting parties.

While the Delegated Regulation is primarily addressed to reporting entities, certain provisions will also affect Market Participants and other clients of RRMs and IIPs, for instance:

• Impact on data validation processes and the quality of submitted data;
• Changes in interactions, communications and notifications between clients and reporting entities;
• Extended scope and level of detail of messages for the disclosure of inside information.

We recommend that interested parties familiarize themselves with the relevant acts and assess their potential impact on their compliance systems, operational processes, and those related to reporting.

The open letters of ACER outline the key requirements, as well as the specific aspects related to their implementation, timelines and application. ACER will progressively update its existing REMIT guidance documents and issue new ones to support the implementation of the updated requirements.

Yоu can find more information on this matter, as well as the next steps ACER will take, on the Agency’s website.

As an OMP, BGH has already initiated the necessary measures to ensure timely compliance with the new requirements.

We remain at your disposal should you have any questions. Please do not hesitate to contact us at: admin@balkangashub.bg