REMIT II Key Takeaways: 

• REMIT II Implementing Regulation was published on 9th April 2026

• New Reporting Deadlines start on 29th April 2026: T+2 for Standard, T+10 for Non-Standard

• Exposure, LNG Market Data, Hydrogen Reporting introduced from 2027-2028

• Substantial changes to Transaction Reporting: fields added and removed from 2027

• ACER to consult on guidelines starting for phase 1 changes starting 16th April 2026

What Is the REMIT II Implementing Regulation?

The REMIT II Implementing Regulation is the revised set of technical rules that govern how wholesale energy market participants report data to ACER (the Agency for the Cooperation of Energy Regulators). It replaces the original Implementing Regulation (EU) No 1348/2014 and sits beneath REMIT II (Regulation (EU) 2024/1106) in the regulatory hierarchy.

Unlike some recent regulatory reforms elsewhere in financial services, simplification is not on the agenda. The changes are substantial, phased, and touch almost every area of REMIT reporting. Firms should review upcoming consultations carefully - including updates to the TRUM, reporting schemas, and ACER guidance - and engage early to make their voices heard.

REMIT II Implementation Timeline: Key Obligations at a Glance

What Are the Substantial Updates from the Draft in the Final Regulation?

• Effective Dates: New and revised obligations have been delayed by 2-8 months in the Final Regulation.

• Exposure Reporting Scope: Forecasted consumption and generation will now only be reportable on request by ACER, rather than reportable by default, and data will extend 18 months, instead of the 24 months in the draft.

• Exposure Reporting Threshold: The threshold of 600GWh which triggers the reporting requirement will only be applicable to positions, not forecasted consumption and generation.

• OMP Lifecycle Event Reporting: OMPs will only be required to report lifecycle events which occur on the OMP, unlike the draft, which suggested that Participants may be required to provide lifecycle event data to OMPs for reporting where the event occurred off the OMP.

What Are the Key Changes in REMIT II Reporting Deadlines?

From 29th April, reporting deadlines change across the board:

• Standard contracts: T+1 becomes T+2 - a modest but welcome extension

• Non-standard contracts: T+1 month becomes T+10 business days - a significant tightening that will require a step-up from firms relying on template-based reporting with limited technical integration

For firms in the latter camp, the immediate priority should be enhanced operational readiness. Systematic reporting should be a clear roadmap priority as soon as the new normal is established.

What Does REMIT II Require for LNG Market Data Reporting?

From 29th October 2027, LNG market participants must report LNG transactions to Registered Reporting Mechanisms (RRMs). ACER has structured these as additions to the existing Table 1, citing considerable overlap - but there are still 16 new LNG-specific concepts to contend with, which will expand into even more discrete data points once fields like "Reporter's information" and "Business contact details" are disaggregated.

The more significant challenge is the requirement to report LNG market data "as close to real time as technologically possible." Real-time REMIT transaction reporting is new territory. How strictly ACER will interpret "real time" is yet to be confirmed, but real-time systems are architecturally distinct from end-of-day systems - and some existing REMIT infrastructure will require significant re-engineering to adapt.

Why LNG is in focus: Following the sharp reduction in Russian pipeline gas - and the forthcoming full ban on both Russian LNG and pipeline gas - LNG markets have become a critical area of interest for EU regulators. REMIT II's elevated focus on LNG reflects that geopolitical and market reality.

How Does REMIT II Change Transaction Reporting?

The 18-month window also starts the clock for substantial updates to REMIT transaction reporting, with the largest changes landing in Table 1 Standard Contract reporting.

17 additional new fields (on top of LNG additions) are introduced, alongside 2 removals. The changes cluster across four areas:

• Counterparty information: Algorithm IDs and DEA end-client IDs

• Contract details: 4 new fields describing Fixing Index

• Optionality: 5 new fields

• Transaction attributes: Transaction Type, Post-Trade Event Indicator, Price Formula, and Type of Trading Venue

The greatest operational lift will fall on firms trading Standard Contracts OTC and those executing within non-standard contracts that are not currently capturing Fixing Index or Contract Optionality data at the granularity now required. The precise data model is yet to be confirmed, with consultations forthcoming on TRUM updates and reporting schema - making early engagement with those consultations all the more important.

On the removals: Type of Reporting Entity Identifier was a low-complexity, largely redundant field. The removal of Days of the Week within the Delivery Profile is more operationally welcome, though the overall structure of Delivery Profiles retains its complexity.

Tables 2, 3, and 4 add 7, 7, and 4 new fields respectively:

• Table 2: New PPA and LNG portfolio-related fields - particularly relevant given the reduced reporting timelines for non-standard contracts

• Table 3: New participant and auction fields

• Table 4: Product, allocation, and auction fields

Table 5 is newly introduced to cover the Article 9 obligation for transactions between Organised Market Places (OMPs) executed via trade-matching systems. Given the narrow scope and 18-month timeline, this is unlikely to be a near-term priority for most firms.

What Is REMIT II Exposure Reporting?

From 1st January 2027, firms above the 600 GWh annualised threshold in open energy market positions, generation, or consumption must report future energy exposure on a quarterly basis. The obligation covers:

• Trading positions in electricity and natural gas

Reporting must cover 18 months ahead from each reference quarter and be submitted via an RRM no later than the last day of the month following the reference quarter. The stated objective is to give ACER a clearer view of market participants' positions and streamline investigations into potentially suspicious market activity. This is a substantive new obligation that requires systematic processes from the outset.

Additionally, ACER may request the reporting of information for the same timeframe relating to:

• Forecasted production volumes

• Forecasted sales to final customers based on concluded contracts

What Are the REMIT II Periodic and Fundamental Data Reporting Changes?

Periodic reporting - introduced on a monthly, six-monthly, or annual basis over a 18–24 month horizon - covers transactions previously reportable only on request, as well as the addition of hydrogen reporting from July 2028. The long lead times before these obligations go live may encourage non-systematic approaches that prove less reliable and more costly over time. Firms should build systematic processes from the start.

There are also changes to Fundamental Data Reporting, Order Book reporting, and Reporting on Request, touching almost every area of the existing REMIT framework. A separate delegated regulation covers RRM and IIP registration requirements.

REMIT II Frequently Asked Questions

When did the REMIT II Implementing Regulation come into force? The revised Implementing Regulation was published in the Official Journal of the European Union and enters into force on 29th April 2026, with further obligations phasing in over 8, 18, and 24 months.

Who does REMIT II affect? REMIT II affects a wide range of firms - not just traditional energy companies. It applies to electricity and gas producers, suppliers, traders, transmission system operators, energy exchanges, LNG market participants, algorithmic traders, brokers (PPAETs), large industrial consumers (>600 GWh), and financial institutions active in wholesale energy products. Critically, it also applies to non-EU firms - including UK-based companies - that trade into European wholesale energy markets.

Does REMIT II apply to UK firms post-Brexit? Yes. UK-based market participants that enter into transactions reportable under REMIT II are required to designate an EU representative in a Member State where they are active and register with the relevant National Regulatory Authority (NRA).

What is the REMIT II deadline for non-standard contract reporting? Under the revised Implementing Regulation, non-standard contracts must be reported within T+10 business days of conclusion, modification, or termination - down from the previous T+1 month deadline.

What is the 600 GWh threshold in REMIT II? The 600 GWh threshold determines scope for both exposure reporting and the definition of wholesale energy products. Market participants with annualised positions exceeding 600 GWh in open energy markets are subject to the new quarterly exposure reporting obligation.

When does REMIT II LNG reporting start? LNG market data reporting obligations come into effect on 29th October 2027. Firms must report LNG transactions to RRMs as close to real time as technologically possible.

Will there be further REMIT II consultations? Yes. Consultations are forthcoming on updates to the TRUM, reporting schemas, and other ACER guidance. Firms should monitor and engage with these actively - particularly given the compressed timelines for non-standard contract reporting.

What Should Firms Do Next to Prepare for REMIT II?

Beyond the headline requirement changes, the revised regulation creates a rare opportunity to revisit the architecture of existing reporting systems - improving templates, adopting standards used elsewhere in the regulatory reporting landscape, and building more resilient infrastructure. Firms under delivery pressure may be tempted to focus only on mandated changes, but that approach risks a more costly rebuild in future review cycles.

Key priorities now:

• Assess your gaps against the new field requirements across Tables 1–5

• Review your non-standard contract reporting process - T+10 BD is a significant tightening

• Evaluate your LNG reporting infrastructure for real-time capability

• Engage with upcoming consultations on TRUM and reporting schema updates

• Build systematic processes for exposure and periodic reporting from the outset

Speak to a REMIT II Reporting Specialist

If you're navigating the REMIT II Implementing Regulation changes and want to understand what they mean for your specific reporting obligations, reach out to the KOR team today. KOR is a cloud-native platform providing global trade repositories and regulatory reporting services for financial markets. Our reporting specialists work across the full REMIT reporting lifecycle and can help you assess your gaps, prioritize your roadmap, and build towards systematic compliance.