Energy Supply EOOD fined for layering and spoofing (EWRC, 2023)
EWRC found that Energy Supply placed fictitious sell orders that briefly pushed down the price of certain intraday products, led other participants to sell to it below the price they would otherwise have accepted, then cancelled the sell orders and bought at the lower price.
On this page
The decision
- Authority
- Energy and Water Regulatory Commission (EWRC), Bulgaria
- Decided
- 23 March 2023
- Participants
- Energy Supply EOOD
- Commodity
- Electricity
- Market
- Intraday segment of the Bulgarian Independent Energy Exchange (IBEX)
- Conduct period
- 1 January 2021 to 31 March 2022
- REMIT
- Article 5 (Market manipulation)
- Type of conduct
- Layering and spoofing
- Penalty
- BGN 165,238, and an order to end the breach
- Status
- Appeal Possible (ACER register, 2026-10-14)
What EWRC found
At a session on 23 March 2023, EWRC adopted a decision imposing a property sanction of BGN 165,238 on Energy Supply EOOD for market manipulation by layering and spoofing, in breach of Article 5 of REMIT. The conduct was found between 1 January 2021 and 31 March 2022 on the intraday segment of the Bulgarian Independent Energy Exchange (IBEX). EWRC ordered the company to end the breach immediately.
Applying the indicators in ACER's guidance on layering and spoofing, EWRC found that the company issued fictitious sell orders which produced a short-term fall in the price of certain products, solely to its own benefit. In EWRC's account this gave other participants the impression that the price would keep falling, and they sold electricity to the company at lower prices than they would have traded at without the manipulation. The company then cancelled its sell orders and carried out real purchase transactions at the lower prices, making a profit EWRC called unjustified.
EWRC quoted the REMIT guidance description of the practice: multiple or large orders on one side of the order book, often far from the best bid and offer, to trade on the other side, then cancelled without intention to execute. The release gives no volumes, products, dates of individual episodes or the company's reply.
This account is based on the official public releases. EWRC's explanation of Article 74a(8) of the Energy Act states that decisions and protocols concerning REMIT Article 3 and 5 breaches are not published on its website.
Context
It was EWRC's second decision sanctioning market manipulation under Article 5, after six companies were fined BGN 1,258,419 in total on 25 November 2022. EWRC credited ACER with interpretation, guidance and ideas during the investigation, and said it was continuing work on other proceedings for market manipulation and insider trading.
For a surveillance function
The release describes the pattern as a sequence: sell orders that move the price, trades by others at the lowered price, cancellation, then the company's own purchases. A firm reviewing its own intraday order flow can read the order, trade and cancellation timeline of one participant against that sequence.
Sources
- EWRC, news release, 27 March 2023 (Press release, in Bulgarian)
- EWRC, news release, 17 November 2023 (Press release, in Bulgarian)
- ACER, overview of REMIT sanction decisions (ACER register)
Sources read on 27 October 2026. This page restates what the authority published and adds no finding of its own. A decision under appeal is not final, and its status may have changed since: check the source before relying on it.