Hungaro Energy fined HUF 350 million for gas spoofing (MEKH, 2026)
MEKH found that Hungaro Energy issued non-genuine buy orders while selling gas on six days in 2024. Its published decision explains how order timing, cancellations and execution rates supported a finding of likely false demand signals, and imposed a HUF 350 million fine.
On this page
The decision
- Authority
- Hungarian Energy and Public Utility Regulatory Authority (MEKH), Hungary
- Published
- 19 May 2026
- Participants
- Hungaro Energy Kft.
- Commodity
- Gas
- Market
- Hungarian organised gas market (the venue is redacted in the decision): day-ahead, intraday and weekend products
- Conduct period
- Six trading days between 16 April and 27 August 2024
- REMIT
- Article 5 (Market manipulation)
- Type of conduct
- Layering and spoofing
- Penalty
- HUF 350,000,000 (approx. EUR 980,000)
- Status
- Appeal possible to the Budapest-Capital Regional Court within 30 days (ACER register: Appeal Possible)
What MEKH found
Decision H1875/2026 found that Hungaro Energy breached Article 5 of REMIT by issuing orders likely to give false or misleading demand signals. MEKH identified windows on six days in 2024: 16, 19, 26 and 30 April, and 16 and 27 August. The products were day-ahead, intraday and, on 16 August, the weekend product for 17-20 August. The venue is redacted.
MEKH records two reports through ACER's notification platform, in June and October 2024, identifying eight suspected episodes. It excluded two September episodes because no buy orders were present, so the suspected spoofing or layering pattern could not exist. MEKH opened proceedings on 5 September 2025.
MEKH found the company was the largest seller on seven of the eight days examined and second largest on the other. It obtained gas mostly outside the organised market and sold mostly on it. MEKH treated selling as the genuine activity and the buy orders as non-genuine: usually at the best bid, mostly unexecuted and cancelled shortly after a sale.
How MEKH tested the orders
Applying ACER's guidance and its 2019 layering and spoofing note, MEKH held that a resting order signals to the market even if it never executes. Under Article 2(2)(a)(i), it said, neither intent nor profit is a required element; a likely false or misleading signal is sufficient.
MEKH examined whether a buy order preceded the opposite-side trade, was cancelled shortly afterwards and had disproportionate cumulative volume. Where those three criteria were not all present, it examined additional measures: order volume against opposite-side trades, time in the book and execution rate against market averages, cancellation timing and hidden iceberg volume. Most ratios are redacted.
MEKH acknowledged that some orders produced no trade or were cancelled before it. It held that an ensuing trade was not required and relied on the repeated pattern and combined indicators to establish the likely false signal.
The penalty
The decision records that the company did not answer a September 2025 request for its strategy, algorithms, controls and chat records, or collect the preliminary position sent in February 2026. MEKH relied on its own data and ACER's system, and treated the failure to respond as aggravating.
MEKH rated nine of eleven factor groups aggravating, two neutral and none mitigating. It gave greater weight to seriousness and the affected circle of 66 trader members. It also considered further similar events and a prior HUF 60,250,000 reporting fine. Harm quantified for three days was judged negligible.
Without a prior-year revenue figure, MEKH used a statutory range of HUF 5 million to HUF 2 billion. It set HUF 350,000,000, equivalent to 0.70% of reported 2023 net revenue and 17.5% of the maximum. The decision required payment within 15 days and allowed a challenge within 30 days before the Budapest-Capital Regional Court, without automatic suspension.
For a surveillance function
MEKH's analysis combines the sequence of opposite-side orders and trades with execution rates, resting times and cancellation timing. Its exclusions and discussion of imperfect indicators show why the decision relies on the combined pattern rather than a single cancelled order.
Sources
- MEKH, decision H1875/2026 (redacted public copy) (Decision, in Hungarian)
- 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.