Most Energy and Kumer: EWRC market manipulation sanctions
EWRC found that Most Energy and Kumer breached Article 5 of REMIT through commercial transactions in January and June 2020, and fined each BGN 1,057,026. EWRC later described the conduct as market manipulation by sending misleading signals and price positioning.
On this page
The decision
- Authority
- Energy and Water Regulatory Commission (EWRC), Bulgaria
- Decided
- 14 November 2023
- Participants
- Most Energy AD; Kumer OOD
- Commodity
- Electricity
- Market
- Bulgarian wholesale electricity market
- Conduct period
- January and June 2020
- REMIT
- Article 5 (Market manipulation)
- Type of conduct
- Misleading signals and price positioning
- Penalty
- BGN 1,057,026 for each company (BGN 2,114,052 in total)
- Status
- Under appeal (ACER register, 2026-10-14)
What EWRC found
At a closed session on 14 November 2023, EWRC adopted a decision finding that Most Energy AD and Kumer OOD, both market participants, breached Article 5 of REMIT. The breaches were committed in January and June 2020 through commercial transactions that EWRC held to be market manipulation within the meaning of Article 5.
In its release of 22 April 2024 on Kozloduy, EWRC summarised the case as market manipulation by sending misleading signals and price positioning. The November 2023 release itself gives no description of the transactions, counterparties, volumes or prices, and does not say whether the two companies traded with each other.
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.
The penalty
EWRC sanctioned both companies under Article 224d of the Energy Act, forming each amount by its methodology for sanctions and fines under that article: BGN 1,057,026 each, BGN 2,114,052 in total. The decision can be appealed to the Administrative Court of Sofia City within 14 days of notification.
It was EWRC's third decision under Article 5, after NEK EAD and five others (25 November 2022, BGN 1,258,419 in total) and Energy Supply EOOD (23 March 2023, BGN 165,238). EWRC credited ACER's support with interpretation and guidance.
Sources
- EWRC, news release, 17 November 2023 (Press release, in Bulgarian)
- EWRC, news release on Kozloduy NPP, 22 April 2024 (Press release)
- 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.