Neuro Energía y Gestión fined for controlling the order queue
CNMC found that Neuro Energía y Gestión, a consultant with access to 34 clients' digital certificates, used them to flood the continuous intraday market's processing queue with non-genuine buy orders so that its clients' genuine sell orders for the next day validated first and matched against French demand. It fined Neuro EUR 1,081,502, reduced by 20% to EUR 865,201.60 after voluntary payment, and found the 34 clients not responsible.
On this page
The decision
- Authority
- National Commission on Markets and Competition (CNMC), Spain
- Decided
- 24 July 2024
- Participants
- Neuro Energía y Gestión, S.L.
- Commodity
- Electricity
- Market
- Spanish continuous intraday market, cross-border sales contracts with France
- Conduct period
- 23 August 2022 to 15 March 2023
- REMIT
- Article 5 (Market manipulation)
- Type of conduct
- Quote stuffing
- Penalty
- EUR 865,201.60 (EUR 1,081,502 less the 20% reduction for voluntary payment); the 34 other agents were found not responsible
- Status
- Under appeal (ACER register, 2026-10-14)
What CNMC found
In resolution SNC/DE/017/23 of 24 July 2024, CNMC found that Neuro Energía y Gestión used clients' digital certificates to coordinate non-genuine orders across the continuous intraday market. Between 23 August 2022 and 15 March 2023, over 125 sessions, it used the processing queue to obtain priority for genuine next-day sell orders aimed at French demand.
The decision records 160,857 buy orders at the minimum volume of 0.1 MWh and prices between EUR -100/MWh and EUR -400/MWh, representing 39.2% of orders in the two critical windows examined. All 122,021 validated orders were cancelled, and none executed. CNMC found those shown in the book gave misleading signals, being far from the agents' genuine bidding prices. It also identified 85,605 next-day sell orders placed using 25 agents' certificates.
How it was established
OMIE reported coordinated submissions in December 2022 and March 2023. CNMC found Neuro sent baskets of up to 100 orders from two applications and two IP addresses, placing genuine sell orders within or just after the queue. Multiple certificates allowed it to avoid OMIE's per-agent message ratios.
CNMC found that Neuro adapted when the rules changed on 4 March 2023 from arrival-based to price-based order reactivation: it moved the technique to just before 21:50. OMIE had warned 26 agents, who passed warnings to Neuro; CNMC found Neuro described them as isolated errors while continuing the strategy. It estimated Neuro's earnings from its 50% success share at EUR 6,984,658.
Responsibility and penalty
Neuro argued mass submission was accepted practice, its prices were within limits, OMIE had not disabled its application and consumers benefited. CNMC rejected those arguments. It assessed the purpose and effect of orders at critical times; neither valid parameters nor a venue's failure to disable software established legitimacy. It held that proof of consumer harm was unnecessary.
CNMC found Neuro acted intentionally but found the 34 clients not responsible and closed proceedings against them: they did not know the strategy, and five had not authorised use of their certificates in that market. It separately noted that sharing credentials was not formal representation under the market rules.
CNMC set the fine at EUR 1,081,502, the 10% ceiling on Neuro's 2022 turnover, weighing intent, duration, benefit and harm to other agents. Voluntary payment on 29 May 2024 reduced it by 20% to EUR 865,201.60, conditional on waiving administrative appeals; Neuro reserved court action. CNMC ordered no restitution because it could not determine an effect on transaction prices: the identified effect was displacement of other sellers.
For a surveillance function
The decision traced orders beyond the named account to the adviser controlling the certificates, distinguishing the author of the strategy from clients unaware of it. Its findings support reviewing outsourced access and aggregated activity across accounts: the pattern CNMC identified depended on coordinated submissions under multiple identities, rather than on one account viewed alone.
Sources
- CNMC, resolution SNC/DE/017/23 (Neuro Energía y Gestión and 34 other agents), 24 July 2024 (Decision, in Spanish)
- CNMC, case file SNC/DE/017/23 (Decision, in Spanish)
- ACER, REMIT breach: Spanish energy regulator fines Neuro Energía y Gestión, 4 October 2024 (ACER 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.