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Uniper and two traders fined for blocking a gas order book (2019)

The Bundesnetzagentur fined Uniper Global Commodities SE EUR 150,000 and two traders EUR 1,500 and EUR 2,000. It found that in October 2016 their orders on both sides of the PEGAS book, with an iceberg order on one side, kept others from trading with the market area manager NCG, which was misled about the offers available.

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The decision

Authority
Bundesnetzagentur (BNetzA), Germany
Published
20 February 2019
Participants
Uniper Global Commodities SE; Two Uniper traders
Commodity
Gas
Market
PEGAS gas trading platform, where NetConnect Germany covered short-term balancing needs
Conduct period
October 2016
REMIT
Article 5 (Market manipulation)
Type of conduct
Order-book blocking
Penalty
EUR 150,000 (Uniper), EUR 1,500 and EUR 2,000 (the two traders)
Status
Final (ACER register, 2026-10-14)

What the Bundesnetzagentur found

The market area manager NetConnect Germany (NCG) used the PEGAS gas platform to cover short-term balancing energy needs. The Bundesnetzagentur found that in October 2016 two Uniper traders placed buy and sell orders in a way that let them exclude other participants from trading with NCG. They acted on both sides of the order book at once, using an iceberg order on one side to block other participants until the trade with NCG was done.

The consequence, in the agency's words, was that other participants could not submit a cheaper offer although they intended to, and NCG was deceived about the offers available. The agency applied the Article 5 prohibition of market manipulation in REMIT.

The exchange operator Powernext SA and an affected participant had reported the conduct in five cases. The Bundesnetzagentur found a sixth in its own analysis of the data. Uniper made about EUR 70,000 from the six manipulative transactions, which the agency took into account when setting its fine.

The penalty

The fines were EUR 150,000 for Uniper Global Commodities SE and EUR 1,500 and EUR 2,000 for the two traders. The agency said at announcement on 20 February 2019 that they were not final and that the Higher Regional Court of Düsseldorf would decide on any objection.

This account rests on the Bundesnetzagentur's announcement. The underlying fine notice and any court decision were not located for this review, so the account does not add reasoning beyond the public release.

What the decision turned on

Uniper was also accused of a breach of its supervisory duty. The agency records that Uniper and one of the traders said the behaviour was a strategy for asserting themselves against automated trading algorithms. It records that no prior check of the lawfulness of the behaviour took place, so that the traders were unsupervised. The agency held that Uniper was obliged to implement suitable and necessary supervision and control measures that would have prevented a manipulative trading strategy, or made it substantially harder.

For a surveillance function

The agency's finding against the firm rests on the absence of a prior legality check and of controls, not only on what the traders did. A firm's compliance function therefore needs to review a trading strategy for lawfulness before it is run, particularly one designed to outcompete other participants, and to monitor orders on both sides of the book.

Sources

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.

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