Vattenfall's erroneous NO2 order: a breach with no fine (RME, 2025)
RME found that Vattenfall sold 6,156 MWh too much in the NO2 day-ahead auction after failing to deduct electricity already sold through North Sea Link. Its decision of 19 February 2025 found market manipulation but imposed no fine, taking account of the single error, disclosure before further trading and absence of gain.
On this page
The decision
- Authority
- Norwegian Energy Regulatory Authority (RME) (RME), Norway
- Published
- 27 February 2025
- Participants
- Vattenfall
- Commodity
- Electricity
- Market
- Day-ahead auction for NO2
- Conduct period
- Orders placed 13 November 2022 for delivery 14 November 2022
- REMIT equivalent
- Article 5 (Market manipulation)
- Legal basis
- Norwegian NEM regulation, chapter 5 (mirrors REMIT Article 5)
- Type of conduct
- Erroneous orders
- Penalty
- Breach found, no fine
- Status
- Decision allows appeal to the Energy Appeals Board within three weeks of receipt
What RME found
RME's decision concerns orders placed on 13 November 2022 for delivery on 14 November. Vattenfall intended to offer only the difference between an updated wind forecast and its sales in the earlier North Sea Link auction. RME found that the trader instead submitted the forecast volume without subtracting those sales, duplicating almost the same volume across both auctions. The resulting excess sales were about 233-289 MWh per hour, totalling 6,156 MWh across 23 hours. Hour 7 was unaffected because the earlier sell bid had not cleared.
RME identified the event through its own market monitoring and requested an explanation in June 2023. Vattenfall attributed it to manual error and accepted that the decision concerned this incident. RME said it was not pursuing the other events initially examined, while reserving the possibility of reopening them if new information appeared. Vattenfall asked RME to make clear that the breach was objective and unintentional.
How it was established
RME reconstructed the auction using submitted bid data, correcting the order to match Vattenfall's stated intention. It put the excess volume at about 4% of NO2's daily sales. Its analysis estimated lower clearing prices in every affected hour except hours 23 and 24, when wider coupling made the price effect insignificant. The largest estimated reductions, in hours 19-22, were between 20% and 60%. Other bidding zones sharing NO2's price were also affected.
RME applied NEM section 5-4, Norway's REMIT-equivalent manipulation prohibition. It held that an order need not be visible individually, or deliberately misleading, to give a false signal. The question was its actual or likely effect on supply and price. RME also found that the remaining imbalance, only partly corrected through intraday purchases, had to be handled by Statnett.
Why there was no fine
The decision records a Nord Pool urgent market message at 16:09 on 13 November, three hours and 34 minutes after the NO2 auction results. RME accepted, with doubt, that publication was timely because Vattenfall said it published immediately on discovering the error. It nevertheless expected professional participants to detect their own mistakes when results arrive. Vattenfall placed no intraday orders before publication, so RME found no indication of insider trading.
RME considered inadequate checks a reason supporting a fine: only one minute separated copying the earlier results and submitting the new bid, with another 43 minutes remaining before gate closure. Against a fine it weighed a single incident, no previous manipulation decision against Vattenfall, no deliberate pursuit of gain and costs rather than profit. It also recorded instructions to double-check volumes and the decision to disclose before further trading. The decision allowed appeal to the Energy Appeals Board within three weeks of receipt.
For a surveillance function
RME's reasoning distinguishes the original order from its subsequent handling. It expects controls before submission, checks after results and disclosure before corrective trading. In this case those later steps mattered to the sanction, while leaving the manipulation finding intact.
Sources
- RME, Vattenfall AB - Vedtak - brudd paa forbudet mot markedsmanipulasjon, 19 February 2025 (Decision, in Norwegian)
- RME, Vattenfall har brutt forbudet mot markedsmanipulasjon, 27 February 2025 (Press release, in Norwegian)
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.