Layering and spoofing in energy markets under REMIT
Layering and spoofing both place orders the trader does not want executed, on one side of the book, to trade on the other side at a better price. The difference is the shape: several price levels for layering, one level for spoofing.
On this page
The definitions
ACER defines layering as issuing multiple non-genuine orders at different price levels on one side of the order book, in order to enter into transactions on the other side. Spoofing is issuing a single large or multiple non-genuine orders at the same price level on one side, for the same purpose. Its Guidance Note 1/2019 of 22 March 2019 covers both.
“Spoofing: issuing a single large or multiple non-genuine orders at the same price level on one side of the order book, in order to enter into one or multiple transactions on the other side of the order book.”
Where it happens
Both need a continuous order book: power intraday markets, gas hub spot and prompt products, and exchange-traded futures. The decisions below cover both commodities: EWRC sanctioned Energy Supply EOOD in March 2023 for layering and spoofing on the Bulgarian exchange's intraday segment, Hungary's MEKH fined Hungaro Energy in 2026 for spoofing on the organised gas market, and Ofgem fined Engie Global Markets in 2019 for spoofing a month-ahead GB gas contract in 2016.
What can explain it innocently
Orders are cancelled for legitimate reasons all the time: the market moved, a position was filled elsewhere, an algorithm re-quoted. A high cancellation ratio is not layering by itself. What a decision turns on is whether the orders were genuine when placed. MEKH's 2026 decision sets out the indicators it computed: how often the participant's orders on the suspect side executed compared with the whole market, how soon after a trade on one side the orders on the other were cancelled, and whether the genuine side used iceberg orders to hide its size. It held that the signal is established when that structural pattern and the indicators are present together.
What a review asks
For each sequence: orders placed on one side, a trade on the other, the first side cancelled shortly after; how large the cancelled orders were against the book, and whether the pattern recurs across days. Under REMIT II, a participant trading algorithmically must also have controls that prevent its systems from creating or contributing to a disorderly market (Article 5a).
Decisions
- Hungaro Energy fined HUF 350 million for gas spoofing (MEKH, 2026)Hungary · Published 19 May 2026 · Gas
- Energy Supply EOOD fined for layering and spoofing (EWRC, 2023)Bulgaria · Decided 23 March 2023 · Electricity
- Engie Global Markets fined GBP 2.1 million for gas spoofing (Ofgem)Great Britain · Published 5 September 2019 · Gas
Sources
- ACER, Guidance on the application of REMIT, 6.1st edition, 18 December 2024 (Guidance)
- Regulation (EU) No 1227/2011 (REMIT), consolidated text including Regulation (EU) 2024/1106 (Regulation)
Sources read on 15 October 2026. This guide summarises the regulation and ACER’s non-binding guidance for orientation; it is not legal advice, and the decisions it cites are the deciding authorities’ findings, some of them under appeal.