Suspicious transaction and order reports under REMIT
Persons professionally arranging transactions in wholesale energy products must notify ACER and the national regulator when they reasonably suspect a breach of Articles 3, 4 or 5, and must have the systems to find such suspicions in the first place.
On this page
The obligation
Article 15(1) requires any person professionally arranging transactions who reasonably suspects that an order or a transaction, including a cancellation or modification, on or outside an organised market place, could breach Article 3, 4 or 5 to notify ACER and the relevant national regulator without further delay, and in any event no later than four weeks from becoming aware of it.
Notifications go to the regulators of the member states where the participant involved is registered and where the product is delivered (Article 15(4)).
“...shall notify the Agency and the relevant national regulatory authority without further delay and in any event no later than four weeks from the day on which that person becomes aware of the suspicious event.”
The arrangements required
Article 15(3) requires effective arrangements, systems and procedures to identify potential breaches of Articles 3, 4 and 5, to keep the staff doing surveillance free of conflicts of interest and independent, and to detect and report suspicious orders and transactions. Since REMIT II, ACER publishes an annual report on how this article is implemented.
Reports that became cases
Several decisions in the register began with an exchange's report. OMIE reported the mass order submissions that led to the Gesternova and Axpo Iberia decisions; OPCOM reported the trades behind ANRE's 2024 wash trade decisions through ACER's notification platform; Powernext reported Uniper's blocking orders on PEGAS.
Sources
- 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.