ACER - Updated Remit Framework Strengthens Trust in EU Energy Markets

What changed between the Draft and the Final REMIT IR and what areas did ACER emphasise in its Open Letter?

The final REMIT IR keeps much of the structure and core approach of the August 2025 draft (click here for August 2025 draft REMIT IR and annexes), but it also introduces a number of changes firms will need to understand and implement.

Article 2 – Definitions

The final Article 2 makes only limited substantive changes, but two are important:

• Definition of “Consumption unit” now includes hydrogen. The definition of “consumption unit” now expressly includes hydrogen. In the draft, a consumption unit was “a resource receiving electricity or natural gas for its own use.” In the final text, it is “a resource receiving electricity, natural gas or hydrogen for its own use.”

Minor revision to ‘Lifecycle event’ definition. The draft captured execution of a trade without qualification. The final text now refers to modification, cancellation, correction, early termination or, where applicable, execution. While it is a small change, it recognises that execution is not relevant to every trade, order, or contract in the same way.

ACER Open Letter deep dive:

Standard vs. Non-Standard contract definitions. ACER comments on the revised standard and non-standard contract definitions (the definitions have been carried over unchanged from the 2025 draft IRs). The final Article 2 designates contracts admitted to trading at an Organised Marketplace (OMP) as standard and those contracts not admitted to trading at an OMP as non-standard. ACER further clarifies that even when a bilateral contract is based on a contract admitted to trading at an OMP, the bilateral contract should still be treated as non-standard because it is expected to contain some degree of customisation (page 7):

The reasoning for this understanding is that, even when a bilateral transaction is based on a contract admitted to trading at an OMP, it can be assumed that the bilaterally agreed contract entails some elements of customisation, which effectively distinguishes it from the contract admitted to trade on the OMP.

This further implies that all transactions concluded/taking place on an OMP will have to be reported pursuant to the timeframes set for standard contracts, while all transactions occurring outside an OMP (over-the-counter) will have to be reported following the timeframes set for non-standard contracts (see next question).

Non-Standard contract reporting is now T+10 (not T+30) and applies from 29 April 2026. On page 7, ACER provides guidance on the reporting of non-standard contracts with a worked example via question '8. What are the new reporting timeframes for standard and non-standard contracts?’:

Article 10 of the recast REMIT IR prescribes that standard contracts should be reported within two business days (T+2) and non-standard contracts should be reported within 10 business days (T+10). Lifecycle events relating to standard contracts should also be reported within T+2 and lifecycle events relating to non-standard contracts should be reported within T+10. This effectively means that even if the lifecycle event itself takes place outside an OMP but relates to a transaction that occurred on an OMP, the deadline for reporting is T+2.

The worked example provides clear guidance for market participants:

ACER expects reporting parties to adhere to the new reporting timeframes as of 29 April 2026. This means that when the conclusion of the trade, the placement of the order, the end of the auction (gate closure), or the occurrence of the lifecycle event takes place before 29 April 2026, the old reporting timeframes are applicable for those transactions. For example, if a non-standard contract is concluded on 28 April 2026 (one day before the entry into force of the recast REMIT IR) the one-month reporting timeframe still applies, and the transaction needs to be reported at the latest on 28 May 2026. Whilst if the transaction occurs on 29 April 2026, it will have to be reported at the latest by 13 May 2026.

OMP reporting obligations from 29 April 2026. ACER’s Open Letter on page 8 adds a more detailed reporting guidance for organised marketplaces (OMPs) from 29 April 2026.

• In particular, ACER says OMPs must report transactions carried out or registered on their platform as a result of secondary allocation, even where the underlying secondary allocation took place outside the OMP (with specific reference to gas or power capacity/transportation transactions). ACER also makes it clear that those trades remain non-standard contracts for reporting-timing purposes, even if they are later registered on the OMP.
• In addition, ACER says OMPs must, at the request of the market participant, make the relevant reported data of that market participant available on a continuous basis, including information showing whether the reported data comply with ACER’s validation rules.
• The Open Letter also highlights the new five-year retention obligation on OMPs for reported data under Article 8(3), including exogenous data provided to them.

For firms relying on venue reporting, this means the final REMIT IR is not only shifting responsibility onto OMPs in certain areas, but is also increasing the operational controls, retention expectations, and transparency obligations that sit around that reporting model.

OMP reporting on behalf of market participant – market participant does not have to report. ACER concludes noting that the recast REMIT IR clarifies that when an OMP reports on behalf of the market participants active on their platform, those market participants shall not report that data to ACER.

System-generated orders are still in scope for reporting purposes by OMPs but not starting immediately. ACER clarifies on page 9 under question '10 When will the reporting of system generated orders start?’ that system-generated-order reporting under Article 8(1) of the recast REMIT IR is not expected to start immediately.

• Although the recast REMIT IR provides for reporting of system-generated orders by OMPs, ACER says that this type of reporting will only commence at the request of ACER and that it does not plan to activate that reporting from 29 April 2026.
• ACER says it will communicate any such request well in advance to allow for an appropriate implementation period.

Article 4 – Transactions to be reported on a periodic basis ("periodic reporting")

Hydrogen transportation scope expanded. The final Article 4(8)(b) expands hydrogen transportation within periodic reporting. The draft text referred only to transactions relating to the transportation of hydrogen in the Union. The final text extends this to transportation of hydrogen in the Union and between transmission networks in the Union and transmission networks outside of the Union and broadens the geographic scope of the annual hydrogen reporting obligation.

More broadly, the final Article 4 confirms the move to periodic reporting for a number of new or reclassified categories, including large final-consumer OTC contracts, capacity mechanisms, balancing services, longer-duration natural gas storage contracts, and hydrogen transactions.

The final framework preserves the annual hydrogen reporting model that the 2025 draft had proposed, with the application date for Article 4(8) deferred until 1 July 2028 (with the first reporting due on 31 January 2029) while reporting dates for Article 4(2) in respect of large final-consumer contracts set to apply from 29 October 2027 (with the first reporting due on 31 January 2028) and Article 4(3) to 4(7) reporting dates begin on 29 April 2028 covering capacity mechanisms, balancing services, longer-duration natural gas storage contracts and derivatives relating to natural gas storage.

ACER Open Letter Deep Dive:

ACER’s Open Letter adds an operational perspective on periodic reporting noting that Article 4 periodic reporting will not follow the familiar Article 10 reporting timeframes e.g. T+2, T+10, and T+30. ACER noted on page 10:

Article 4 of the recast REMIT IR introduces a new type of reporting on periodic basis. The periodicity varies between the different types of transactions listed in the Article. The timing of reporting of these types of transactions is thus indicated directly in the Article and does not relate to the reporting timeframes established in Article 10 of the recast REMIT IR.

With regard to hydrogen, on page 16 ACER sets out the practical first-report timetable where, as referenced above, the first hydrogen reports are expected to be submitted by no later than 31 January 2029, covering the period from 1 July 2028 to 31 December 2028 providing firms an operational implementation timeline.

How will hydrogen transactions be reported?

Article 4(8) of the recast REMIT IR introduces the reporting of transactions related to various hydrogen contracts. These transactions are expected to be reported once a year and no later than the last day of the first month of the following year. As Article 4(8) becomes applicable as of 1 July 2028, the first reporting is expected to take place no later than 31 January 2029, covering the period from 1 July 2028 until 31 December 2028. The next report is expected to take place no later than 31 January 2030, covering the period from 1 January 2029 until 31 December 2029, and so on.

Article 5 - Transactions to be reported at the request of ACER (ad-hoc reporting)

Additional ad-hoc transaction reporting categories added. The final Article 5 on pages 8-9 of the REMIT IR keeps the REMIT IR 2025 draft’s overall ad hoc reporting definitions but expands the list of categories reportable only upon reasoned request by ACER. In particular, two additional operational categories appear in the final text:

• Transactions for gas balancing services not already reported under Article 3; and
• Details of primary capacity allocations where no bids were submitted and no capacity was allocated as a result of the allocation process.

Those categories are also highlighted in the recitals to the final REMIT IR as part of the effort to keep reporting burdens proportionate while preserving access to lower-risk data when needed for supervision.

Natural gas small-production exemption definition was widened (Article 5(1)(c)). The final text also widens the natural-gas small-production carve-out, deviating from the 2025 draft IRs. In the 2025 draft, the exemption covered transactions relating to the physical delivery of natural gas produced by a single natural gas production facility with a production capacity of 20 MW or less, unless concluded on an OMP. In the final text, it also covers delivery by production units with a combined capacity equal to or less than 20 MW (page 9) following a similar principle applying to small power generation facilities.

Transactions relating to the physical delivery of natural gas produced by a single natural gas production facility with a production capacity equal to or less than 20 MW or by production units with a combined capacity equal to or less than 20 MW, unless they are concluded on OMPs

ACER Open Letter Deep Dive:

ACER clarifies that not all unsuccessful primary capacity allocations are treated the same way. Where bids were submitted but no capacity was allocated, the reporting obligation sits under Article 8(1). Where no bids were submitted at all, Article 5(1)(i) applies, meaning those cases are reportable only upon ACER’s reasoned request and on an ad hoc basis. For firms and venues involved in capacity allocation reporting, this distinction is important for reporting requirements.

Article 6 - Exposure Reporting

Article 6 is one of the most important and relevant provisions in the final text for market participants.

Exposure reporting scope is materially narrowed. The 2025 draft proposed a quarterly exposure reporting framework covering three categories: (i) trading positions, (ii) forecast production, and (iii) forecast consumption, each reported monthly across the following 24 months. The final Article 6 materially narrows that framework.

• Routine quarterly reporting now covers only positions resulting from trading wholesale energy products, with physical delivery or cash settlement occurring within the following 18 months.
• Forecast production and forecast consumption no longer form part of the default quarterly submission and instead only need to be provided only upon request of ACER (per Article 6(4)).

The final IR's also confirm that exposure reporting must be aggregated by month, for each of the 18 months following the last day of the reference period, as calculated on the last day of the reference period.

Intragroup positions must now be separately distinguished. Another important refinement is the treatment of intragroup positions. The 2025 draft stated that the report should include intragroup transactions. The final text requires the information in Article 6(2) to be differentiated between intragroup and non-intragroup positions under Article 6(3)(d) for reporting purposes. That is more granular than the draft and will matter for internal data models and control frameworks.

Threshold calculations for 600GWh/year are, by default, simplified in the final IRs. In the 2025 draft, market participants were excluded from the reporting obligation where annual energy volumes fell below 600 GWh across all three metrics: (i) trading activity, (ii) forecast generation and (iii) forecast consumption, assessed separately for electricity and natural gas. In the final text, the threshold applies only to positions referred to in Article 6(2) i.e. “positions of market participants in wholesale energy products with physical delivery or cash settlement within the 18 months following the last day of the reference period”, assessed separately for electricity and natural gas on a yearly basis. The final REMIT IR confirms that the threshold is assessed as a sum of absolute monthly values.

As per the 2025 draft IRs, market participants must assess their threshold status on an annual basis at the end of each calendar year. We provide further analysis on threshold calculation below with reference to ACER's Open Letter.

First quarterly exposure reporting date confirmed as 31 October 2027. Finally, on timing, the final IR provides that Article 6 applies from 1 January 2027, but the first exposure report is to be submitted by 31 October 2027. ACER’s Open Letter (see page 14) makes it clear that firms may need to assess threshold applicability before the first submission deadline arrives, even though the first exposure report is not due until October 2027.

ACER Open Letter Deep Dive:

ACER provides a large amount of instructive implementation detail for market participants (pages 13-15).

ACER clarifies who is in scope and the timing logic of first reporting. The Open Letter confirms that only market participants who enter into reportable transactions and are required to report transaction records under REMIT can be subject to the exposure-reporting obligation (page 13).

Further, the timing logic is elaborated on per the extract below (page 14):

Article 6 of the recast REMIT IR becomes applicable as of 1 January 2027, whilst the first reporting shall take place in October 2027. ACER understands this to mean that, as of 1 January 2027, market participants should assess whether the threshold referenced in paragraph 5 applies to them by considering transactions concluded until 23:59 31 December 2026 with delivery in the upcoming year (1 January 2027 – 31 December 2027).

The assessment does not necessarily have to be undertaken on 1 January 2027 but can be undertaken at any time before the deadline of reporting in October 2027. What is important is that the date used for the assessment is 31 December 2026 and that the transactions included are for delivery between 1 January 2027 – 31 December 2027.

ACER explains how the 600 GWh threshold should work. The Open Letter states that firms should assess the threshold once per year, at the end of each calendar year, for the upcoming year, and do not need to re-assess during the year. It also confirms that although there is no compulsory requirement to submit the threshold calculation, firms should be able to demonstrate their assessment if asked to do so (as noted on page 13):

Market participants with positions below 600 GWh on a yearly basis, assessed separately for electricity and natural gas, are not required to report their positions resulting from trading wholesale energy products.

Consequently, market participants with positions equal to or above 600 GWh on a yearly basis, assessed separately for electricity and natural gas, are required to report their positions.

Market participants should assess whether the threshold applies to them once per year, at the end of each calendar year for the upcoming year. Market participants are thus not required to re-assess the threshold during the year.

ACER would like to stress that, while no compulsory submission of the exposure threshold calculation is required, market participants should be able to demonstrate their assessment in case of ad- hoc requests from regulators.

ACER provides further clarity on the delineation of reporting split between electricity and natural gas based on potential different threshold outcomes under question 18 'How should market participants assess the threshold for exposure reporting?' (page 18):

As the threshold should be assessed separately for electricity and natural gas, in cases where the market participant is e.g. equal to or above the threshold for electricity, but below the threshold for natural gas, it is expected that the market participant will report its positions for electricity [only].

ACER narrows the contract scope relevant for exposure reporting. In its Open Letter on page 14, ACER notes only wholesale energy products for the supply of energy under Article 2(4)(a) and 2(4)(b) of REMIT should be considered for threshold assessment and exposure positions. However, because exposure reporting is forward-looking, day-ahead and intraday spot contracts should be excluded, while forwards, futures and options should be included. This also means that transportation and storage contracts, and derivatives on them, fall outside the exposure-reporting perimeter.

In this context, ACER understands that only contracts for the supply of energy shall be considered, therefore, only points (4)(a) and (4)(b) in the definition of ‘wholesale energy product’ set out in Article 2 of REMIT, shall be taken into consideration.

Considering the forward-looking nature of the obligation, spot market data from the day-ahead and intraday timeframes should not be considered for the sake of exposure reporting. Hence, forwards and futures, as well as option contracts shall be included in the calculation of positions, and consequently also when assessing the threshold.

ACER makes an important point about forecasts. The final REMIT IR moved forecasts out of routine reporting, but ACER states on page 15 that it intends to include placeholders for forecasts of generation and consumption in the initial electronic format so that those components are ready should ACER later requests them.

In accordance with Article 17 of the recast REMIT IR, ACER will provide the electronic formats and guidance on how market participants should report their exposures by 29 October 2026. ACER plans to include guidance on forecasts and placeholders for details on forecasts of generation and consumption in the initial electronic format for exposure reporting, in order to have all components of exposure consulted and ready, in case the reporting of forecasts is requested.

It is an important message for firms intending to build long-term reporting architecture, and signals that while forecast reporting is no longer the default requirement, it has not disappeared from ACER’s supervisory toolbox. Firms should also consider developing the ability to produce forecast-generation and forecast-consumption data at relatively short notice. Even though this data is no longer part of the default quarterly submission, it may be requested by ACER. Responding to such requests will be more challenging should the market participant have developed at least a fundamental plan on how this data will be gathered and reported.

Article 8 - Reporting channels for transactions

Article 8(5) broadens exogenous-data obligation for market participants. The REMIT IR draft required market participants to provide only a narrow set of specified data to the OMP, namely the identity of the intermediate or final beneficiaries and certain lifecycle-event information occurring outside the OMP. The final text replaces that closed list with a broader obligation to provide any information not already available to the OMP that is needed for reporting. This makes the obligation more flexible and potentially much wider in practice (see the guidance from the ACER Open Letter outlined below).

ACER Open Letter Deep Dive:

ACER provides further clarity on page 9 of its Open Letter:

11. How should market participants provide exogenous data to OMPs?

In accordance with Article 8(5) of the recast REMIT IR market participants should provide to the OMP where the trading occurs, information not already available to the OMP, so that the OMP can fulfil its reporting obligations. This type of exogenous information can, for example, be the identification code of the algorithm used by the market participant in its trading activity, if not already known by the OMP, or information on the DEA client, or on sub-clients and final beneficiary, when such information has been made available to the DEA provider.

Furthermore, other examples could be the transfer price or price of the transaction in secondary allocation, if not already known by the OMP. The information should be made available by the market participant to the OMP no later than at the time of reporting as set out in Article 10 of the recast REMIT IR and should be reported by the OMP, via its RRM, as part of the OMP’s reporting obligation. How market participants provide this information to the OMP can vary between OMPs, depending on technical possibilities or other business decisions.

ACER links this requirement to Article 14 (i.e.Technical and organisational requirements and responsibility for reporting data) which deals with which party bears responsibility for timely and accurate reporting. The Open Letter notes that there is no legal requirement on market participants to retain exogenous data provided to an OMP, but it may still be in their interest to do so because they remain responsible for the completeness and accuracy of that information under Article 14.

In practice, this means firms should not treat exogenous data as an exception. It needs to be incorporated into onboarding, venue-connectivity, data-governance, and record-keeping processes if the OMP is to satisfy its reporting obligation and the market participant is to remain comfortable that the data reported on its behalf is complete and accurate.

Article 16: Repeal and transitional provision

REMIT transition arrangements and application dates are finalised. The explanatory text accompanying the 2025 draft IRs stated the revised rules would repeal the existing REMIT IR but preserve Article 3 and the Annex for up to 12 months from entry into force. The final legal text adopts a broader and more staged transitional approach:

• It repeals Implementing Regulation (EU) No 1348/2014 with effect from 29 April 2026;
• Preserves Article 3, Article 11(1), and the Annex until 29 October 2027; and
• Separately preserves Article 9(5), Article 9(9), and Article 10(1) until 29 April 2028.

Back-reporting obligation is refined. The final text also refines the back-reporting obligation. Transactions concluded before Article 4 (i.e. periodic reporting) becomes applicable must be reported within 90 days only if they remain outstanding on that date, and have not already been reported to ACER.

ACER Open Letter Deep Dive:

ACER provides an implementation approach which firms can follow.

Reporting approach and logic. On page 4, the Open Letter states that previously reported legacy Article 3 transactions (i.e. those reported on a continuous basis) do not need to be re-reported under the new formats, even if they remain outstanding. However, lifecycle updates after the transition date must comply with the final REMIT IR, and any transaction that took place before transition but is reported after transition must also follow the new regime.

ACER also adds an important operational clarification noting that while the old Article 3 and Annex formats continue during the transition, the reporting timings must follow the new REMIT IR timeframes which are important for implementation planning (note that many have dependencies on the publication of further detailed guidance).

Article 16 further specifies that transactions reported on the basis of Article 3 of Commission Implementing Regulation (EU) No 1348/2014 (transactions reported before the transition to the recast REMIT IR) are not subject to the requirements of the recast REMIT IR.

Such transactions, even if outstanding on the date of transition, do not have to be reported again, following the new formats and standards of the recast REMIT IR. However, updates to such transactions (i.e. lifecycle events) made after the transition date shall comply with the requirements of the recast REMIT IR. In connection with this, ACER would also like to emphasise that any transaction taking place before the transition date, but reported after that date, shall comply with the requirements of the recast REMIT IR.

Back-reporting clarifications. ACER adds a targeted clarification on page 5 of the Open Letter stating that the phrase “transactions which have not already been reported” is aimed at large final-consumer contracts above 600 GWh/year that were previously reported continuously and which will now move into periodic reporting under Article 4(2). Such contracts will not be subject to backloading.

ACER also explains that where such a contract had already been reported before the transition but execution occurs afterwards, that execution should be reported according to the periodic-reporting timing and specifications under Article 4(2).

This means Article 16 should be read as creating three separate implementation tasks which is a clearer operational implementation playbook than the legal text alone:

• transition of formats;
• transition of timeframes; and
• transition of legacy and backloaded transactions.

The reference to “transactions which have not already been reported” targets transaction with final consumers with a capacity of consumption higher than 600 GWh/y, which were previously reported on a continuous basis pursuant Article 3 of REMIT Implementing Regulation 1348/2014, and will move to periodic reporting (unless concluded on an OMP) under Article 4(2) of the recast REMIT IR on 29 October 2027. These type of transactions with final consumers will thus not be subject to the ‘backloading’ provision. In case such a contract was reported before the transition date, but the execution takes place afterwards, the execution is expected to follow the reporting timing and specifications for periodically reported transactions under Article 4(2), meaning the execution would be reported at the first periodic report (please see the overview table in Annex 2).

Article 17 - Entry into force and application

Application dates are now confirmed. The draft Article 17 text indicated fixed implementation dates ranging from 6 months, to 12 months and 18 months from entry into force. This approach was a cause for concern for many given the dependency on more detailed guidance from ACER.

The final Article 17 dates are still independent of the availability of the more detailed guidance but generally have longer lead times than implied by the 2025 draft IR. The final rules also state that ACER will provide guidance and electronic formats but are not bound to a legal delivery date. The dates of entry into force are as follows:

• Article 6 from 1 January 2027;
• Article 7(2), Article 10(6), Article 3, Article 4(2), Article 8(5), and the Annex from 29 October 2027;
• Article 4(1), Article 4(3) to 4(7), Article 9, Article 11(4), Article 12(5), Article 12(9), and Article 13(2) from 29 April 2028; and
• Article 4(8) from 1 July 2028.

ACER Open Letter Deep Dive:

ACER’s Open Letter confirms that several obligations have delayed application dates and that Annex 2 on page 17 of the Open Letter should be used as a practical implementation reference point. The Annex also contains dates by which ACER will publish its guidance and formats for each provision. These dates have been provided by ACER and are presumed to be indicative.

Annex Tables

The final Annex broadly preserves the draft five-table reporting formats with only minor changes instead of a complete overhaul. The most significant change is in Table 5, which was expanded in the final text. By contrast, Tables 2 to 4 appear largely unchanged as between the draft Annex and the final Annex, while Table 1 was revised in a more targeted way. Our analysis below is between the 2025 draft Annex and the final Annex.

Table 1 Changes

Table 1 was largely retained in the final Annex, but it was revised in several specific areas. The title and overall scope remain the same, covering standard contracts for the supply or storage of electricity and supply of natural gas, together with LNG market data. The most notable changes are a broader Beneficiary ID concept, a shorter Algorithm ID description, the deletion of the separate Option strike price formula field, and the resulting renumbering of later fields.

• Field 5, Algorithm ID, was shortened. In the draft, the description included an explanatory sentence stating that the algorithm ID was expected to allow the distinction among different algorithmic strategies through its components. That explanatory sentence does not appear in the final text.
• Field 10, Beneficiary ID, was broadened. In the draft, the field applied where the beneficiary was not the same as the market participant identified in field 1. In the final version, it applies where the beneficiary is not the same as the market participant identified in field 1 or field 9. That matters because field 9 concerns when a market participant acts on behalf of another party, such a in a direct electronic access (DEA) arrangement.
• Field 74, Option strike price formula, was removed. The draft included a separate field for Option strike price formula. That standalone field does not appear in the final Table 1.

It is also worth noting that Field 3, Liquidity provision activity, which identifies market making activity, remains in the final IRs.

ACER Open Letter Deep Dive:

LNG reporting migration - a phased approach.The final Table 1 brings LNG market data into the Annex structure. ACER confirms, however, that LNG market data will continue to be reported via TERMINAL until the new Table 1 becomes applicable on 29 October 2027. After that date, ACER expects LNG market data to be reported via RRMs to ARIS using a new electronic format based on Table 1 (fields 58-68 were retained from the 2025 draft IRs in this respect). ACER also says it will publish the electronic format and further LNG reporting guidance by 29 October 2026.

Table 2 Changes

Table 2 was largely preserved in the final Annex and does not appear to have been materially redesigned. The title, overall structure, numbering, and core logic remain the same for non-standard contracts for the supply or storage of electricity or the supply of natural gas. The main changes are drafting clarifications rather than new reporting requirements.

• Field 42, Option strike index, was clarified. In the draft, the wording was awkward and read as though it had not yet been fully written (“The field indicates the name for each index specify the name.”). In the final version, the field simply indicates the “name of each option strike index.”
• Field 44, Option strike index source, was also clarified. In the draft it referred to the “fixing type” for each index. In the final text it refers to the publication source for each index, which is much clearer and better aligned with the rest of the Annex.

Table 3 Changes

Table 3 appears unchanged between the draft Annex and the final Annex. The title remains the same, covering reportable details of wholesale energy products in relation to the transportation of electricity, and the visible field numbering and descriptions align on a like-for-like basis.

Table 4 Changes

Table 4 also appears materially unchanged between the draft Annex and the final Annex. The title remains the same, the common data section appears stable, and there is no visible sign of inserted fields, deleted fields, or renumbering in the compared material. Any changes here appear to be editorial in nature.

Table 5 Changes

Table 5 is where the final Annex changes most significantly. The draft version covered standard contracts for the supply or storage of electricity or supply of natural gas executed via trade-matching systems connecting two or more OMPs. The final version extends that title to cover supply or transportation or storage of electricity, and it revises the table so that several fields now expressly capture transportation-capacity information. It also adds one new field.

• Field 7, Delivery point or zone, is broadened so that it covers not only where the order is visible, but also to which zone the capacity relates to (when applicable).
• Field 10, Quantity, is broadened. In the draft REMIT IR, Quantity referred to the visible quantity in the specified delivery point or zone. In the final version, it refers to the visible quantity “and, when applicable, the available capacity in the specified delivery point(s) or zone(s).”
• Field 12, Transaction timestamp, is broadened. In the draft REMIT IR, Transaction timestamp covered the date and time of the order submission or any subsequent lifecycle event. In the final version, it also includes any change in available transportation capacity.
• *NEW* Field 13: Time interval. The new field identifies “the time interval to which the delivery or available capacity relates.” This field did not exist in the draft REMIT IR. As a consequence, Action type becomes field 14 rather than field 13.