Tooth and Claw: Navigating Enforcement at GFEX
Known for specialising in materials critical to the green energy transition, GFEX has demonstrated that its "Tooth and Claw Regulation" approach more than just a metaphor.
The Finnish national energy regulator (Energiavirasto/EV) recently published its first Annual Review of wholesale market supervision alongside a detailed technical blog. These reports provide an informative look behind the curtain of a Nordic regulator following a period of significant market volatility induced by changes to the Nordic market design. While the headlines focus on 35 cases addressed in 2025, the underlying data reveals a regulator that is increasingly confident and laser-focused on the power markets.
The statistics leave little doubt about where EVs’ priorities lie. Out of 35 cases, 33 related to power markets. This focus is driven by the rapid evolution of the Finnish energy mix and the introduction of complex new market designs, leaving gas as an apparent distant secondaryconcern in the current enforcement landscape.
The standout figure from the report is that 73% of investigations focused on the balancing market, specifically the mFRR energy market. This was largely triggered by the Nordic balancing market design changes in March 2025, which led to significant price spikes. While EVinvestigated these "exceptional situations" and "unusualprices," they found no wrongdoing at this stage. However, the regulator remains clear: monitoring is ongoing, and combined with the transition to 15-minute delivery periods, the market is only getting more complex.
Perhaps most surprising is the source of theseinvestigations. Approximately 60% of cases were identified and triggered by theEV market surveillance team itself. Notably, ACER contributed no leads over the year. This suggests that the Finnish regulator has built a robust internal monitoring capability, though they still lean on exchanges for about 30% of their alerts.
Algorithmic trading is no longer a peripheral concern, appearing in roughly 10% of the power market manipulation cases. EV’s recent blog compares the intraday market to a "wrestling ring" where algos compete for position, often creating "sawtooth" patterns in the order book. Consequently, the regulator is now demanding detailed descriptions of algo designs, emphasising that "misconduct cannot be blamed on the algorithm." Ultimately, the market participant always carries theresponsibility.
The transition to 15-minute intervals and the growth of battery storage mean the Finnish market, like other EU power markets, is becoming more technically demanding. For market participants, the primarytakeaway from these reports is the shift in supervisory style. EV is moving away from a reactive model toward one where they increasingly rely on its own internal data triggers. In this new environment, firms must be prepared to provide clear, rational justifications for their algorithmic logic and bidding strategies.
- Energy Authority's Annual Review of Wholesale Market Supervision 2025 (in Finnish)
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