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Gatekeepers and Guidance: Lessons from the ACM’s REMIT Supervision Report

Written by RegTrail | Mar 6, 2026 2:00:00 PM

The Dutch energy regulator, ACM, recently shared several updates on REMIT supervision, focusing on Direct Electronic Access (DEA) and its market observations from late 2025 (click here).

DEA Registration and the "Gatekeeper" Role 

Under REMIT, any firm trading wholesale energy products in the EU must register with a national regulatory authority. This includes firms using not only their own accounts but also those using Direct Electronic Access (DEA) to trade.

The ACM noted a broad increase in DEA trading and has been actively reminding DEA clients of their registration duties. This proactive outreach led to a significant rise in registrations.

Crucially, the ACM views DEA providers as market gatekeepers. Because these providers see all client activity, the ACM expects them to ensure their customers comply with, amongst other things, REMIT registration rules. The regulator warned it would confront providers who grant market access to unregistered firms. To manage risk, DEA providers – which include several large utilities - should make proof of REMIT registration a mandatory condition for the enrolment of any new DEA clients.

REMIT Supervision Report: July – December 2025

The ACM’s brief half-yearly report (click here) highlights its ongoing monitoring of market integrity:

  • Market Signals: The regulator investigated 17 signals of potential prohibited trading, mostly concerning market manipulation in the electricity balancing market.
  • Balancing Actions: Following extreme price reports for the ‘TTF Next Hour’ gas product, a code change on 1 January 2026 stopped its use in balancing actions to protect the market.
  • Inside Information: Compliance regarding the publication of inside information improved after the ACM voiced concerns in early 2025. However, the regulator continues to monitor the timeliness of these disclosures, especially regarding production unit failures or maintenance changes.

A Model for Supervision

The ACM’s benevolent, collaborative style is a blueprint for other regulators. By using "soft messaging" to highlight concerns before resorting to "hard power" and penalties, they proactively encourage better industry standards. This transparency helps firms from both the EU and third countries, like the UK and US, understand and meet their obligations.