This service supports market participants who must comply with REMIT rules (inside information, market manipulation, reporting) and those facing requests or investigations from ANRE or ACER. We help you build a practical compliance framework and respond with a structured, legally consistent file.
The information is general and does not replace legal advice. Facts, documents and chronology matter.
When you need this
- You need to assess whether you qualify as a market participant under REMIT and what obligations apply.
- Your company must publish inside information and you need a defensible workflow and platform choice.
- You are implementing or reviewing transaction reporting (RRM, data fields, internal controls).
- You received requests for documents, questions, or an investigation notice from ANRE or ACER.
- You need to manage potential allegations: market manipulation, insider trading, or misleading signals.
- You operate across jurisdictions and need to align group-wide policies with Romanian requirements.
- You want a remediation plan after identifying reporting or disclosure gaps.
What we do in practice
- Map your activities to REMIT concepts (wholesale energy products, inside information, fundamental data) and identify obligations.
- Review inside information governance: detection, approval, timing, publication, and recordkeeping.
- Set a reporting workflow: roles, data sources, RRM interface, validation, and audit trails.
- Draft or review internal rules (conflicts, restricted lists, communications, record retention, escalation).
- Support registration topics (where relevant) and documentation for group structures and delegation.
- Manage responses to authority requests: deadlines, scope control, privilege and confidentiality, and file structure.
- Prepare a defensible narrative: chronology, document map, and consistent explanations.
Documents / information useful for the first review
| Document | Why it matters | Notes |
|---|---|---|
| Business model summary (products, venues, counterparties) | Helps classify your activity under REMIT | Include group structure and delegation arrangements |
| Inside information log and publication records | Shows how you identify, approve, and publish inside information | Include platform(s), timestamps, approvals |
| Trading and scheduling records | Evidence for transaction patterns and internal controls | Keep exports with identifiers and time stamps |
| Reporting set-up (RRM, data fields, mapping) | Shows how reporting is implemented and controlled | Include validation and error handling steps |
| Policies and training materials | Demonstrates governance and reasonable procedures | Include role-based responsibilities |
| Authority correspondence (ANRE/ACER) | Defines the scope and deadlines of requests | Preserve originals and attachments |
| IT and access logs (where relevant) | Supports integrity of records and internal investigations | Handle confidentiality carefully |
Risks and frequent mistakes
- Publishing inside information late or inconsistently, without a complete decision record.
- Using informal channels that are not monitored or retained according to policy.
- Assuming reporting is fully outsourced without verifying legal responsibility and controls.
- Reporting with missing or inconsistent identifiers (counterparty, venue, product taxonomy).
- Responding to authority requests without a clear chronology and document map.
- Over-sharing or under-sharing: poor scope control and confidentiality management.
FAQ
Does REMIT apply to our company?
REMIT applies to market participants active in wholesale energy markets, but obligations depend on activities and products. A short classification exercise (what you trade, where, and operational activities) usually clarifies the scope.
What counts as inside information?
Inside information is generally precise information that, if made public, would be likely to significantly affect wholesale energy prices and relates to facilities or trading decisions. In practice, you need internal criteria, examples, and recordkeeping of decisions.
Do we need a specific platform for publication?
Publication must be effective and non-discriminatory. Many market participants use dedicated inside information platforms and follow ACER and NRA guidance. The choice should be documented and applied consistently.
How should we respond to an ANRE or ACER request?
Start by preserving evidence and mapping deadlines, then build a document inventory and a chronology. Submit a structured response aligned with the request scope, managing confidentiality and privilege where applicable.
Can corrective reporting reduce exposure?
Remediation and corrective reporting can help, but steps should be planned carefully to avoid inconsistencies or unnecessary admissions. We typically align remediation with a coherent explanation and improved controls.