REMIT representative for non-EU energy companies

Companies established outside the EU that trade wholesale gas or power in the EU must register with the regulator of a member state where they are active and designate a representative there (Article 9(1) REMIT). Entering EU markets? We support you from the start: German ACER code, mandate and representation.

Entering EU energy markets? Start with us

Registration has to be in place before you enter into your first transaction that must be reported to ACER, and as a non-EU company you need a representative in the same member state. We handle both together, so you are compliant from your first trade:

  1. We agree the written mandate under Article 9 REMIT with you.
  2. We prepare your registration with the Bundesnetzagentur in CEREMP, naming us as your designated representative.
  3. You receive your German ACER code, which identifies you in REMIT reporting.
  4. From then on, regulator correspondence comes to us in Germany and is forwarded to you without delay.

See ACER code registration with the Bundesnetzagentur for the details of the registration.

Already trading in the EU?

  • Registered with the Bundesnetzagentur and active in Germany: you can designate us as your representative and update your registration in CEREMP.
  • Registered in another member state: to use a representative in Germany, you must be active in Germany and move your registration to the Bundesnetzagentur with the CEREMP function “Change Member State”. You then receive a new ACER code and must report lifecycle events (novations) for outstanding trades and contracts.
  • No representative yet: the deadline of 8 November 2024 has passed and the obligation applies now. Designate a representative as soon as possible.

What your representative must be able to do

  • Be addressed by national regulators and ACER, in addition to or instead of your company, on decisions and requests for information under REMIT
  • Cooperate with regulators efficiently and on time, with the powers and means you give it, including access to the information requested
  • Act on your behalf under a written mandate

Notes by country

The rules are the same for every non-EU country. What differs is the typical company setup and what else applies at home.

Switzerland

Switzerland is neither in the EU nor in the EEA, so Swiss companies trading wholesale gas or power in the EU are non-EU market participants under REMIT. If you are active in the German market, Germany is a natural choice for registration and representation. Formal correspondence from the Bundesnetzagentur may be in German; we handle it and explain it to you in English or German. Obligations under Swiss law apply separately.

United Kingdom

Since Brexit, UK companies are non-EU market participants under EU REMIT. UK REMIT, supervised by Ofgem, applies separately: a UK registration does not replace registration with an EU regulator, and the EU requirement for a designated representative applies in addition.

Norway

Norway is not an EU member state, and Norwegian companies trading wholesale gas or power in the EU need a designated representative in the member state where they register. If you are active in Germany, we support your registration with the Bundesnetzagentur and act as your representative.

United States

US groups often trade in the EU through several legal entities. ACER assesses the obligation entity by entity: every non-EU entity that trades in the EU needs its own registration and representative, although entities active in the same member state can appoint the same representative. A non-EU subsidiary of an EU company is not covered by its parent's registration either.

United Arab Emirates

Trading companies in Dubai and Abu Dhabi that buy or sell gas or power for delivery in the EU are non-EU market participants. If several group entities trade in Germany, each needs its own registration, and we can act as the representative for all of them.

Singapore

For trading desks in Singapore, regulator decisions and requests for information arrive during European business hours. As your representative in Germany we receive them, keep track of deadlines and forward them without delay. If you are active in several member states, one representative in the EU is enough.

Common questions

Does the representative have to be our subsidiary or branch?

No. According to ACER, the representative can be a natural or legal person, including a third-party company such as a consultancy or law firm, as long as it is established or resident in the EU member state where you are registered.

Do we need a representative in every member state where we trade?

No. One representative in the EU is enough. It must be established in a member state where you are active, and you register with that member state's regulator.

Can one representative act for several companies in our group?

Yes. ACER assesses each non-EU entity separately, so each one needs its own registration and designation, but entities active in the same member state can appoint the same representative.

Who enters the representative's details in CEREMP?

The market participant itself, as the market participant user in CEREMP. We prepare the information with you and guide you through the update.

Sources

Setting up EU trading? Start with us

Tell us where you plan to trade. We prepare your registration with the Bundesnetzagentur and act as your designated representative from day one.