REMIT Article 15 and the algorithmic-trading notification
Author
Volton Editorial Team
Date Published
REMIT (Regulation (EU) 1227/2011) is the EU framework that prohibits market abuse on wholesale energy markets. Its 2024 amendment (REMIT II, Regulation 2024/1106) extended the regime to cover algorithmic trading — every firm dispatching electricity by algorithm on European markets, including aggregators bidding batteries every fifteen minutes, must notify their national regulator and ACER.
In 2011, the EU passed REMIT, the Regulation on Energy Market Integrity and Transparency, to bring wholesale electricity and gas trading under formal market-abuse supervision. It set up ACER as the central watchdog. Every wholesale energy trade in the EU now gets reported to ACER. Insider trading, market manipulation, withholding capacity to push prices: all formally regulated, with national-regulator coordination behind the scenes.
In 2024 the regulation was substantially updated. Among the additions was Article 15, which for the first time brought algorithmic trading in energy markets into a formal notification regime. The text is short. Any market participant that engages in algorithmic trading on wholesale energy markets has to notify its national regulator and ACER, and it has to put in place specific organisational requirements: effective systems and risk controls, resilience, prevention of erroneous orders, and protection against the algorithm contributing to disorderly markets.
What counts as algorithmic? Broadly, any trading where a computer determines order parameters with limited human intervention: what to bid, when to bid, at what price, in what volume. That covers automated bidding agents on day-ahead and intraday, battery dispatch algorithms acting on price signals, aggregator software that turns thousands of small assets into a single market-facing schedule, and high-frequency intraday trading on continuous platforms. Practically every modern trading firm in European energy now runs at least some volume algorithmically.
Article 15 does not ban any of this. It documents it. The notification covers the trading strategies, the parameters and limits of the system, the testing methodology, and the controls. Once notified, the firm operates as a recognised algorithmic trader, with audit obligations to match.
For asset owners this is a quiet but real shift. When you ask a counterparty how your asset is being traded, under Article 15 they have to be able to answer. The risk controls described in their ACER notification are the same controls that apply when they bid your kilowatt-hours. The regulation is a transparency layer, not a brake.
Volton is notified to ACER as an algorithmic trader under Article 15. The trading systems that bid your battery into mFRR every fifteen minutes, that re-balance your portfolio in intraday when wind forecasts shift, that monitor every order before it leaves the building — all of it operates inside that regulatory frame.
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