NEW OBLIGATIONS FOR MARKET PARTICIPANTS ACCORDING TO THE REVISED REGULATION (EU) NO 1227/2011 ON WHOLESALE MARKET INTEGRITY AND TRANSPARENCY (REMIT).

(1)of the REMIT Regulation. Non-EU market participants shall fulfill this obligation by updating their market participant registration details in the Centralised European Register of Energy Market Participants (CEREMP) by 08.11.2024. The representative shall be designated by a written mandate which takes the form of a notarial Power of Attorney by a notary public of the country where the market participant is based, bearing the Hague Convention apostille, accompanied by a Greek official translation. The representative shall be authorised to act on the market participant’s behalf, and for the purpose of being addressed in addition to or on their behalf, by the national regulatory authorities or the ACER, on all issues necessary for the receipt of, compliance with and enforcement of decisions or requests for information issued in relation to REMIT Regulation. The Non-EU market participants shall: (

1. a)provide their designated representative with the necessary powers and means to guarantee their efficient and timely cooperation with the national regulatory authorities or ACER and to comply with the decisions and requests for information of the national regulatory authorities or ACER issued in relation to the REMIT Regulation, including providing access to the requested information; and (
2. b)notify the name, email address, postal address and telephone number of their designated representative to the national regulatory authority of the Member State where that designated representative resides or is established and to the ACER. The designation of a representative shall be without prejudice to legal actions which could be initiated against the market participant itself. According to article 9 par. 1, any person professionally arranging transactions in wholesale energy products (PPATs) who reasonably suspects that an order to trade or a transaction, including any cancellation or modification thereof, whether placed on or outside an organized market place (OMP), could breach Article 3, 4 or 5, shall notify ACER and the relevant national regulatory authority without further delay and in any event no later than four weeks from the day on which that person becomes aware of the suspicious event. According to article 9 par. 2, any person professionally executing transactions under Article 16 of Regulation (EU) No 596/2014 who also executes transactions in wholesale energy products that are not financial instruments (PPETs), and who reasonably suspects that an order to trade or a transaction, including any cancellation or modification thereof, whether placed on or outside an OMP, could breach Article 3, 4 or 5 of this Regulation, shall notify ACER and the relevant national regulatory authority without further delay and in any event no later than four weeks from the day on which that person becomes aware of the suspicious event. The obligations for persons professionally arranging transactions (PPATs) under article 15

(1)became applicable on 7 May 2024. However, as way of derogation from the general entry into force, the obligations for persons professionally executing transactions (PPETs) under article 15

(2)shall only start applying from 8 November 2024 onwards. Further information and clarifications on the application of the above are provided in the Open Letter of the Agency for the Cooperation of Energy Regulators (ACER) dated 25.09.2024. Finally, as noted in Announcement of R.A.A.E.Y. dated 28.06.2024, it is reminded that relevant fields have been introduced in CEREMP in order to allow market participants to comply with the disclosure obligations related to algorithmic trading and direct electronic access in accordance with the provisions of article 5a par. 2 and article 5a par. 3 of the REMIT Regulation. Further information on the implementation of the notification obligations related to algorithmic trading and direct electronic access is provided in the Open Letter of the Agency for the Cooperation of Energy Regulators (ACER) dated 30.07.2024.