OrganisationBE
PPATs
Persons Professionally Arranging Transactions; ACER's primary REMIT 2.0 surveillance target.
Last refreshed: 22 May 2026 · Appears in 1 active topic
Key Question
Why must PPATs comply with REMIT 2.0 before the guidance document is even finalised?
Timeline for PPATs
#1121 May
Mentioned in: ACER builds enforcement stack in 48 hours
European Energy Markets#1012 May
Named as targets for 'targeted improvements in surveillance' by ACER
European Energy Markets: REMIT 2.0 T+10 lands; STORs doubleCommon Questions
What are PPATs in EU energy market regulation?
PPATs (Persons Professionally Arranging Transactions) are brokers, trading platforms, clearing houses, and intermediaries that arrange or execute wholesale energy trades on behalf of clients. Under REMIT 2.0, they are required to report transactions to ACER within 10 working days of execution and to maintain suspicious transaction reporting systems.Source: Lowdown European Energy Markets
Why does ACER want PPATs to improve their market surveillance?
ACER's 2025 enforcement report found significant gaps in PPATs' suspicious transaction reporting, with many intermediaries filing no STORs despite active trading. ACER is concerned that PPATs are not detecting manipulation or insider trading at the transaction-arrangement stage, which is the earliest point at which suspicious patterns can be identified in wholesale energy markets.Source: Lowdown European Energy Markets
What is the REMIT 2.0 T+10 deadline for PPATs?
REMIT 2.0 introduced a T+10 reporting Deadline requiring PPATs to submit transaction reports to ACER within 10 working days of trade execution. The first T+10 Deadline landed on 12 May 2026. ACER reported that STOR (Suspicious Transaction and Order Report) volumes doubled compared to the equivalent period under the original REMIT framework.Source: Lowdown European Energy Markets
Background
PPATs became a REMIT 2.0 compliance category when the recast regulation entered full T+10 reporting requirements on 29 April 2026. ACER's 8 May enforcement report recorded 204 STORs in 2025, double the 2024 figure, and called for 'targeted improvements in PPAT surveillance'. The first T+10 Deadline landed 12 May; guidance consultation runs to 12 June, creating a live-compliance-before-final-guidance paradox that affects every broker and trading platform arranging EU wholesale energy trades.
More questions
Which types of firms are classified as PPATs under REMIT 2.0?
PPATs under REMIT 2.0 include energy brokers, exchange operators, organised trading facilities (OTFs), algorithmic trading platforms, clearing members, and any other professional intermediary whose business involves arranging or executing wholesale electricity or gas transactions. They are distinct from market participants who trade on their own account.Source: Lowdown European Energy Markets
What happens to a PPAT that fails to report suspicious transactions to ACER?
REMIT 2.0 empowers national regulatory authorities (NRAs) to investigate and fine PPATs that fail to meet reporting obligations. While ACER coordinates the framework, enforcement actions are brought by national regulators. Failure to submit STORs can result in fines and, in serious cases, withdrawal of authorisation to operate in EU wholesale energy markets.Source: Lowdown European Energy Markets
What are PPATs under REMIT 2.0 and who qualifies?
PPATs (Persons Professionally Arranging Transactions) are brokers, trading platforms, and any intermediaries whose principal activity includes arranging wholesale EU energy trades on behalf of clients. Under REMIT 2.0, they carry T+10 transaction reporting obligations from 29 April 2026.Source: ACER REMIT 2.0 guidance
What is the REMIT 2.0 T+10 reporting deadline for energy traders?
How many suspicious transaction reports were filed under REMIT in 2025?
204 STORs (Suspicious Transaction and Order Reports) were filed by national regulators in 2025, double the 2024 figure, according to ACER's enforcement report published 8 May 2026.Source: ACER REMIT Quarterly, May 2026
Why does ACER single out PPATs for targeted surveillance improvements?
REMIT 2.0 expanded reporting obligations to intermediaries (PPATs) that were previously less visible to regulators. ACER's May 2026 report called for targeted surveillance improvements because intermediary-routed trades represent a gap in prior REMIT enforcement.Source: ACER REMIT 2.0 enforcement report, May 2026
How the World Sees Them
EU
ACER's PPAT surveillance call is directed at intermediaries across all 27 member states; the doubling of STORs creates pressure on national regulatory authorities whose capacity has not grown in proportion.
UK
UK energy desks using EU-based PPATs face indirect REMIT 2.0 exposure through their counterparties, even though the UK no longer participates directly in REMIT enforcement following Brexit.
US
US-based commodity brokers active in EU wholesale energy markets as PPATs sit within ACER's surveillance perimeter; the T+10 deadline creates a first hard reporting test for non-EU intermediaries.
UK energy desks
UK firms using EU-based PPATs face indirect REMIT 2.0 exposure through their counterparties, even though the UK no longer participates directly in REMIT enforcement following Brexit.
EU member states
ACER's PPAT surveillance call directs NRAs across 27 member states; the doubling of STORs in 2025 signals capacity pressure before the new data flow from 29 April even lands.
US intermediaries
US-based commodity brokers active in EU wholesale energy markets as PPATs sit within ACER's surveillance perimeter; the T+10 deadline is the first hard reporting test for non-EU intermediaries.