PPATs
Persons Professionally Arranging Transactions; ACER's primary REMIT 2.0 surveillance target.
Last refreshed: 18 May 2026 · Appears in 1 active topic
Will ACER land the first REMIT 2.0 enforcement action against a PPAT before the guidance closes?
Timeline for PPATs
Named as targets for 'targeted improvements in surveillance' by ACER
European Energy Markets: REMIT 2.0 T+10 lands; STORs double- 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
- 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
Background
PPATs (Persons Professionally Arranging Transactions) are financial intermediaries — brokers, trading platforms, clearing members, and other firms — that arrange or execute wholesale energy transactions on behalf of clients. Under REMIT 2.0 (the revised EU Regulation on wholesale energy market Integrity and transparency), PPATs carry mandatory reporting obligations and are specifically called out as a priority surveillance target by ACER. In May 2026, following the first REMIT 2.0 T+10 transaction reporting deadline on 12 May, ACER published an enforcement report calling for "targeted improvements in surveillance by trading intermediaries", directing the compliance uplift specifically at PPATs. 204 STORs (Suspicious Transaction and Order Reports) were filed by national regulators in 2025, double the 2024 figure, under the prior REMIT framework .
PPATs first acquired defined regulatory status under REMIT 2.0, which came into force in November 2024 and entered full T+10 reporting obligations on 29 April 2026. Prior to REMIT 2.0, wholesale energy transaction reporting was primarily the responsibility of market participants directly; the expansion of obligations to PPATs plugs a surveillance gap where intermediary-routed trades were less visible to national regulators and ACER. PPATs include commodity brokers, inter-dealer brokers, organised market places, and any firm whose principal activity includes arranging wholesale energy trades for clients.
The compliance paradox that ACER's May 2026 report makes operative is structural: PPATs must comply with REMIT 2.0 from 29 April under rules whose guidance document remains formally open to revision until 12 June. Energy desks using third-party PPAT intermediaries now sit inside an expanded surveillance architecture where the doubling of STORs in 2025 signals that NRA capacity is already stretched before the new data flow arrives. The first REMIT 2.0 enforcement action targeting a PPAT will set the precedent tariff for the sector.