EEX and EPEX SPOT jointly responded to the public consultation of the European Commission on fees due to ACER for tasks under REMIT. ACER should be given the proper resources to carry out its REMIT activities to ensure a high level of integrity and transparency of wholesale energy markets in Europe. A fee paid by the market itself should however be carefully designed. For this purpose, in our response, we highlight the most important principles to consider in the final fee design in order not to endanger market integrity, liquidity or transparency.
We consider, amongst others, that the fee calculation must not discourage trading on regulated and transparent trading venues. Orders should thus not be considered for the fee calculation. Second, we recommend that the final fee design and implementation is as clear and easy-to-understand as possible to enable a transparent fee calculation per market participant. Data and calculations should be provided by ACER. Finally, charging the fees directly to market participants would the most efficient approach where RRMs could collect the fee as intermediaries