If a company is using a battery storage, are contracts related to the battery storage reportable under REMIT?
Answer: As a commodity storage unit, a battery storage follows the same rules as a gas storage system, which is not subject to REMIT transaction reporting according to Article 2(4) of REMIT. It follows that storage contracts are not considered wholesale energy products.
At the same time, storage system operators are required to report nomination data as fundamental data, as defined in Article 9(7) of Commission Implementing Regulation (EU) No 1348/2014, while market participants or storage system operators (on their behalf) are required to report gas storage data as specified in Article 9(9) of the same Regulation (see also Q&A III.3.30).
The situation differs when the battery storage owner performs the activities of purchase and resale of energy. In such a case, the battery storage owner is not a final customer, but a market participant entering into transactions which are reportable under REMIT (see also Q&A III.3.42).