German REMIT Representative for Third-Country Market Participants
- RA Dr. Hendrik Müller-Lankow, LL.M. (UCL)
- Dec 13, 2024
- 2 min read
Updated: Sep 24
Non-EU/EEA market participants trading wholesale energy products in Germany must register with the Bundesnetzagentur (BNetzA) via ACER’s CEREMP and appoint a German REMIT representative. We act as your mandated representative, so you can start trading quickly and compliantly.
Who must appoint a German REMIT representative?
Non-EU/EEA market participants that enter into wholesale energy transactions reportable under REMIT—whether bilaterally or via an organised market place such as EEX—must register with a single national regulatory authority (in Germany: Bundesnetzagentur) before trading and, as part of that registration, designate a German REMIT representative by written mandate. The representative serves as the contact point for the NRA/ACER and ensures timely cooperation and information exchange. If you are already registered with (and represented in) another EU/EEA Member State, a second German registration and representative are generally not required. This obligation also applies where the activity concerns products now within REMIT’s scope, including hydrogen wholesale energy products.
What the written mandate must cover (Article 9 REMIT)
The representative shall be designated for registration purposes by a written mandate that shall
authorise the designated representative to act on the market participants’ behalf and mandate the designated representative for the purpose of being addressed in addition to or on their behalf, by the EU/EEA national regulatory authorities or ACER, on all issues necessary for the receipt of, compliance with and enforcement of decisions or requests for information issued in relation to REMIT; and
provide the designated representative with the necessary powers and means to guarantee their efficient and timely cooperation with the EU/EEA 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 REMIT, including providing access to the requested information.
Download the draft representative agreement:
Registration steps in CEREMP (Bundesnetzagentur/ACER)
Appoint the representative by written mandate, then create/verify your CEREMP account and select the Bundesnetzagentur as the competent NRA. Complete the registration (entity/LEI and contacts), designate the representative, upload the mandate and supporting corporate documents, and submit for validation. ACER will issue or update your ACER code—keep the CEREMP record current thereafter.
Timeline, documents and fees
Once we receive complete documents (LEI, registry excerpt/board resolution, UBO details, signed mandate/PoA, contact data), we file CEREMP promptly; BNetzA/ACER validation usually follows shortly. Pricing is straightforward: a fixed onboarding fee (EUR 2,000) plus a monthly retainer (EUR 300) for the representative role, plus disbursements and applicable VAT.
Hydrogen markets now within scope of REMIT
Relevant wholesale energy products include spot and derivative contracts referred to in Article 2(4) of REMIT relating to the supply, transportation or storage of electricity, hydrogen or natural gas. Hydrogen is within the scope of REMIT since 2 February 2025.
Why Kronsteyn for REMIT representation
Kronsteyn advises clients with respect to German and European on wholesale energy products. In this context the German law firm also assumes the role as German REMIT representative for third-country market participants who intend to register at the Bundesnetzagentur (BNetzA). For any queries, please contact Dr. Hendrik Müller-Lankow.
