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HWW Hewelt Wojnowski Lindner i Wspólnicy

REMIT and CEREMP

For companies trading in electricity or gas that need registration in CEREMP, rules for performing REMIT obligations or representation before the President of the Energy Regulatory Office (URE).

This offer is prepared by the team of HWW Hewelt Wojnowski Lindner i Wspólnicy sp.k. The matter is led by Aleksandra Lindner, partner and adwokat (Polish advocate). Telephone: +48 22 100 42 24.

Request a quote +48 22 100 42 24
Fee
from 2 300 EUR net
The quotation sets out the selected activities, the period of service and the stage of the proceedings.
Prices are net, in EUR. VAT depends on your status and place of establishment.

You can order this service directly, without a prior consultation. We confirm the scope and the fee before we start.

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A consultation is optional. To discuss your matter with a lawyer first, you can book a consultation. If you then order the work, its cost is credited against the project fee.

Before we start, we agree and confirm the scope and the fee. The price is indicative and does not constitute an offer within the meaning of the Polish Civil Code.

What it includes

  • We assess the market participant status and the registration obligation (Article 2(7) and Article 9(1) REMIT, as amended by Regulation (EU) 2024/1106). We set out the sequence of steps before the first transaction reportable to ACER (Article 9(4) REMIT).
  • We register the company in CEREMP on the URE form (Article 23a(2) of the Polish Energy Law (Prawo energetyczne)). We report changes to the data so that the entry reflects the company's situation (Article 9(5) REMIT).
  • We prepare a procedure for publication through an inside information platform (Article 4(1) REMIT). We define the conditions for delaying publication and for notifying ACER and the President of URE with reasons (Article 4(2) REMIT).
  • We organise reporting of transactions and orders to ACER through a registered reporting mechanism, that is an RRM (Article 8(1) REMIT, as amended by Regulation (EU) 2024/1106). We review the agreement with the reporting entity, the division of tasks and how errors are handled (Article 8(4)(b) REMIT).
  • We develop internal rules and run training to prevent abuse. We take account of the ban on using inside information (Article 3(1) REMIT, as amended by Regulation (EU) 2024/1106) and on market manipulation and attempted manipulation (Article 5 REMIT).
  • We represent the company in a REMIT inspection and in the President of URE's explanatory proceedings (Article 23b(1) and (1a), Article 23p(1) of the Energy Law). We prepare objections to the inspection report and information on the implementation of recommendations (Article 23l(2) and (10) of the Energy Law).
  • We handle the financial penalty case before the President of URE (Article 56(2) of the Energy Law). We draft the appeal and represent the company before the Regional Court in Warsaw, Court of Competition and Consumer Protection (SOKiK) (Article 30(2) and (3) of the Energy Law).

What the price does not include

  • Defence in criminal proceedings.
  • Procedures for detecting and reporting suspicious transactions for intermediaries arranging transactions as a business.
  • Building an IT system for reporting, and the fees of RRM operators and inside information platforms.

What you receive

  • A written assessment of obligations and a schedule of steps.
  • A registration or update form and confirmations of its submission.
  • An inside information publication procedure, internal rules to prevent abuse, a division of responsibilities and training materials.
  • Comments on the reporting agreement and rules for transferring and correcting data.
  • In a disputed case: pleadings, objections to the inspection report or an appeal, according to the commissioned stage.

Who this service is for

We help companies starting to trade, putting their procedures in order or responding to a letter from the President of URE.

Please prepare

  • The company’s details, a description of the group structure and the details of the people responsible for trading.
  • Agreements, a description of the products and markets, and the planned start date of transactions.
  • CEREMP registration details, procedures, the agreement with the reporting entity and confirmations of reports.
  • URE correspondence, an inspection report or a decision, together with proof of delivery.

Objections to the inspection report may be made in writing before it is signed, within 7 days of its presentation for signature (Article 23l(2) of the Energy Law). The time limit for an appeal to the SOKiK is 14 days from delivery of the decision (Article 30(2) of the Energy Law).

Information on the implementation of recommendations is provided without delay, at the latest on the day after the deadline for removing the irregularities (Article 23l(10) of the Energy Law). Explanatory proceedings may not last longer than 6 months (Article 23p(1) of the Energy Law).

When this service is not enough

Criminal proceedings or the implementation of an IT system require a separate scope of assistance.

What the fee depends on

  • The number of companies, products and markets.
  • The state of the documentation and of the procedures to date.
  • The scope of training and of the review of reporting agreements.
  • The stage of the inspection or proceedings, and the deadlines for steps.

The final quotation depends on the client’s factual and legal situation; we present it once we know that situation, before work begins.

To discuss the matter with a lawyer first, you can book a consultation for PLN 600 net + VAT. If you then order the work, its cost is credited against the fee for this project.

The price is indicative and does not constitute an offer within the meaning of the Polish Civil Code.

Questions and answers

When must a company register in CEREMP?

Before the first transaction requiring a report to ACER, the market participant submits a registration form (Article 9(4) REMIT). Entering into transactions without the required entry is subject to a financial penalty (Article 56(1)(42) of the Energy Law).

When must inside information be published?

The market participant publishes the information covered by the obligation effectively and in a timely manner (Article 4(1) REMIT). The obligation covers inside information held about the business or installations owned, controlled or under the operational responsibility of the participant, its parent or a related undertaking (Article 4(1) REMIT).

Does registration in CEREMP replace transaction reporting?

No. Reporting through an RRM is a separate obligation; the overall responsibility lies with the market participant (Article 8(1) REMIT, as amended by Regulation (EU) 2024/1106).

  • REMIT: Regulation (EU) No 1227/2011 of the European Parliament and of the Council of 25 October 2011 on wholesale energy market integrity and transparency (OJ L 326, 8.12.2011, p. 1), as amended by Regulations (EU) 2024/1106 and 2024/1789. Provisions: Article 2(7), Article 3(1), Article 4(1) and (2), Article 5, Article 8(1) and (4)(b). Also Article 9(1), (4) and (5).
  • Act of 10 April 1997, the Energy Law (Prawo energetyczne), consolidated text: Journal of Laws of 2026, items 43, 516, 607, 900, 1347 and 1348. Provisions: Article 23a(2), Article 23b(1) and (1a), Article 23l(2) and (10), Article 23p(1). Also Article 30(2) and (3), and Article 56(1)(42) and 56(2).

What we have done in this area

In 2024 and 2025, an independent electricity trading company was entering the exchange market. HWW prepared applications for admission to operate on the commodity market and on the OTF platform, and the internal rules required of an exchange member. It also prepared an application to use the mechanism for reporting transactions to ACER. During the work, HWW pointed out that the company’s data in the CEREMP register needed updating. HWW later prepared the company for an inspection carried out by the exchange.

In 2024, an electricity trading company applied for a general distribution agreement. HWW handled the correspondence with the operator and provided the company’s ACER code. It also explained a discrepancy in the company’s data in the European register of market participants.

How to instruct us

  1. Please describe the matter in the form or call +48 22 100 42 24. Please give the nearest deadline and the documents available.
  2. We will reply by 17:00 on the next working day.
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How to start

You can order this service directly or book a consultation first. A consultation is not required to order the service.

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