Be BATE ready.

What you need to know about BATE

BATE applies to organisations active in Swiss wholesale energy markets, including firms based outside Switzerland. It introduces new requirements for registration, eligibility assessment, exposure reporting and regulatory reporting. Whether you're already managing REMIT obligations or preparing for wholesale energy market regulation for the first time, understanding your responsibilities early will help you prepare effectively.

BATE is designed to increase transparency and integrity in wholesale energy markets. Organisations subject to the regulation may need to register with ElCom, assess their reporting obligations, appoint a Swiss representative, and prepare for exposure and transaction reporting requirements.

To make life easy, here's a brief summary of the key takeaways you need to know.

Understanding your obligations

1. Are you in scope? BATE applies if you trade or place orders in Swiss wholesale power or gas products, wherever you're based. It also applies if you're a Swiss firm trading EU wholesale energy products.
2. Register with ElCom Register with ElCom before you trade. If you're already registered under REMIT, you can reuse the information and ACER code you've already provided.
3. Appoint a Swiss representative If you're based outside Switzerland, you'll generally need a Swiss representative appointed under a written mandate. Equias partners with BATEREP to support customers with this requirement.
4. Report your trades, orders and fundamental data Report trades and orders in Swiss wholesale energy products to ElCom through an approved reporting mechanism. Equias is preparing to support BATE reporting through eRR, helping customers manage Swiss and European reporting obligations through a consistent reporting workflow.
5. Prepare for exposure reporting BATE introduces exposure reporting requirements similar to those being introduced under REMIT2. Organisations should assess whether they are in scope and prepare the data and processes needed to support reporting.
6. Meet market transparency and conduct requirements BATE introduces obligations relating to inside information, market abuse, algorithmic trading and direct electronic access. Organisations should review their controls, policies and governance arrangements to ensure they are prepared for the new regime.