AggregateEU is the name of the demand aggregation and joint purchasing service, operated by Prisma, the Service Provider, under the EU Energy Platform in accordance with Council Regulation 2022/2576.
The objective of AggregateEU is to contribute to the security of supply (both in terms of volume and affordability), with a focus on LNG.
AggregateEU has thus been designed AggregateEU has be designed to match buyers and seller, while a) ensuring equal treatment and b) preventing market manipulation.
AggregateEU will organise tendering rounds on a monthly basis. Participating in an AggregateEU tendering round (i.e. per month, per location) will involve four steps:
On the demand side, companies established in the EU or in the Energy Community countries can take part in demand aggregation and joint purchasing of gas, either alone or by concluding an agreement with another buyer that would submit their demand and negotiate for them (“central buyer” type of cooperation – for more details see the section on Consortia).
On the sellers side, both EU and non-EU companies will be able to participate.
Companies shall be precluded from participating as sellers, producers or purchasers, if they fall into one of the categories listed under Art. 8 of Regulation 2022/2576 (targeted by the EU measures adopted in the view of Russia’s invasion on Ukraine).
They will only be able to participate on AggregateEU as sellers, i.e. by submitting supply offers. They will not be able to submit gas demand.
AggregateEU offers a new opportunity to procure gas in addition to existing market places or practices. AggregateEU brings additional value to the market participants with demand aggregation, increased transparency and new forms of cooperation. This could bring particular benefit for, but not limited to, smaller companies or those in landlocked countries, which might benefit from demand aggregation – given the size of their demand or their lack of experience in contracting LNG.
Further, AggregateEU will enable demand aggregation by individual companies or by groups of companies. This will also facilitate the establishment of cooperation models such as central buyers and agents/shippers on behalf (for more details see the section on Consortia).
These are the elements and the added value that distinguish AggregateEU from existing services.
AggregateEU allows for the aggregation of demand for both, pipeline natural gas and LNG.
LNG will be delivered in two areas (North West and South-East), and pipeline natural gas on national markets (26 points).
There is a legal requirement for Member States to submit a certain volume for demand aggregation. Member States are obliged to identify the national companies that will be aggregating their demand. It is up to Member States to define how they will implement this obligation. Depending on Member States, the obligation to participate in the demand aggregation process might be passed on their national gas companies, or the industrial consumers, or some municipalities or administration.
This volume must be equivalent to 15% of their obligation under Regulation (EU) 2017/1938 on gas storages (hereinafter, “the Storage Regulation”).
The obligation to aggregate applies to all Member States with storage obligations, including those without gas storage facilities on their territories. It also applies to those having already contracted filling or filled their storage. Beyond this 15%, demand aggregation will be voluntary.
While the provision refers to storage obligation when defining mandatory submission of demand for aggregation, gas purchased through AggregateEU may be destined for any use, not only storage.
The only mandatory element relates to the mandatory submission of demand (equivalent to 15% of storage obligation), but not to gas purchasing. It is for the companies to negotiate and make a business decision to purchase gas via AggregateEU or not.
The gas purchased through demand aggregation and joint purchasing can be used for different purposes, depending on the needs of the buyer(s): the gas could be used for gas storage filling, or the volumes purchased can go to gas consumption in the EU or in the Energy Community countries.
Companies will have to follow a two-step process to participate in AggregateEU. First, they will need to register with PRISMA, which is already open (see question below on Registration for more details). Second, they will need to subscribe to AggregateEU (see question below on Subscription for more details).
Companies already registered on the PRISMA platform will not have to register again.
Companies that are not already registered on the PRISMA platform will need to provide the information below:
- Company information – i.e. name, registered official address and country of registration
- Energy Identification Code (EIC) – mandatory for companies registered in the EU Energy Community and contracting party member states, with exemptions applicable. (More information on EIC and on the way to obtain one).
In addition, the following documents will have to be provided: power of attorney and commercial registry extract (only for the registration of the first user of a company).
Companies will have to declare their ownership and control structures to be in compliance with Article 8 of the Regulation 2022/2576 and this will be subject to checks.
Companies will need to indicate:
- Whether they are buyer, seller or both (noting that a company cannot have both roles in the same tender)
- The location where they would like to buy and/or sell natural gas (indicative information)
- Financial Securities: interested buyers and sellers will have to indicate which financial security(ies) will be made available to the potential counterparty(ies)
In addition, applicant must submit a declaration of honour, assuring the fulfilment of the requirements introduced by Council Regulation (EU) 2022/2576 – i.e. no affiliation to Russian entities.
There is a volume threshold for companies to be able to submit monthly demand:
- equal or higher than 5GWhat Virtual Trading Point (VTP) - value still under consideration;
- 300 GWh at the European Virtual LNG (Virtual LNG refers to “on-ship” LNG available for delivery (ex-ship) to any of the terminals in the respective areas (i.e. North-west or South-East).
Companies that plan to submit a volume equivalent or above this threshold are invited to register and subscribe to AggregateEU. Companies that are not able to reach this threshold could consider using the services of a Central Buyer (see section below for more details).
Potential buyers and sellers will have to provide information about the financial collaterals available for the procurement of natural gas.
These include options such as: cash collateral, letter of credit, bank guarantee, parent company guarantee, stand-by letter of credit, bonds & debt security, open to use a broker, open to use a clearing house, credit rating (only bbb- or above under S&P and Fitch Rating, baa3 for Moody).
This information will be subsequently provided to the potential counterparty(/ies) in case of positive matching. Buyers and sellers will exchange documents providing proof of these guarantees outside the platform during the contracting phase.
Companies that are not in possession of any financial collaterals are strongly encouraged to obtain such instruments.
There will be information on the website regarding international financial institutions/banks available to support buyers.
It is the responsibility of each participant in AggregateEU to secure financial collaterals (e.g. stand-by letter of credit, parent company guarantee, credit rating).
Companies that are not in possession of any financial collaterals are strongly encouraged to obtain such instruments. The Commission also encourages companies to provide feedback should they encounter difficulties in obtaining these products.
Since the service of demand aggregation and joint tendering is preliminary established for a duration of one year, entities will be able to register at any point in time before the last cut-off date in 2023 (fourth quarter).
Yes, but entities that register both as buyer and supplier will only have one role per tender – i.e. they will not be able to participate as both, buyer and supplier, in the same tender.
The registration and subscription to AggregateEU will be done at the level of the legal entity (i.e. different legal entities can each register separately).
In case subsidiaries within an industrial holding have different/separate legal entities, they can register separately on AggregateEU and will have to decide which role (either buyer or seller) they want to take within the same tender. But should subsidiaries belong to the same legal entity, then the limitation to participate as both, buyer and supplier, in the same tender will apply.
PRISMA will publish the aggregated demand and organise tenders to attract supply offers. The most competitive offers will then be matched with demand.
The various tasks of PRISMA are described in the figure below.
No, there will be no fee associated with the Service Provider.
The plan is to have a series of tenders on a rolling basis.
The tenders will be organised by month, product and location (for LNG or National Balancing Points). The timeline of each tendering round is described in the chart below (where days correspond to calendar days from Monday to Friday).
Yes: a monthly flat wholesale product. Either Virtual LNG, with two delivery areas (North West Europe and South East Europe) or Virtual Trading Points / National Balancing Points.
The unit used will be energy unit (GWh) and the period will be monthly, on a rolling basis.
For each location and for each period a potential buyer can submit up to one demand for himself as well as one for the group of companies for which it is acting a central buyer.
The potential buyer can change/withdraw its demand while this phase is still open.
When submitting demand, the buyers would need to specify, at least, parameters such as:
- Gas quantity expressed as energy i.e. GWh,
- Delivery period,
- Delivery point.
The submitted value of demand must be equal or higher than 5 GWhat VTP (value still under consideration) and 300 GWh at the European Virtual LNG.
The potential buyer can submit demand for a maximum period of 12 months – starting two months after the submission of demand has taken place. As an illustration: if the submission of demand takes place on June 2023, the monthly demand to be submitted on AggregateEU can potentially span from August 2023 to October 2024.
There are 5 governing principles, underpinning the matching algorithm:
- Every tender is independent
- The matching is non-discriminatory towards potential buyers – i.e. every potential buyer shall be treated equally and have the same quality of matching (i.e. equal access to best prices)
- The algorithm shall minimise the costs of the potential buyers bidding in one tender
- The sellers’ offers will be ranked from the lowest to the highest price
- In case of over-demand or over-supply, the pro-rata mechanism will be applied
A potential seller will have to indicate for each bid:
- the quantity the seller is willing to sell
- the price at which the seller would like to sell the gas
A potential seller will be able to edit its bid until the bidding window is closed. A potential seller can submit more than one bid in the same tender process.
Once the demand is aggregated, the Service Provider will draft an information sheet based on the information received from the buyers. This information sheet will represent a set of common simple requirements that will have to be met by the suppliers. Any additional requirements will be part of the contractual negotiations outside AggregateEU, once the demand is matched.
Yes. This will result in a pro-rata allocation.
AggregateEU will provide the following information to potential buyers for each tender:
- General information to contact the seller
- Quantities allocated to the seller(s)
For Virtual LNG, information regarding the identity of other companies that submitted demand will also be shared, as well as preferences in terms of destination terminal. This will allow possible cooperation and coordination logistics-wise.
AggregateEU will provide the following information to potential seller(s) for each tender:
- General information to contact the buyer(s),
- Quantity allocated to the buyer(s),
- Financial securities provided by the buyer(s).
No, the matching is not binding. After the matching, the companies will start negotiating outside AggregateEU.
Depending on the tender, it will either be national/virtual trading/balancing points or an LNG terminal (either FOB or at the terminal flange).
Potential buyers will be fully responsible for transportation and, in case needed, regasification and storage of the procured gas quantities.
Buyers are responsible for the transport of the gas at the point where they take title of it. They can arrange this by themselves or through the procurement of services from a third-party that would be responsible for the shipping, balancing, and other ancillary services related to the purchase of gas.
A list of the potential Agent/Shipper on Behalf will be available on AggregateEU.
A request for Expression of Interest has been published on the PRISMA webpage for these services.
The buyer and the seller will negotiate contracts. Negotiations are outside AggregateEU and the remit of the Service Provider. The Service Provider is only a demand aggregation, tendering and matching solution.
The focus of AggregateEU is to support the filling of storages in 2023 and the supply of gas during the winter 2023/2024. Demand aggregation and joint purchasing can be used for procurement of gas for any purposes, be it for storage filling or supplies to customers. Contracts will have a maximum duration of 12 months.
AggregateEU will not interfere with existing contracts and obligations, which are outside of the scope of its mandate.
No. The negotiations and conclusions of contracts is outside the scope of AggregateEU and the remit of the Service Provider. As for all contracts, it is for the relevant market participants to provide the relevant information to ACER under REMIT. This will not be the Service Provider’s responsibility.
Yes. Given the negotiations of contracts will happen outside AggregateEU, buyers will therefore be obliged to notify the potential conclusion of contract, if the volume is superior to 5 TWh per year (for more information see section on Transparency).
Yes. The notification obligation applies to all contracts – whether the gas is purchased through or outside AggregateEU – if the volume is superior to 5 TWh per year.
Article 3 of Council Regulation (EU) 2022/2576 lays out transparency provisions in order to ensure better coordination and energy solidarity among Member States.
The Regulation places an obligation on natural gas undertakings, undertaking consuming gas established in the Union, or authorities of Member States, to inform the Commission of their intention to launch a tender to purchase gas or open negotiations with suppliers or producers from third countries for the purchase of gas. The volume foreseen in the planned agreement must be above 5TWh/year to be reported.
Information shall be shared with the Commission at least six weeks before the conclusion of such binding agreements (or no later than two weeks before the intended conclusion or launch if the negotiations are opened closer to the date of signing the contract). The Commission will ensure adequate handling of the notified information.
Based on this information, the Commission may issue recommendations if it considers that:
- further coordination with regards to the launch of a tender or planned gas purchases is needed to improve the functioning of the joint purchasing, or
- the launch of a tender or planned gas purchases may have a negative impact on the internal market, on security of supply or on energy solidarity
Before issuing any such recommendation, the Commission will inform the ad hoc Steering Board (as per Articles 3 and 4 of the Council Regulation 2022/2576).
Companies and authorities in the Member States are invited to contact the dedicated functional mailbox ENER-PLATFORM-TRANSPARENCY@ec.europa.eu in order to get further details on how to implement this reporting obligation.
Art. 3 of Regulation 2022/2576 is applicable to:
- EU undertakings intending to launch a gas tender both with third countries as well as intra-EU;
- EU undertakings soon to conclude negotiations of gas purchase with suppliers based outside of the EU.
The trigger for the notification should be the intention to conclude a contract or launch a tender. The undertaking should notify the Commission at least six weeks before the conclusion of the contract or the launch of tender. The intention should be understood objectively i.e. the negotiations or other conditions for concluding the contract are already in place and the likelihood of concluding the contract is high.
If the negotiations are moving fast, the undertaking may notify within a shorter deadline, i.e. up to two weeks before the envisaged signature of the contract.
The obligation to notify is valid even in the case that the deadline is missed.
Yes, as stated in Article 3 and the Definitions of Article 2 in Regulation 2022/2576, LNG is also covered by Article 3.
Yes. Recital 14 of Regulation 2022/2576 specifically mentions ‘new or renewed contracts’.
The Regulation also applies to amendments to the contracts, if these amendments relate to the elements of the contract that have to be reported.
Yes. FOB contracts are also subject to the notification obligation. Art 3 specifies that it covers negotiations between an EU-established undertakings and an undertaking established in a third country. The provision does not take into account other terms of sale.
The Commission will assess this on a case-by-case basis. As the transparency obligation is about coordination, it depends on how many transactions are foreseen at a given moment in time. But confidentiality will be safeguarded at all times.
The Steering Board is a forum for enhanced coordination at Union level, with the aim of facilitating the coordination of demand aggregation and joint gas purchasing, including from third countries.
The Steering Board will assist the Commission on draft recommendation(s) in assessing the impact of planned gas tenders/contracts on:
- the functioning of joint purchasing;
- the internal market, on security of supply or on energy solidarity;
The first phase of implementing the EU energy Platform will serve as a learning process for the potential implementation of joint purchasing for renewable hydrogen in the future. This is in line with the Commission communication of 18 May 2022 entitled ‘REPowerEU plan’, setting up an EU Energy Platform together with the Member States for the common purchase of gas, liquified natural gas (LNG) and hydrogen.
No. Regulation 2022/2576 refers to the possibility for EU companies to form consortia to be able to sign contracts with suppliers that will respond to the tenders organised by the Service Provider. In this sense the consortia are not mandatory but may facilitate the signature of contracts that follow from demand aggregation.
Cooperating with other buyers may be a solution for buyers that:
- would like submit demand that is lower than the minimum volume foreseen for a given tender,
- do not have expertise in negotiating gas purchase contracts,
- do not have necessary transmission, LNG or storage capacities (e.g. buyers located in landlocked countries).
There is no minimum quantity, but exact terms and conditions may be defined by the consortium leader.
It is for companies to decide to go ahead with the purchase of gas collectively. They can voluntarily agree to enter company cooperation or to set-up a consortium and coordinate conditions of purchase such as volumes, price or delivery points and time, always within the limits of the EU competition rules.
Establishing consortia is an option foreseen in Regulation 2022/2576 for gas buyers to pursue according to their best knowledge of the market. Following discussions with gas companies and with industrial customers, the Commission has envisaged two types of cooperation between buyers aimed at high efficiency when jointly purchasing gas. These two types of cooperation are referred to as “central buyer” and “agent/shipper on behalf”. See the details below.
Some downstream gas companies or industrial consumers (such as ceramics, fertilisers, and aluminium industries) may not have sufficient demand, expertise or credit worthiness to buy enough gas on their own. In this case, they could ask other entities (likely larger gas companies) to act on their behalf as a Central Buyer, which would purchase gas for them. Each gas company and industrial consumer would sign a contract with a Central Buyer.
In terms of timing of the formation of contractual relations between a central buyer its group of buyers, there are two alternatives:
- bringing a group of buyers to the AggregateEU platform: The central buyer can register and place the aggregated demand on the AggregateEU platform on behalf of the buyers. In this case, individual buyers do not have to register on the AggregateEU platform.
- on the AggregateEU platform: companies interested in providing services to other buyers as central buyers will be listed on the AggregateEU platform following a call for expression of interest organised by Prisma. Buyers registering on the AggregateEU platform, interested in these services, would need to contact one of the central buyers and enter into a contractual relationship with it, preferably before placing demand on the platform.
As a next step, after the tender has taken place, the Central Buyer would enter into negotiations and sign gas sale and purchase agreements (GSPAs) with upstream gas suppliers in order to match the volume, profile and timing of the aggregated gas demand of its customers.
Companies participating in this model would join the platform - where their demand would be aggregated - and they would participate in tenders using the AggregateEU platform.
They would negotiate and sign individual contracts with suppliers following matching on the AggregateEU platform. Under this model, companies would entrust another company, likely a mid-streamer, to act as an agent providing services which could include for example reservation of a slot on an LNG terminal, transport from a ship to the point of consumption, or balancing services. Companies may contract an agent/shipper on behalf either outside/before or after the tender, with or without the involvement of the AggregateEU platform. Companies interested in providing services to other buyers as agents/shippers on behalf will be listed on the AggregateEU platform.
No, but the call in March represents a good opportunity for companies wishing to offer their services to be advertised.
Company cooperation frameworks for the joint purchase of gas must be compliant with the EU competition rules. According to the EU competition law regime, companies cooperating for the joint purchase of gas shall self-assess the compliance of the consortia with competition rules. The Commission has issued extensive guidance to assist companies in this process, such as the Guidelines for the assessment of horizontal cooperation agreements (currently under review) and the Guidelines on Vertical Restraints.
In the context of the implementation of the emergency regulation, the Commission stands ready to assist companies willing to jointly purchase gas to ensure compliance with competition rules of their joint purchasing arrangements. Namely, the Commission stands ready to assist interested companies and their legal counsels through informal guidance, including a guidance letter under the Commission Notice on informal guidance relating to novel or unresolved questions concerning Articles 101 and 102 of the Treaty on the Functioning of the European Union that arise in individual cases (“Notice on Informal Guidance”) based on a reasoned request pursuant to paragraphs 10 to 12 of the Notice on Informal Guidance.
Competition rules will apply to information exchanges taking place in the framework of joint purchasing of gas.
Commercially sensitive information should only be exchanged bilaterally between the agent/shipper on behalf or the central buyer, on the one hand, and their respective individual customers, on the other hand. These bilateral exchanges should be limited to what is necessary for the purposes of negotiating and implementing the respective gas purchase agreements.
Commercially sensitive information exchanged in this context can be considered necessary if the companies concerned can explain how it relates to the agreement they are negotiating, why it needs to be exchanged and why it would be proportionate to the objective of the agreement. Moreover, if the agent/shipper on behalf or the central buyer are operating in the same market as one of their customers, they need to make sure that access to commercially sensitive information obtained from their customers for the purposes of carrying out their purchasing function is limited to staff dedicated to this function, and that such information is not shared with other staff within the company (see: and the Guidelines on Vertical Restraints para. 103).
The Commission stands ready to assist interested companies and their legal counsels through informal guidance.
In case of a Central Buyer, the negotiations and the signing of the contract will occur between the Central Buyer and the gas suppliers. In case of an Agent-on-behalf, the signing of the contract will occur between every single individual buyer and the gas suppliers. The liability regime will therefore depend on the model pursued and the parties entering into the contract.
In case of Central Buyer, there will be two different liabilities: the one stemming from the contractual relationship between the Central Buyer and buyers (if there is more than one buyer, liability can be joint and several, although this will depend on negotiations); and the one arising from the contracts signed between the Central Buyer and the gas supplier.
In the case of Agent on Behalf, there will be a contractual relation between the Agent on Behalf and the buyer purchasing its services; and another one between the buyers and the gas suppliers.
All additional queries regarding the joint purchasing of gas and the EU Energy Platform should be sent to EU-ENERGY-PLATFORM@ec.europa.eu