Ready for BATE on 1 January 2027?
ElCom reporting and Swiss representation through one partner
From 1 January 2027, Switzerland’s new wholesale energy market regulations will introduce registration and reporting obligations for affected market participants.
Whether you’re already reporting under EU REMIT or preparing for regulatory reporting for the first time, Fidectus can help you manage your reporting to ElCom and, where required, provide Swiss representation.
Regulatory reporting and Swiss representation, through one partner.
BATE brings REMIT-style oversight to Swiss power and gas
Switzerland is introducing a new regulatory framework for wholesale energy market transparency, closely aligned with the EU’s REMIT regulation.
The framework comprises:
BATE
The Federal Act on the Supervision and Transparency of Wholesale Energy Markets.
VATE
The implementing ordinance setting out the detailed requirements and transitional arrangements.
Both enter into force on 1 January 2027.
The new framework covers Swiss wholesale electricity and gas products, including relevant derivatives, and introduces requirements relating to registration, transaction and order reporting, inside information, market conduct and risk-position reporting.
It extends regulatory oversight to gas and to Swiss wholesale energy products not already covered by existing reporting arrangements.
The exact obligations depend on the type of market participant, product, and trading setup.
See where your business fits
BATE affects different businesses in different ways. Understanding which requirements apply to your trading activities is the first step towards preparing.
Already report under REMIT? Build on what you have
If you trade wholesale energy products in both Switzerland and the EU, you may have reporting obligations to both ElCom and ACER. Your existing REMIT processes and trade data can provide a starting point for meeting the additional Swiss requirements, without necessarily building a separate reporting infrastructure.
New to reporting? Start simply
Swiss traders, utilities, municipal energy companies, gas businesses and companies trading exclusively in Switzerland may now face reporting obligations for the first time. For these companies, preparation starts with identifying reportable trading activity, understanding what data is available, and establishing a reliable reporting process.
Trading from abroad? Cover the Swiss representative requirement
Companies based outside Switzerland that participate in the Swiss wholesale energy market must appoint a representative in Switzerland under Article 6 BATE. This requirement sits alongside any applicable registration and reporting obligations. Fidectus can act as your representative.
Not sure which requirements apply to you?
Book a free 30-minute BATE scoping callPlan around the 2027 deadlines
BATE and VATE take effect on 1 January 2027, but the reporting and registration requirements are introduced in phases.
The following milestones are important when planning your preparations.
| Date | What you need to know |
|---|---|
| 1 January 2027 | BATE and VATE enter into force. |
| 28 February 2027 | Existing Swiss-market participants must submit their registration application by this date if they want to continue trading while ElCom processes it. |
| 31 March 2027 | End of the transition period for certain EU wholesale energy reporting information newly subject to submission to ElCom. |
| 31 May 2027 | End of the transition period for organised markets reporting standard contracts traded on their markets. |
| 1 June 2027 | Deadline for submitting information about the appointed Swiss representative to ElCom, where required. |
| 31 October 2027 | First risk-position report due for participants subject to that obligation, covering Q3 2027. Also, the end of the relevant off-OMP reporting transition for participants already reporting to ACER. |
| 31 December 2027 | End of the general transition period for reporting off-OMP standard and non-standard contracts, subject to specific exceptions. |
Not every deadline applies to every participant. Different transitional provisions apply depending on the reporting obligation, with later reporting start dates for certain product categories.
Read our BATE guide
Three steps to get BATE-ready
For many businesses, the immediate priority is understanding three practical requirements.
01
Register with ElCom
Determine whether your trading activity falls within the scope of BATE and whether you need to register with ElCom.
Participants subject to registration must generally complete the process before trading, taking account of the transitional arrangements for existing market participants.
02
Establish your reporting arrangements
Identify which transactions and orders need to be reported, where the data comes from, and who is responsible for submission.
03
Appoint a Swiss representative, if required
If your business is based outside Switzerland, you must appoint a representative under a formal mandate and provide the required information to ElCom.
Other obligations under BATE, including those concerning inside information and market conduct, may also need to be addressed separately.
Reporting responsibilities depend on how the transaction is concluded:
Standard contracts traded on an organised market (OMP)
The organised market generally handles reporting.
Standard contracts traded off-OMP and non-standard contracts
Reporting sits with the market participant, although transmission can be delegated to a third party.
This distinction is particularly important for companies trading bilaterally or through platforms that are not classified as organised markets.
Reporting and representation from one partner
Meeting new regulatory requirements shouldn’t mean introducing unnecessary manual processes or building reporting infrastructure from scratch.
Fidectus specialises in digital post-trade operations for energy markets. We support two important areas of BATE implementation: regulatory reporting and Swiss representation.
Report with confidence. Control by exception.
Regulatory reporting doesn’t end when data is submitted.
Reports can be rejected, information may need correcting, and regulators may request evidence of what was reported. Without clear visibility into the full process, even routine reporting can create unnecessary manual work.
Fidectus helps you manage the entire reporting lifecycle, from capturing trade data through to resolving exceptions.
01
Capture
Collect trade data from your ETRM, ERP or other source systems, with guidance on connecting your existing infrastructure.
02
Validate
Apply data-quality and reporting checks to identify missing or inconsistent information before submission.
03
Submit
Submit the relevant reports to ACER and ElCom or, for EMIR reporting, to the trade repository REGIS-TR.
04
Verify
Track reporting receipts and submission status, so you know what has been received, accepted, or rejected.
05
Resolve
Identify exceptions requiring attention, correct errors, and resubmit rejected reports until accepted.
What does this mean for your business?
Why not just let your counterparty report for you?
For smaller market participants, delegating reporting to a counterparty may seem like the simplest approach. And in many cases, the transmission of reporting information can be delegated.
However, delegating transmission doesn’t remove your responsibility for overseeing your reporting obligations.
If you trade with several counterparties, you may depend on multiple reporting arrangements, with limited visibility into what has been submitted, whether reports were accepted or what needs correcting.
By consolidating your reporting through Fidectus, you can take a more consistent approach: one process across all your counterparties, with a single view of what was submitted, what was accepted and what still needs attention.
Trading on enmacc? Two routes to the same reporting
enmacc enables OTC trading in Swiss markets and for Swiss market participants, while Fidectus provides Swiss representation and regulatory reporting for ACER and ElCom. Together, they seamlessly support your BATE compliance – whether trading in Switzerland or as a Swiss counterpart – alongside cross-border EU–Swiss reporting requirements.
enmacc provides a digital venue for OTC energy trading. However, it has been assessed as a person professionally arranging transactions (PPAT), rather than an organised market (OMP).
This means transactions arranged through enmacc are treated as off-OMP for reporting purposes.
Where BATE reporting obligations apply, the market participant remains responsible for arranging reporting, although transmission can be delegated.
You have two routes to the same reporting infrastructure: contract BATE reporting directly with Fidectus, or arrange it through enmacc, which uses Fidectus as its RRM. Either way, your reports are submitted through Fidectus.
Trading in the EU as well?
Companies based outside the EU that trade EU wholesale energy products may also need to appoint an EU representative under REMIT.
This is separate from the Swiss representation requirement. Fidectus can introduce you to enmacc’s EU REMIT representation service, helping you coordinate your requirements across both markets.
Regulatory reporting is already what we do
Fidectus supports energy market participants with regulatory reporting to ACER and ElCom, combining specialist market knowledge with digital post-trade technology.
Our approach brings together:
Swiss representation
ElCom reporting and Article 6 BATE representation from one Swiss-based provider.
Regulatory reporting expertise
Experience with REMIT, ElCom and EMIR reporting processes.
Connected reporting workflows
Data capture, validation, submission, monitoring and exception management through one platform.
Flexible onboarding
Start with file-based reporting or connect your systems for greater automation.
Recognised credentials
Registered Reporting Mechanism with ACER and ElCom under existing frameworks, and ISO/IEC 27001-certified information security management.
FAQ
I already report under REMIT. Do I also need to report under BATE?
Possibly. If you trade Swiss wholesale electricity or gas products, you may have reporting obligations to ElCom as well as ACER. Your existing REMIT processes and trade data are a good starting point, and Fidectus can manage reporting to both through one workflow.
Can I start without integrating my systems?
Yes. For simpler reporting requirements, you can submit trade data through our web interface or by file upload and introduce automation later.
If my counterparty is reporting for me, am I covered?
Transmission can often be delegated, but you remain responsible for overseeing your reporting obligations. Consolidating your reporting through Fidectus gives you one view of what was submitted and accepted.
Do I need a Swiss representative?
If your business is based outside Switzerland and participates in the Swiss wholesale energy market, you must appoint one under Article 6 BATE and notify ElCom by 1 June 2027. Fidectus can act as your representative.
Be ready before the first deadline
New reporting obligations don’t have to mean new complexity.
Whether you’re extending your existing REMIT reporting, establishing a process for the first time or arranging Swiss representation, Fidectus can help you determine the most practical way forward.
Tell us how and where you trade. We’ll discuss your reporting setup, the services relevant to your business, and how you can prepare for the upcoming deadlines.
Want to understand the regulations in more detail?
Regulatory information is based on BATE and VATE, with VATE approved by the Swiss Federal Council on 2 October 2026, including the transitional provisions in Articles 34–39. The exact requirements and applicable deadlines depend on the type of market participant, product and trading arrangements. This page provides general information and does not constitute legal advice.