The REMIT II ‘’deadline paradox’’: why some OTC traders now have a clearer T+10 deadline

Did you know that some bilateral OTC trades now have a clearer T+10 reporting deadline under REMIT II?

Much of the conversation around REMIT II has focused on tighter reporting timelines, and understandably so. The recast REMIT Implementing Regulation introduces significant changes to transaction reporting, including revised deadlines for standard and non-standard contracts.

However, the impact is more nuanced than a simple acceleration of every reporting obligation.

For some bilateral OTC transactions, the revised framework may provide more time than the T+1 reporting process firms previously applied. This should not be interpreted as a reason to delay reporting. Market participants should continue to submit complete and accurate reports as promptly as possible.

Nevertheless, understanding the formal deadline matters. It affects how firms classify transactions, design controls, manage exceptions and organise their reporting workflows.

REMIT II is therefore not simply a regulatory update. It is also an operational one.

What has changed?

Under the recast REMIT Implementing Regulation, reporting deadlines differ depending on whether a contract is classified as standard or non-standard.

The new reporting timeframes have applied since 29 April 2026. Standard contracts must be reported within two working days, while non-standard contracts must be reported within ten working days.

Where the conclusion of the trade, the placement of the order or the occurrence of a lifecycle event took place before 29 April 2026, the previous reporting timeframes continue to apply.

At first glance, the change appears straightforward: standard contracts receive a small extension, while the reporting window for non-standard contracts is shortened considerably.

The more important change, however, concerns how these categories are understood.

Under the revised framework:

- A standard contract is a contract concerning a wholesale energy product admitted to trading at an organised marketplace.
- A non-standard contract is a contract concerning a wholesale energy product that is not admitted to trading at an organised marketplace.

ACER has clarified that, in practice, transactions taking place on an organised marketplace should follow the standard-contract timeframe, while transactions occurring outside an organised marketplace should follow the non-standard-contract timeframe.

This means that the reporting deadline depends not simply on whether standardised contractual documentation is used, but on where and how the transaction is executed.

ACER has also confirmed that lifecycle events follow the same timeframes. Lifecycle events relating to standard contracts should be reported within T+2, while lifecycle events relating to non-standard contracts should be reported within T+10.

If you're catching up on the wider REMIT II reporting changes, our previous blog 'REMIT II Becomes Operational on April 29'', is a good place to start. Access it here.

Understanding the “deadline paradox”

This creates what could be described as a deadline paradox within REMIT II.

The overall direction of the regulation is towards more detailed, consistent and traceable reporting. Yet some bilateral OTC transactions may now have a longer formal reporting window than the T+1 process previously applied to them.

Under the previous Implementing Regulation, a standard contract was defined as one concerning a wholesale energy product admitted to trading at an organised marketplace, "irrespective of whether or not the transaction actually takes place on that market place." A trade concluded bilaterally in a product admitted to trading at an organised marketplace was therefore a standard contract, and the T+1 deadline applied to it as a matter of law. The recast Regulation removes that qualifying phrase. Classification now follows where the transaction is executed, which is why the same trade now carries a T+10 deadline.

Under the revised framework, a transaction may use familiar or standardised contractual terms, such as those found in an EFET agreement. However, the use of standardised documentation does not automatically make the transaction a standard contract for REMIT reporting purposes.

Where the transaction is concluded bilaterally outside an organised marketplace, it falls within the non-standard category and therefore carries a T+10 working-day deadline.

That does not mean firms should wait until T+10 to report.

The deadline should be understood as the final permissible reporting point - not necessarily the target operating timeline. Where transaction data is complete, accurate and validated, firms should continue to report promptly.

However, the revised timeframe may provide more scope to resolve genuine data-quality issues, investigate exceptions and complete necessary controls before submission.

The more substantial tightening applies to transactions that were already classified as non-standard under the previous framework. For these contracts, the formal deadline moves from one month to ten working days.

The operational impact will therefore depend on the transaction, its execution venue and how it was previously classified and processed.

Why this matters operationally

For compliance and operations teams, the distinction between T+2 and T+10 is not merely administrative. It affects how reporting workflows, controls and escalation procedures should be structured.

A clearly defined T+10 deadline may provide additional time, where needed, for:

- Trade-capture validation

- Data enrichment

- Exception investigation

- Reconciliation

- Lifecycle-event processing

- Internal quality controls.

Under compressed reporting windows, teams may face pressure to submit transactions before discrepancies have been fully investigated.

The T+10 deadline can give firms more room to address legitimate issues before submission, potentially reducing incomplete reports, rejections and subsequent corrections.

However, the additional time should support reporting quality, not become a reason to postpone transactions that are already ready for submission.

This distinction is particularly important because REMIT II also introduces broader reporting requirements, revised data fields and greater lifecycle-event traceability through its phased implementation.

A clearer deadline does not mean less scrutiny or lower expectations.

The importance of correct classification

The use of standardised documentation does not, by itself, determine whether a transaction is standard under the revised reporting framework.

The key consideration is whether the transaction takes place on or outside an organised marketplace.

ACER has explained that even where a bilateral transaction is based on a contract admitted to trading on an organised marketplace, the bilaterally agreed transaction may contain elements of customisation that distinguish it from the contract traded on the marketplace.

Market participants should therefore reassess:

- How transactions are classified internally
- Whether execution-venue information is captured accurately
- Which events trigger reporting obligations
- Which deadline is assigned to each transaction
- Whether existing classification assumptions remain valid
- How reporting timelines interact with validation and approval processes.

Classification logic should be consistent, documented and embedded within the reporting workflow.

Operations and compliance teams should also understand the distinction between the contractual documentation used for a transaction and its regulatory classification.

Applying the wrong classification could result in the incorrect reporting deadline being assigned, creating avoidable compliance and operational risk.

Assessing the operational impact

The move to differentiated T+2 and T+10 working-day deadlines may require firms to reconsider how their reporting processes are structured.

Market participants should already be reviewing:

- Contract-classification logic
- Reporting-trigger mechanisms
- Exception-handling processes
- Lifecycle-event reporting readiness
- Data-validation and reconciliation workflows
- Escalation procedures as deadlines approach.

An effective operating model may continue to target reporting well ahead of the formal deadline while using the available regulatory window to manage legitimate exceptions and data-quality issues.

This allows firms to maintain timely reporting without sacrificing accuracy, consistency or control.

Looking beyond the headlines

REMIT II is frequently presented as a story of tighter deadlines and increased compliance pressure. In practice, its impact is more varied.

Some reporting windows are becoming shorter. Others are being clarified or adjusted. Certain transactions may need to be classified differently based on where they take place rather than the documentation used.

The potential movement from T+1 to T+10 for some bilateral OTC trades demonstrates why operational interpretation matters alongside regulatory interpretation.

The message is not that firms now have permission to report later.

It is that they need to understand which deadline applies, continue reporting promptly and use the revised framework to build more accurate, controlled and resilient reporting processes.

Preparing operationally for REMIT II

REMIT II implementation is not only a regulatory exercise. It is an operational one.

As definitions, reporting formats and requirements evolve through the phased implementation, firms that review their workflows early will be better positioned to improve data quality, reduce reporting risk and adapt efficiently.

Whether reviewing contract classifications, preparing for revised reporting schemas or optimising workflows under the T+2 and T+10 timelines, market participants should already be assessing the practical impact of the recast REMIT Implementing Regulation.

Fidectus helps energy market participants simplify REMIT reporting processes and prepare for the next phase of implementation through scalable, controlled and operationally resilient workflows.

Speak with our team to assess how the revised REMIT reporting framework could affect your operations.