Estonia

PMEG Gas

Page Search

1. Submission of an Economic Activity Notice (EAN) is mandatory to carry out the activities of a natural gas seller in Estonia, i.e.: (1) to supply natural gas to end-customers, including household and non-household customers, and/or
(2) to trade in natural gas – i.e., to buy for sale and sell natural gas – on a wholesale market within the territory of Estonia. EAN shall be submitted to the Competition Authority (NRA) under the procedural terms and conditions stipulated in the General Part of the Economic Activities Code Act (MsüS). Submitted EANs are registered at the Register of Economic Activities (MTR). No local incorporation and/or establishment – whether for undertakings from EU Member States / EEA countries or third countries – is required to be eligible for the EAN submission and/or registration at the Register of Economic Activities (MTR). However, if a foreign company wants to offer goods or services in Estonia in its own name continuously, it is required to register a branch in the Commercial Register (RIK).

2. Activity license for gas imports (GIL) is mandatory to carry out the activity of importing natural gas to Estonia, which is defined as the application of the customs procedure for release for free circulation of natural gas in the territory of Estonia within the meaning of Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code, i.e., imports of natural gas from third countries (non-EU Member States / EEA country) for sale in the Estonian market. GILs are issued by the NRA under the procedural terms and conditions stipulated in the Natural Gas Act (MGA) and the General Part of the Economic Activities Code Act (MsüS).

3. Gas exchange registration (GER) is required to pursue gas trading on the Baltic-Finnish regional gas exchange (GEX). GERs are carried out by UAB GET Baltic – a company established in Lithuania, which is the operator of the only gas exchange currently operational in the Baltic States and Finland. GER does not exempt a natural gas undertaking from mandatory requirements concerning the EAN submission (for gas sale activities) and/or obtaining the GIL (for gas import activities). No local incorporation and/or establishment is required to qualify for the GER.

Natural gas supply of last resort in Estonia is provided by a seller of natural gas with the largest market share in the particular network area (defined by the service area of the activity license for natural gas distribution). Natural gas supply of last resort is defined by law as the sale of natural gas in accordance with the technical capabilities of the network to all household customers who have a network connection in that network area and wish to receive the service of the natural gas supply of last resort (i.e., do not choose a natural gas supplier). Natural gas supply of last resort is not a subject matter of this Guide.

Reporting obligations for wholesale traders are highlighted in orange.

Information to be provided for registration/licensing purposes

Registration and authorisation for gas trading activities in the natural gas market

(Standard) Information category / document to be submitted Registration and authorisation for gas trading activities in the natural gas market
Legal basis Article 267 of the Natural Gas Act (MGA) Articles 14 and 15 of the General Part of the Economic Activities Code Act (MsüS) Articles 27-29 and 32 of the Natural Gas Act (MGA) Articles 16-28 of the General Part of the Economic Activities Code Act (MsüS) GEX Trading Regulation
of GET Baltic
Legal reference and convenience translation Natural Gas Act (MGA) General Part of the Economic Activities Code Act (MsüS) Natural Gas Act (MGA) General Part of the Economic Activities Code Act (MsüS) GEX Trading Regulation of GET Baltic
Recipient (NRA, TSO, power exchange etc.) NRA NRA GET Baltic
Submission deadline Anytime before commencing natural gas sale activities Anytime before commencing natural gas import activities Anytime before commencing gas trading on the GEX
Frequency One-time submission One-time submission One-time submission
Form of submission (internet page, e-mail, original copy etc.) EAN can be submitted by:
1. entering the Register of Economic Activities (MTR) at https://mtr.mkm.ee/; or
2. sending the digitally signed application to the NRA at mtr@konkurentsiamet.ee; or
3. sending the application via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
EAN can be submitted by:
1. entering the Register of Economic Activities (MTR) at https://mtr.mkm.ee/; or
2. sending the digitally signed application to the NRA at mtr@konkurentsiamet.ee; or
3. sending the application via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
Request to Grant the Status of the GEX Participant
Applicable for Natural gas seller
(retail supplier / wholesale trader)
Natural gas importer GEX participant
Comments EAN submission and subsequent registration at the Register of Economic Activities (MTR) are mandatory for carrying the activities of a natural gas seller in Estonia, which include supply of natural gas to end-customers and/or wholesale trade in natural gas. EAN shall be submitted prior to commencing any natural gas sale activity.

Article 267 of the Natural Gas Act (MGA) requires that EANs are submitted to the NRA. In practice, submissions can be done directly through the dedicated section of the website of the Register of Economic Activities (MTR) or sent to the NRA by electronic email (with digitally signed application) or by post delivery to the address of its headquarters.

EAN shall contain at least the following information (pursuant to Article 15 of the General Part of the Economic Activities Code Act (MsüS)):
1. business name and registry code of an undertaking, in the absence thereof the relevant identification code of the country of its seat (the numerical or letter combination equal to the registration number);
2. contact details (telephone number, e-mail address and postal address) of an undertaking;
3. in the case of an undertaking from another EU Member State / EEA country or a third country, the address of its seat if it differs from the postal address;
4. the date of commencement of economic activities in the relevant area of activity if it differs from the date of the EAN submission;
5. name and contact details (telephone number and e-mail) of the person signing EAN, in the case of a legal person also the basis for representation (member of the management board or authorisation).

If an undertaking is established and is operating in the energy sector in another EU Member State / EEA country, but wishes to operate permanently in Estonia, the mandatory EAN submission remains. However, EAN shall not be submitted by an undertaking from EU Member State / EEA country operating in Estonia in the energy sector temporarily.

GIL has to be obtained by any undertaking to import natural gas to Estonia, i.e., to bring natural gas from non-EU Member States / EEA countries for sale in the Estonian market. GILs are issued by the NRA.

In order to be granted GIL, an undertaking shall meet the following requirements:
1. to posses the technical capability and employ personnel with the requisite skills for pursuing the activity stated in the application;
2. to have the required economic and organisational prerequisites and conditions to engage in the activity in respect of which it seeks an authorisation;
3. to submit all the necessary documents pursuant to the Natural Gas Act (MGA) the General Part of the Economic Activities Code Act (MsüS).

If an undertaking holds an authorisation for natural gas imports in another EU Member State / EEA country, which by its subject predominantly corresponds to the Estonian GIL and if its validity has not been confined to a territory or place of business situated outside Estonia, then such undertaking does not need a separate GIL in Estonia. In such case, a foreign undertaking shall submit an application to the NRA for exemption from the authorisation obligation.

Together with the GIL application, the following documents shall be submitted:
1. the TSO’s declaration that, in view of the technical capacity of the system, the transmission and distribution of natural gas is permissible and does not jeopardise the security of supply (the TSO may set additional requirements for natural gas import activities in consideration of the technical capacity and security of supply of the gas system);
2. description of the planned natural gas import activity, for which GIL is requested.

The NRA issues GILs in an electronic format. GIL applications are adjudicated by issuance of or refusal to issue GIL within thirty (30) days as of submission of all required data. The NRA may prolong this term for up to another thirty (30) days.

The Request to Grant the Status of the GEX Participant shall be accompanied by:
1. an extract of the company’s main data issued by the Register of Enterprises or any
other competent authority not earlier than sixty (60) days before the date of submission of an
application to grant the status of the GEX participant (for legal entities only);
2. form for selection of the GEX service fee plan (see below in “Any applicable statutory fees”);
3. a valid Natural Gas Balancing Agreement concluded with a TSO;
4. information about employees or other authorised persons carrying out trading
or other actions on the GEX on behalf of the GEX participant.

Changes in these documents, data, and/or information shall be notified by the GEX participant to GET Baltic immediately, but not later than in two (2) business days from the date of the change. Notifications shall be done in a free form by an e-mail submission.

Gas trading license - notification of the changes (corporate data/contact details)

(Standard) Information category / document to be submitted Gas trading license – notification of the changes (corporate data/contact details)
Legal basis Article 30(5) of the General Part of the Economic Activities Code Act (MsüS) Articles 30(5) and 32-33 of the General Part of the Economic Activities Code Act (MsüS) Paragraph 6.6 of the GEX Participant’s Contract
Legal reference and convenience translation General Part of the Economic Activities Code Act (MsüS) General Part of the Economic Activities Code Act (MsüS) GEX Participant’s Contract
Recipient (NRA, TSO, power exchange etc.) NRA NRA GET Baltic
Submission deadline Within five (5) business days from the date of the change Within five (5) business days from the date of the change Within three (3) business days from the date of the change
Frequency Every time in case of changes in the declared corporate data / contact details Every time in case of changes in the declared corporate data / contact details Every time in case of changes in the indicated corporate data / contact details
Form of submission (internet page, e-mail, original copy etc.) Notification of change can be submitted by:
1. entering the Register of Economic Activities (MTR) at https://mtr.mkm.ee/; or
2. sending the digitally signed application to the NRA at mtr@konkurentsiamet.ee; or
3. sending the application via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
Notification of change can be submitted by:
1. entering the Register of Economic Activities (MTR) at https://mtr.mkm.ee/; or
2. sending the digitally signed application to the NRA at mtr@konkurentsiamet.ee; or
3. sending the application via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
Free form information notice to GET Baltic (e-mail submission)
Applicable for Natural gas seller
(retail supplier / wholesale trader)
Natural gas importer GEX participant
Comments In the event of a change in the general data of the economic activity performed by a natural gas  seller (i.e., retail supplier or wholesale trader), including the corporate data and contact details, such change shall be notified without delay, but no later than within five (5) business days from the date of the change.

The change in the corporate date and contact details shall be notified to both the NRA and the registrar of the Register of Economic Activities (MTR). In practice, the notification of change can be submitted directly through the dedicated section of the website of the Register of Economic Activities (MTR) or sent to the NRA by electronic email (if digitally signed) or by post delivery to the address of its headquarters. 

In the event of a change in the general data of the economic activity performed by a natural gas  importer, including the corporate data and contact details, such change shall be notified without delay, but no later than within five (5) business days from the date of the change.

The change in the corporate date and contact details shall be notified to both the NRA and the registrar of the Register of Economic Activities (MTR). In practice, the notification of change can be submitted directly through the dedicated section of the website of the Register of Economic Activities (MTR) or sent to the NRA by electronic email (if digitally signed) or by post delivery to the address of its headquarters.

If, due to the notified change, a need for amendment to GIL appears, the notices are regarded as applications for amendment to GIL pursuant to the General Part of the Economic Activities Code Act (MsüS). The NRA adjudicates applications for the modification (amendment) of GIL within thirty (30) days.

Please note that this applies to changes in corporate data and/or contact details indicated in the GEX Participant’s Contract. Changes in relevant data and information indicated in the Request to Grant the Status of the GEX Participant shall be notified immediately, but not later than in two (2) business days from the date of the change (see above in “Registration and authorisation for gas trading activities in the natural gas market “).

Gas trading license - renewal of license for additional period

(Standard) Information category / document to be submitted Gas trading license – renewal of license for additional period
Legal basis Articles 4(1), 15(6), 34, 36, and 38 of the General Part of the Economic Activities Code Act (MsüS) Articles 4(1), 24(1), 37, and 38 of the General Part of the Economic Activities Code Act (MsüS) Paragraph 5.1 of the GEX Participant’s Contract
Legal reference and convenience translation General Part of the Economic Activities Code Act (MsüS) General Part of the Economic Activities Code Act (MsüS) GEX Participant’s Contract
Recipient (NRA, TSO, power exchange etc.) NRA NRA GET Baltic
Submission deadline n/a n/a n/a
Frequency n/a n/a n/a
Form of submission (internet page, e-mail, original copy etc.) n/a n/a n/a
Applicable for Natural gas seller
(retail supplier / wholesale trader)
Natural gas importer GEX participant
Comments Natural gas sellers (i.e., retail suppliers and wholesale traders) are registered in the Register of Economic Activities (MTR) upon submission of EAN for an indefinite period of time (unless the EAN specifies the temporary nature of the activity).

An undertaking may be excluded (deregistered) from the Register of Economic Activities at its own initiative by waiving the natural gas sale activity or if it is prohibited by the NRA to perform such activity due to a material violation of the requirements for economic activities in accordance with General Part of the Economic Activities Code Act (MsüS).

GILs are issued for an indefinite period of time. An undertaking may waive its activity of natural gas imports at its own initiative or may be prohibited by the NRA to perform such activity due to a material violation of the requirements for economic activities in accordance with General Part of the Economic Activities Code Act (MsüS). GER and corresponding GEX Participant’s Contract remain valid for an indefinite period of time until not cancelled pursuant to Section 5 of the GEX Participant’s Contract and the GEX Trading Regulation of GET Baltic.

Changes in the corporate data/contact details set out in the agreement concluded with the TSO

(Standard) Information category / document to be submitted Changes in the corporate data/contact details set out in the agreement concluded with the TSO
Legal basis Paragraph 7.2 of
the Natural Gas Transmission Service Agreement
Paragraph 7.2 of
the Natural Gas Balancing Agreement
Legal reference and convenience translation Natural Gas Transmission Service Agreement Natural Gas Balancing Agreement
Recipient (NRA, TSO, power exchange etc.) Elering (TSO)
Submission deadline Within three (3) business days from the date of the change
Frequency Every time in case of changes in the indicated corporate data / contact details
Form of submission (internet page, e-mail, original copy etc.) Free form information notice to Elering
(e-mail submission)
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Applicable to both natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers who are required – prior to commencing their respective activities – to conclude and further possess a valid Natural Gas Transmission Service Agreement and Natural Gas Balancing Agreement with the TSO.

Notification of changes in the corporate data/contact details set out in the agreement with the TSO need to be notified “immediately”, but not later than within three (3) business days from the date of the respective change.

Any applicable statutory fees (e.g. import fees, licence fees, supervisory fees, operational fees)

(Standard) Information category / document to be submitted Any applicable statutory fees (e.g. import fees, licence fees, supervisory fees, operational fees)
Legal basis Article 9(6) of the General Part of the Economic Activities Code Act (MsüS) Article 345 of the State Fees Act (RLS) Article 19(7) and 22(8) of the General Part of the Economic Activities Code Act (MsüS) Article 155 of the State Fees Act (RLS) Paragraphs 93-101 of
the GEX Trading Regulation
of GET Baltic
Legal reference and convenience translation General Part of the Economic Activities Code Act (MsüS) State Fees Act (RLS) General Part of the Economic Activities Code Act (MsüS) State Fees Act (RLS) GEX Trading Regulation of GET Baltic
Recipient (NRA, TSO, power exchange etc.) Ministry of Finance Ministry of Finance GET Baltic
Submission deadline Prior to the EAN submission Prior to the submission of application for GIL See in comments
Frequency One-time payment One-time payment or annually for the term of validity See in comments
Form of submission (internet page, e-mail, original copy etc.) n/a n/a Form for Selection of the GEX Service Fee Plan
Applicable for Natural gas seller
(retail supplier / wholesale trader)
Natural gas importer GEX participant
Comments No state fee applies for natural gas sellers (i.e., retail suppliers and wholesale traders) if the EAN submission is done by entering the Register of Economic Activities (MTR) at https://mtr.mkm.ee/.

A state fee of EUR 10 must be paid in advance to the bank account of the Ministry of Finance* if the EAN submission is done by other means, using the reference number 2900082935.

*Swedbank – EE932200221023778606
*SEB – EE891010220034796011
*Luminor – EE701700017001577198

State fee of the issuance of GIL is EUR 640 for every year of validity. Since GILs are issued for an indefinite period of time, the annual payment shall be made for each year of the validity of GIL (i.e., for each year when an undertaking carries out the activity of natural gas imports).

A state fee in the amount 50% (i.e., EUR 320) must be paid for the review of an application for changing the terms and conditions of GIL.

A state fee  must be paid in advance to the bank account of the Ministry of Finance* if the EAN submission is done by other means, using the reference number 2900080076.

*Swedbank – EE932200221023778606
*SEB – EE891010220034796011
*Luminor – EE701700017001577198

GEX initial registration fee is not applied (i.e., GER is provided free of charge).

GEX participant can choose one of two GEX Service Fee Plans:
Plan #1: annual membership fee – EUR 5,000; floating trading fee – EUR 0.08 per MWh;
Plan #2: annual membership fee – EUR 0; floating trading fee – EUR 0.12 per MWh.

GEX Service Fee Plan may be changed and fees shall be paid under the terms and conditions stipulated in the GEX Trading Regulation of GET Baltic.

Notification on termination of gas trading activities in the natural gas market

(Standard) Information category / document to be submitted Notification on termination of gas trading activities in the natural gas market
Legal basis Articles 4(1), 30(1)-(2), and 34 of the General Part of the Economic Activities Code Act (MsüS) Articles 4(1), 30(1)-(2), and 34 of the General Part of the Economic Activities Code Act (MsüS) Section 5 of the GEX Participant’s Contract
Legal reference and convenience translation General Part of the Economic Activities Code Act (MsüS) General Part of the Economic Activities Code Act (MsüS) GEX Participant’s Contract
Recipient (NRA, TSO, power exchange etc.) NRA NRA GET Baltic
Submission deadline At least thirty (30) days in advance At least thirty (30) days in advance At least thirty (30) days prior to the anticipated cancellation of the GEX Participant’s Contract
Frequency One-time submission One-time submission One-time submission
Form of submission (internet page, e-mail, original copy etc.) Notification of activity termination can be submitted by:
1. entering the Register of Economic Activities (MTR) at https://mtr.mkm.ee/; or
2. sending the digitally signed notification to the NRA at mtr@konkurentsiamet.ee; or
3. sending the notification via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
Notification of activity termination can be submitted by:
1. entering the Register of Economic Activities (MTR) at https://mtr.mkm.ee/; or
2. sending the digitally signed notification to the NRA at mtr@konkurentsiamet.ee; or
3. sending the notification via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
Free form information notice to GET Baltic (e-mail submission)
Applicable for Natural gas seller
(retail supplier / wholesale trader)
Natural gas importer GEX participant
Comments A temporary suspension or termination of the natural gas sale activity is deemed a material economic change  and shall be notified by a natural gas seller (i.e., retail supplier or wholesale trader) at least thirty (30) days prior to the anticipated suspension or termination.

In cases of unplanned interruptions of the natural gas sale activity, such notification shall be made immediately, but not later than within five (5) working days.

Additional requirements apply for suspension or termination of activities of retail suppliers serving as natural gas suppliers of last resort (which is not a subject matter of this Guide).

The suspension/termination notification can be submitted directly through the dedicated section of the website of the Register of Economic Activities (MTR) or sent to the NRA by electronic email (if digitally signed) or by post delivery to the address of its headquarters.

A temporary suspension or termination of the natural imports activity is deemed a material economic change  and shall be notified by a natural gas importer at least thirty (30) days prior to the anticipated suspension or termination.

In cases of unplanned interruptions of the natural imports activity, such notification shall be made immediately, but not later than within five (5) working days.

The suspension/termination notification can be submitted directly through the dedicated section of the website of the Register of Economic Activities (MTR) or sent to the NRA by electronic email (if digitally signed) or by post delivery to the address of its headquarters.

The GEX Participant’s Contract may be cancelled on request of any party by a written notice to the other party not later than thirty (30) days before the anticipated cancellation.

Other possible cases for cancellation of the GEX Participant’s Contract are specified in Section 5 of the GEX Participant’s Contract and the GEX Trading Regulation of GET Baltic.

Commercial information relating to existing or planned trading activities in the given market

Annual (activity) report, including annual turnover, financial statements, annual accounts

(Standard) Information category / document to be submitted Annual (activity) report, including annual turnover, financial statements, annual accounts
Legal basis Articles 8(2), (3), (41) and (6) of the Natural Gas Act (MGA) Articles 30(6) and (8), and 34(3) of the General Part of the Economic Activities Code Act (MsüS) Articles 2, 4(4), and 14-26 the Accounting Act (RPS) Articles 91 and 92 of the Auditing Act (AudS)
Legal reference and convenience translation Natural Gas Act (MGA) General Part of the Economic Activities Code Act (MsüS) Accounting Act (RPS) Auditing Act (AudS)
Recipient (NRA, TSO, power exchange etc.) Commercial Register (RIK), NRA,
customers
(general public)
Submission deadline Within six (6) months after the end of each financial year
Frequency Annually
Form of submission (internet page, e-mail, original copy etc.) Electronically via e-Business platform of the Commercial Register (RIK)
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers are obliged to prepare, approve, submit, and publish annual reports within six (6) months after the end of each financial year in accordance with the Accounting Act (RPS).

The annual report shall contain the following:
1. annual accounts (including balance sheet, income statement, cash flow statement, statement of changes in equity, and notes on annual accounts);
2. management report;
3. report on the changes in the performed economic activity and their notification pursuant to Article 30 of the General Part of the Economic Activities Code Act (MsüS);
4. activity report of an issuer of securities traded on a regulated securities market;
5. corporate governance report (by an undertaking whose securities giving the right to vote have been admitted to trading on the regulated securities market);
6. taxonomy elements established by the Government.

Obligation to audit or inspect (review) annual reports depends on the undertaking’s sales revenue or income, total assets, and the average number of employees, as established under Article 91 and 92 of the Auditing Act (AudS).

Estonian legislation does not require for annual reports to be directly submitted to the NRA. It is thus assumed that, once submitted to the Commercial Register (RIK), annual reports may be retrieved by the NRA electronically. An undertaking shall allow the NRA to inspect its accounts and provide the necessary explanations concerning its economic activities.

Approved and submitted annual accounts shall be published on an undertaking’s website or, if the publishing is not required under the Accounting Act (RPS), an undertaking shall keep one copy of annual accounts available to the public at its place of business (headquarters).

An undertaking which has not submitted its annual report six (6) months after the expiry of the submission term is deemed to have completely renounced (waived) its economic activity.

Yearly/Quarterly/Monthly domestic and cross-border purchase / sale of natural gas

(Standard) Information category / document to be submitted Yearly/Quarterly/Monthly domestic and cross-border purchase / sale of natural gas
Legal basis Articles 8(42) and (43), and 16(4) of the Natural Gas Act (MGA)
Legal reference and convenience translation Natural Gas Act (MGA)
Recipient (NRA, TSO, power exchange etc.) NRA
Submission deadline Continuous obligation for five (5) years following transactions
Frequency Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Information shall be submitted to the NRA by:
1. sending the digitally signed information notice to the NRA at mtr@konkurentsiamet.ee; or
2. by sending the notification via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers are obliged to preserve information concerning natural gas transactions (including domestic and cross-border purchase and sale of natural gas) for five (5) years and, if necessary, submit it to the NRA and the European Commission. Such information shall contain the following:
1. the term of the transaction and the terms of delivery and settlement;
2. the volume of the transaction;
3. date and time of execution of the transaction by trading periods;
4. the price of the transaction;
5. information on the seller;
6. details of unfinished supply contracts.

Such information is required to be deleted after the expiry of five (5) years following the respective transaction.

Domestic and cross-border purchase and sale of natural gas, including imports, are also followed by the TSO and reported to the NRA for the purposes of the preparation of the security of supply report.

Information about the concluded contracts, performance of import agreements in a given period (including type of transaction/agreement, import/export volumes, price, counterparties) - yearly, quarterly, monthly

(Standard) Information category / document to be submitted Information about the concluded contracts, performance of import agreements in a given period (including type of transaction/agreement, import/export volumes, price, counterparties) – yearly, quarterly, monthly
Legal basis Articles 8(4), (42), (43), and (5) of the Natural Gas Act (MGA) Article 28 (et alia) of the Official Statistics Act (RStS)
Legal reference and convenience translation Natural Gas Act (MGA) Official Statistics Act (RStS)
Recipient (NRA, TSO, power exchange etc.) NRA, customers (general public) Statistics Estonia
Submission deadline Continuous obligation for five (5) years following transactions Ad hoc
Frequency Ad hoc Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Information shall be submitted to the NRA by:
1. sending the digitally signed information notice to the NRA at mtr@konkurentsiamet.ee; or
2. by sending the notification via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
In a form of the statistics programme and/or questionnaire published or provided by the Statistics Estonia
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers are obliged to preserve information concerning natural gas transactions for five (5) years and, if necessary, submit it to the NRA and the European Commission. Such information shall contain the following:
1. the term of the transaction and the terms of delivery and settlement;
2. the volume of the transaction;
3. date and time of execution of the transaction by trading periods;
4. the price of the transaction;
5. information on the seller;
6. details of unfinished supply contracts.

Such information is required to be deleted after the expiry of five (5) years following the respective transaction.

A gas undertaking shall also publish the agreed prices, thresholds, methodologies, standard terms and conditions and information on consumer rights and dispute resolution possibilities on its website and provide information thereon to the person who requests it (the publication obligations excludes commercial data of particular transactions).

Natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers are obliged to submit to the Statistics Estonia information concerning the development of the price of gas and network services pursuant to the procedure provided for in the Official Statistics Act (RStS).

Submission of financial information necessary for the calculation of the statutory regulatory fee

(Standard) Information category / document to be submitted Submission of financial information necessary for the calculation of the statutory regulatory fee
Legal basis n/a
Legal reference and convenience translation n/a
Recipient (NRA, TSO, power exchange etc.) n/a
Submission deadline n/a
Frequency n/a
Form of submission (internet page, e-mail, original copy etc.) n/a
Applicable for n/a
Comments Statutory regulatory fees are not applied to natural gas sellers (i.e., retail suppliers and wholesale traders), natural gas importers, and/or GEX participants.

Data on the supply of natural gas to end-customers

(Standard) Information category / document to be submitted Data on the supply of natural gas to end-customers
Legal basis Articles 8(4), (42), (43), and (5) of the Natural Gas Act (MGA) Article 28 (et alia) of the Official Statistics Act (RStS)
Legal reference and convenience translation Natural Gas Act (MGA) Official Statistics Act (RStS)
Recipient (NRA, TSO, power exchange etc.) NRA, customers (general public) Statistics Estonia
Submission deadline Continuous obligation for five (5) years following transactions Ad hoc
Frequency Ad hoc Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Information shall be submitted to the NRA by:
1. sending the digitally signed information notice to the NRA at mtr@konkurentsiamet.ee; or
2. by sending the notification via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
In a form of the statistics programme and/or questionnaire published or submitted by the Statistics Estonia
Applicable for Natural gas seller (retail supplier) Natural gas seller (retail supplier)
Comments Natural gas sellers (retail suppliers) are obliged to preserve information concerning natural gas transactions regarding the supply of natural gas to end-customers for five (5) years and, if necessary, submit it to the NRA and the European Commission. Such information shall contain the following:
1. the term of the transaction and the terms of delivery and settlement;
2. the volume of the transaction;
3. date and time of execution of the transaction by trading periods;
4. the price of the transaction;
5. information on the seller;
6. details of unfinished supply contracts.

Such information is required to be deleted after the expiry of five (5) years following the respective transaction.

A gas undertaking shall also publish the agreed prices, thresholds, methodologies, standard terms and conditions and information on consumer rights and dispute resolution possibilities on its website and provide information thereon to the person who requests it (the publication obligations excludes commercial data of particular transactions).

Natural gas sellers (retail suppliers), amongst other gas undertakings, are obliged to submit to the Statistics Estonia information concerning the development of the price of gas and network services pursuant to the procedure provided for in the Official Statistics Act (RStS).

Data on investigations of complaints received from customers

(Standard) Information category / document to be submitted Data on investigations of complaints received from customers
Legal basis Articles 8(3) and (5), and 101(2)(9) of the Natural Gas Act (MGA)
Legal reference and convenience translation Natural Gas Act (MGA)
Recipient (NRA, TSO, power exchange etc.) NRA, customers (general public)
Submission deadline Continuous obligation to publish information
Frequency n/a
Form of submission (internet page, e-mail, original copy etc.) Website publication

Information shall be submitted to the NRA by:
1. sending the digitally signed information notice to the NRA at mtr@konkurentsiamet.ee; or
2. by sending the notification via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia

Applicable for Natural gas seller (retail supplier)
Comments Natural gas sellers (retail suppliers), amongst other natural gas undertakings, are obliged to publish on their website (as standard contract provisions) and provide in natural gas sales contracts information on the procedure for handling complaints.

Natural gas sellers do not have a separate obligations to report on the data on investigations of complaints received from customers. It is assumed that such data  may be inquired and retrieved by the NRA on an ad hoc basis in a form of its requests for information pursuant to Article 8(3) of the Natural Gas Act (MGA).

REMIT reporting obligations

(Standard) Information category / document to be submitted REMIT reporting obligations
Legal basis Regulation (EU) No 1227/2011
Legal reference and convenience translation Regulation (EU) No 1227/2011 of the European Parliament and of the Council of 25 October 2011 on wholesale energy market integrity and transparency
Recipient (NRA, TSO, power exchange etc.) NRA, ACER
Submission deadline Pursuant to REMIT
Frequency Pursuant to REMIT
Form of submission (internet page, e-mail, original copy etc.) Pursuant to REMIT and as procedurally set by the NRA
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Regulation (EU) No 1227/2011 is directly applicable in Estonia, therefore a set of its reporting obligations – obligation to publish inside information (Article 4), record of wholesale gas market transactions (Article 8), registration of market participants (Article 10) – shall be implemented pursuant to respective rules stipulated therein. Certain procedural arrangements, such as applicable for registration of market participants, are systematically published by the NRA on a REMIT dedicated section of its website (see Competition Authority’s website: Electricity, natural gas –> International cooperation –> REMIT) .

REMIT reporting obligations are applied to those natural gas undertakings who trade in wholesale natural gas products.

Security of supply

Storage obligation

(Standard) Information category / document to be submitted Storage obligation
Legal basis Articles 2(5)(b), 6(1) (et alia) of
Regulation (EU) No 2017/1938
Articles 8(7), 261, and 264-266 of the Natural Gas Act (MGA)
Legal reference and convenience translation Regulation (EU) 2017/1938 of the European Parliament and of the Council of 25 October 2017 concerning measures to safeguard the security of gas supply and repealing Regulation (EU) No 994/2010 Natural Gas Act (MGA)
Recipient (NRA, TSO, power exchange etc.) NRA, Elering (TSO)
Submission deadline Ad hoc
Frequency Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Ad hoc
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Gas supply standard is applied as established under Article 6(1) of Regulation (EU) 2017/1938.

In Estonia, gas supply standard is ensured through the gas stocks to be formed, stored, and used by the TSO (Elering) as a quantity that ensures the gas supply of a protected customer in accordance with Regulation (EU) 2017/1938 and following the requirements stipulated in the Natural Gas Act (MGA). The TSO may hold gas stocks in an EU Member State.

The TSO may keep the gas stocks itself or assign it to another legal person on a contractual basis. This is how natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers may participate in securing the gas stocks. Apart form the TSO, other market participants do not have express obligations to store natural gas (unless are contracted for this purpose by the TSO).

Protected customers are deemed household customers and non-household customers defined under Article 2(5)(b) of Regulation (EU) 2017/1938 and specified under Article 261(2) of the Natural Gas Act.

At the request of the NRA, a natural gas undertaking shall provide the NRA with the information concerning its particular economic activity necessary to fulfil the NRA’s obligations under Regulation (EU) 2017/1938 (ad hoc information request).

Obligations in cases of energy emergencies

(Standard) Information category / document to be submitted Obligations in cases of energy emergencies
Legal basis Articles 8(7), 261-266 of the Natural Gas Act (MGA)
Legal reference and convenience translation Natural Gas Act (MGA)
Recipient (NRA, TSO, power exchange etc.) Ministry of Economic Affairs and Communications, NRA, Elering (TSO)
Submission deadline Ad hoc
Frequency Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Ad hoc
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments If the TSO has reliable information that an event may occur as a result of which the supply situation may significantly deteriorate or a supply disruption has already occurred, the TSO shall notify the Ministry of Economic Affairs and Communications and the NRA.

Upon submission by the Ministry of Economic Affairs and Communications (in consultations with the NRA), the Government may introduce the following emergency measures:
1. to restrict the supply of gas to persons who use gas for purposes other than the production of heat;
2. permit the restriction of gas supply to undertakings producing heat;
3. permit the lowering of the temperature of water supplied for the heating of residential buildings;
4. oblige undertakings producing heat to use reserve fuel as fuel.

Natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers shall implement/follow the Government’s established emergency measures addressing their specific activities on the natural gas market.

Natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers may also be required to implement/follow specific measures envisaged in the NRA’s security of supply plans pursuant to Article 263 of the Natural Gas Act (MGA).

Notification of each natural gas supply agreement, cross-border trading agreement above certain duration period

(Standard) Information category / document to be submitted Notification of each natural gas supply agreement, cross-border trading agreement above certain duration period
Legal basis Article 14(6) of
Regulation (EU) No 2017/1938
Articles 8(4), (42), (43), and (5) of the Natural Gas Act (MGA)
Legal reference and convenience translation Regulation (EU) 2017/1938 of the European Parliament and of the Council of 25 October 2017 concerning measures to safeguard the security of gas supply and repealing Regulation (EU) No 994/2010 Natural Gas Act (MGA)
Recipient (NRA, TSO, power exchange etc.) NRA
Submission deadline Ad hoc
Frequency Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Information shall be submitted to the NRA by:
1. sending the digitally signed information notice to the NRA at mtr@konkurentsiamet.ee; or
2. by sending the notification via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers are obliged to preserve information concerning natural gas transactions (including domestic and cross-border purchase and sale of natural gas) for five (5) years and, if necessary, submit it to the NRA and the European Commission. Such information shall contain the following:
1. the term of the transaction and the terms of delivery and settlement;
2. the volume of the transaction;
3. date and time of execution of the transaction by trading periods;
4. the price of the transaction;
5. information on the seller;
6. details of unfinished supply contracts.

Notification obligation under Article 14(6) of Regulation (EU) No 2017/1938 is directly applicable and shall be duly implemented by natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers operating in Estonia.

Operational / IT information

Data on quality of supply and other services

(Standard) Information category / document to be submitted Data on quality of supply and other services
Legal basis Articles 8(1) and 32 of the Natural Gas Act (MGA) Articles 17 and 29 of the General Part of the Economic Activities Code Act (MsüS) Article 19 of the Network Codes for the Functioning of the Gas Market
Legal reference and convenience translation Natural Gas Act (MGA) General Part of the Economic Activities Code Act (MsüS) Network Codes for the Functioning of the Gas Market
Recipient (NRA, TSO, power exchange etc.) NRA
Submission deadline n/a
Frequency n/a
Form of submission (internet page, e-mail, original copy etc.) n/a
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers have a general obligation to ensure the quality of their services in compliance with the Natural Gas Act (MGA), the General Part of the Economic Activities Code Act (MsüS), other legal acts and contractual obligations. However, natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers – unlike system operators – are not obliged to report to the NRA regarding particular quality parameters of their provided services.

Additional requirements (presumably, including quality requirements) may be established for natural gas imports and for natural gas supplies in emergency cases, as envisaged by Article 32 of the Natural Gas Act (MGA).

It is assumed that quality of the services provided by natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers may be inquired and retrieved by the NRA on an ad hoc basis in a form of its requests for information pursuant to Article 8(3) of the Natural Gas Act (MGA).

Quality requirements for natural gas supplied to the natural gas system are provided stipulated in Article 19 of the Network Codes for the Functioning of the Gas Market approved by the Ministry of Economic Affairs and Communications.

Evidence that the financial security is maintained for each year of validity of the license

(Standard) Information category / document to be submitted Evidence that the financial security is maintained for each year of validity of the license
Legal basis Article 122 of the Natural Gas Act (MGA) Paragraphs 102-121 and 143
of the GEX Trading Regulation
of GET Baltic
Legal reference and convenience translation Natural Gas Act (MGA) GEX Trading Regulation of GET Baltic
Recipient (NRA, TSO, power exchange etc.) Elering (TSO) GET Baltic
Submission deadline Ad hoc Not later than one (1) business day prior to the beginning of gas trading on the GEX
Frequency Ad hoc One-time / ad hoc
Form of submission (internet page, e-mail, original copy etc.) Bank guarantee In a form of collaterals prescribed under the GEX Trading Regulation
Applicable for n/a GEX participant
Comments No general financial security-related requirements are applied for natural gas sellers (i.e., retail suppliers and wholesale traders) and/or natural gas importers(apart from specific requirements to GEX participants (see below)).

Specific requirements for balance provider guarantees, as stipulated in Article 122 of the Natural Gas Act (MGA), apply only if a natural gas seller (i.e., retail supplier and wholesale trader) and/or natural gas importer acts as a balance provider pursuant to the contract concluded with the TSO.

A GEX participant, in order to fulfil order to buy, shall transfer to the bank account indicated by the GEX Operator the prepayment or submit the collateral the value of which should be no less than the value of foreseen orders price, including VAT and floating trading fee.

The GEX Operator shall be entitled to provide an additional trading limit that is not subject to the submission of any collateral or prepayment. The decision regarding the provision of the
additional trading limit shall be adopted by the meeting of the Board of the GEX Operator with due consideration of the risk level of each GEX participant individually,  based on such criteria as the GEX participant’s financial position, the execution of their obligations to goods or services suppliers and other circumstances, which influence the financial risk.

The GEX Operator is  entitled to request the information required to
evaluate the financial standing of a GEX Participant provided that this is required for the
performance of the activity of the GEX.  Such information shall be submitted to the GEX Operator in five (5) business days following the GEX Operator’s request (see below in “Provision of information to the GEX Operator”).

Provision of the system-related information to the TSO

(Standard) Information category / document to be submitted Provision of the system-related information to the TSO
Legal basis Contractual arrangements with the TSO Common Natural Gas Transmission System Regulations
Legal reference and convenience translation Natural Gas Transmission Service Agreement Natural Gas Balancing Agreement Common Regulation for the Use of the Natural Gas Transmission System Common Regulations for the Natural Gas Balancing of the Transmission System
Recipient (NRA, TSO, power exchange etc.) Elering
(TSO)
Submission deadline Ad hoc
Frequency Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Free form information notices to Elering (TSO) submitted in person and/or by email
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments Exchanges in the system-related information between the TSO and natural gas traders are executed on the basis of respective contractual arrangements – the Natural Gas Transmission Service Agreement and the Natural Gas Balancing Agreement – under the terms and conditions stipulated in the natural gas transmission system regulations and other applicable legal acts (including directly applicable EU Gas Network Codes).

The TSO is also one of the entities entitled by law for retrieving an ad hoc information from gas undertakings, if such information is required to perform the TSO’s tasks.

Provision of information to consumers

(Standard) Information category / document to be submitted Provision of information to consumers
Legal basis Articles 8(5), (51), and (52) and 101of the Natural Gas Act (MGA) Article 31 of the General Part of the Economic Activities Code Act (MsüS) Consumption Data Format
Legal reference and convenience translation Natural Gas Act (MGA) General Part of the Economic Activities Code Act (MsüS) Consumption Data Format
Recipient (NRA, TSO, power exchange etc.) Customers
Submission deadline n/a
Frequency Continual
Form of submission (internet page, e-mail, original copy etc.) Online publication / indication in service contracts / indication in billing information / submission upon request
Applicable for Natural gas seller (retail supplier / wholesale trader)
Comments Each natural gas seller (i.e., retail supplier and wholesale trader) is required to ensure that its customers are provided with an access to and/or are individually provided with an information regarding contractual relations with the natural gas seller, specification of services, applicable prices, billing information, consumer rights, rules for investigation of complaints, dispute settlement rules, actual consumption of natural gas, and other information prescribed by the  Natural Gas Act (MGA) and other applicable legal acts, which corresponds with Paragraph 1 of Annex I to Directive 2009/73/EC of the European Parliament and of the Council of 13 July 2009 concerning common rules for the internal market in natural gas. Such information shall be provided to customers free of charge.

Provision of information to the GEX Operator

(Standard) Information category / document to be submitted Provision of information to the GEX Operator
Legal basis Paragraphs 143 and 150-153 of the GEX Trading Regulation
of GET Baltic
Legal reference and convenience translation GEX Trading Regulation of GET Baltic
Recipient (NRA, TSO, power exchange etc.) GET Baltic
Submission deadline In five (5) business days following the GEX Operator’s request
Frequency Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Free form information submitted to GET Baltic in an electronic form (by e-mail or via the Electronic Trading System (ETS))
Applicable for GEX participant
Comments Each GEX participant shall deliver to the GEX Operator the information
required to duly carry out the monitoring of trade in natural gas. Reporting to the GEX Operator is regulated by the GEX Participant’s Agreement and the GEX Trading Regulation.

Gas Data Hub

(Standard) Information category / document to be submitted Gas Data Hub
Legal basis Article 102 of the Natural Gas Act (MGA) Articles 12-18 of the Network Codes for the Functioning of the Gas Market
Legal reference and convenience translation Natural Gas Act (MGA) Network Codes for the Functioning of the Gas Market
Recipient (NRA, TSO, power exchange etc.) Elering (TSO), gas market participants
Submission deadline Ad hoc
Frequency Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Online submissions via the TSO’s administered Gas Data Hub
Applicable for Natural gas seller (retail supplier / wholesale trader)
Comments For the efficient functioning of the gas market, promotion of competition between sellers, and supplier switching, the TSO created and administers a digital environment – the Gas Data Hub – and enables the access thereto for gas market participants who have a legal obligation and right to submit and receive data on an equal basis. There is no charge for submitting or receiving data to/from the Gas Data Hub.

The TSO submits the following information to the Gas Data Hub:
1. the identifier of the market participant;
2. the identifier of the measuring point;
3. data of the measuring point;
4. measurement data by measurement points;
5. the period of validity of the network participant’s network contract;
6. other relevant information.

Natural gas sellers (i.e., retail suppliers and wholesale traders) shall forward to the Gas Data Hub the validity period of the sales contract of the market participant and the seller’s data.

Data entered on the Gas Data Hub is stored for five (5) years.

Any other information upon the request of the NRA (supply agreements, transport / storage agreements, etc.)

Any other information upon the request of the NRA (supply agreements, transport / storage agreements, etc.)

(Standard) Information category / document to be submitted Any other information upon the request of the NRA (supply agreements, transport / storage agreements, etc.)
Legal basis Articles 8(3) and 37(1) of the Natural Gas Act (MGA)
Legal reference and convenience translation Natural Gas Act (MGA)
Recipient (NRA, TSO, power exchange etc.) NRA
Submission deadline Ad hoc
Frequency Ad hoc
Form of submission (internet page, e-mail, original copy etc.) Information shall be submitted to the NRA by:
1. sending the digitally signed information notice to the NRA at mtr@konkurentsiamet.ee; or
2. by sending the notification via mail to the address of the NRA: Tatari 39, Tallinn 10134, Estonia
Applicable for Natural gas seller (retail supplier / wholesale trader)

Natural gas importer

Comments The NRA, while performing its functions specified in the Natural Gas Act (MGA), has the right to request and receive without hindrance the information necessary for the performance of its tasks,  regardless of its degree of secrecy. The NRA may request information, inter alia, from all natural gas sellers (i.e., retail suppliers and wholesale traders) and natural gas importers.

A natural gas trader must provide the information requested by the NRA at the time and in accordance with the procedures specified by the NRA. This obligation reaches beyond mandatory reporting described above and covers any NRA’s ad hoc request for information within the scope of its regulatory competence

A natural gas undertaking must also ensure the possibility for the NRA to perform its state supervision functions pursuant to the Natural Gas Act (MGA).

Contact information

COMPETITION AUTHORITY (NRA)
Address: Tatari 39, 10134 Tallinn, Estonia
Tel: +372 667 2400
E-mail: info@konkurentsiamet.ee
Web: www.konkurentsiamet.ee/en

MINISTRY OF ECONOMIC AFFAIRS AND COMMUNICATIONS
Address: Suur-Ameerika 1, 10122 Tallinn, Estonia
Tel: +372 625 6342
E-mail: info@mkm.ee
Web: www.mkm.ee/en

MINISTRY OF FINANCE
Address: Suur-Ameerika 1, 10122 Tallinn, Estonia
Tel: +372 611 3558
E-mail: info@fin.ee
Web: www.rahandusministeerium.ee/en

REGISTER OF ECONOMIC ACTIVITIES (MTR)
Tel: +372 668 7080
E-mail: register@ttja.ee
Web: https://mtr.mkm.ee/

ELERING AS (GAS TSO)
Address: Kadaka tee 42, 12915 Tallinn, Estonia
Tel: +372 715 1222
E-mail: info@elering.ee
Web: www.elering.ee/en

UAB GET BALTIC (GEX OPERATOR)
Address: Geležinio vilko str. 18A, LT-08104 Vilnius, Lithuania
Tel: +370 5 236 0000
E-mail: info@getbaltic.com
Web: www.getbaltic.com/en

Disclaimer: This document has been prepared by Correggio Consulting Limited, exercising all reasonable care and to the best knowledge of Correggio Consulting contributors and subject to the information available at the time of its preparation. However, neither Correggio Consulting nor its retained consultants, involved in its preparation, shall be liable or otherwise responsible for its use, or reliance upon, and any damages, direct, or, indirect, or consequential losses resulting out of its use in any individual case. Correggio Consulting is not responsible for the users’ decisions based on this report. This report is intended for general guidance and information purposes only. This document or any information provided by it, or derived from it, does not constitute any legal, business, investment or tax advice.

The material contained in this document is obtained from various sources and is complete on the date of its issuance. The CorreggioNet user acknowledges that the regulatory environment is subject to frequent and sometimes unexpected change. This document may not reflect any events, changes or circumstances which occur after the date of its issuance. While all reasonable care has been taken to ensure that all material is up-to-date, true and correctly interpreted, Correggio Consulting does not guarantee its accuracy or completeness.

Correggio Consulting suggestions and recommendations should be analyzed by the user in this informatory context only. Any decisions or corporate strategies taken shall be attributable only to the CorreggioNet user.

This report is only intended for the CorreggioNet users and should not be copied or otherwise distributed, in whole or in part, to any third person. Any infringement of this basic license obligation shall constitute a reason to immediately terminate the CorreggioNet subscription in line with the GTC.