REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on certain aspects concerning gas storage based on Regulation (EU) 2017/1938 of the European Parliament and of the Council
Date: 2023-03-27
Institutions: Directorate-General for Energy, European Commission
Subjects: EU Member State, EU energy policy, energy storage, gas, gas supply, natural gas, price of energy, security of supply, self-sufficiency in energy, storage of hydrocarbons

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.3.2023  COM(2023) 182 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on certain aspects concerning gas storage based on Regulation (EU) 2017/1938 of the European Parliament and of the Council     {SWD(2023) 73 final}  
 
 
1.  Introduction 

Gas  markets  already  started  to  show  considerable  tension  in  2021,  and  gas  prices  increased 
significantly.  Russia’s  military  aggression  against  Ukraine,  which  started  in  February  2022, 
triggered a succession of gas supply disruptions and made gas prices in global markets much more 
volatile.  For  the  EU  and  its  immediate  neighbours,  which  were  dependent  on  the  Russian  gas 
supply, these developments required a strong reaction and measures to tackle supply and demand.   

The extent of imbalances on the gas market and fear of severe supply disruptions, followed by 
potentially  serious  supply  constraints  for  both  industry  and  households,  have  led  to  an 
unprecedented regulatory response. This has contributed to the security of gas supply and ensured 
that gas prices moderated in winter 2022/2023.  

Gas  storage  was  already  an  important  part  of  the  Commission’s  gas  preparedness  plans  to 
overcome winter 2022/2023 and for the coming years, as also highlighted in the REPowerEU plan1 
and  the  Commission  Communication  Save  gas  for  a  safe  winter2.  Specifically,  well-filled  gas 
storages ensure that gas is available both for private households and businesses during the winter 
heating period.  

As a further measure, the Regulation on Gas Storage3, adopted by the co-legislators on 27 June 
2022, requires all Member States with gas storage capacity to ensure their underground gas storage 
is filled up to at least 80% of capacity by 1 November 2022. From 2023 onwards, gas storage will 
have to be filled to 90% by 1 November of each year.  

As an additional safeguard for an adequate filling level of gas storage in the coming years, the Gas 
Storage Regulation stipulates that each storage system operator in the EU has to be certified. This 
certification should be refused or lead to remedies if relevant authorities conclude that a person or 
entity  that  directly  or  indirectly  controls  or  exercises  any  right  over  the  storage  system  could 
endanger the security of the EU’s energy supply.  

This report takes stock of the implementation of the Gas Storage Regulation based on information 
by Member States on their gas storage measures and their certification procedures, complemented 
by  data  from  Eurostat,  in  accordance  with  Article  17a  of  Regulation  (EU)  2017/1938.  It  is 
accompanied by a staff working document, which provides detailed information on measures taken 
by Member States to ensure their gas storage sites are filled and an analysis of gas prices in the 
context of implementing the Storage Regulation.  

1 COM(2022) 639 final. 
2 COM(2022) 360 final. 
3 REGULATION (EU) 2022/1032 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 29 June 2022 amending 
Regulations (EU) 2017/1938 and (EC) No 715/2009 with regard to gas storage, OJ L 173, 30.6.2022, p. 22. 

1 

 
 
 
 
 
 
 
 
                                                           
2.  Legal basis and context of the annual report  

On 1 November 2022, 94.9% of the EU’s gas storage was filled. This was well above the target of 
80%, with all Member States achieving their target set by the Regulation4. On 31 December 2022, 
the filling level was still 83.4% in the EU. In terms of storage, the EU appeared well prepared for 
winter 2022/2023. 

Article 6d (5) of the Storage Regulation states that the Commission has to submit annual reports 
to the European Parliament and the Council. These reports must include: 

  an overview of the measures taken by Member States to fulfil the storage obligations; 
  an  overview  of  the  time  needed  for  the  certification  procedure  set  out  in  Article  3a  of 

Regulation (EC) No 715/2009; 

  an overview of the measures requested by the Commission to ensure compliance with the 

filling trajectories and filling targets; 

  an analysis of the potential effects of this Regulation on gas prices and potential gas savings 

in relation to Article 6b (4). 

The report contributes to broadening the knowledge base on best practices for filling storage sites.  

3.  Overview of measures taken by Member States to fulfil the storage obligations 

The Gas Storage Regulation provides that Member States have to take all necessary measures to 
meet the filling targets. They should aim to use market-based measures where possible to avoid 
unnecessary market  disruption. However, measures may include  regulatory measures,  financial 
incentives or compensation to market participants. 

The Storage Regulation provides an illustrative list of potential measures and tools that Member 
States may take for that purpose. To get feedback on these suggestions, the Commission sent a 
questionnaire  to  the  relevant  Member  State  authorities  in  autumn  2022,  asking  them  about  the 
measures and tools they have used to ensure that their storage sites are filled. The questionnaire 
also asked the views and assessments of Member States on the effectiveness of their measures, 
their strengths and weaknesses.   

According to Member States, the following measures have effectively contributed to filling their 
storage sites in time:  

1.  Imposing an obligation on the storage facility operators on the minimum filling level to 

achieve, in line with the national objective; 
2.  Tendering the capacities to market participants; 
3.  Having a mechanism in place for when the total capacity subscribed is below the minimum 
filling level, for example pre-agreed terms with market participants for the complementary 
volume; 

4.  Ensuring that the capacities booked are effectively used by applying a  ‘use it or lose it’ 

mechanism or imposing penalties for non-compliance; 

4 Gas infrastructure in Europe – Aggregated Gas Storage Inventory (agsi.gie.eu) 

2 

 
 
 
 
 
                                                           
5.  Finally,  if  the  measures  mentioned  above  are  unlikely  to  produce  the  desired  results, 

designate an entity to purchase the missing capacity from the wholesale market. 

Furthermore, with  reference to Annex Ib of Regulation (EU) 2022/1032,  Austria and Germany 
have concluded an agreement on the filling target and the filling trajectory pursuant to Article 6a, 
as those Member States share the responsibility for the storage facilities Haidach and 7Fields5. 

The burden-sharing mechanism of the Regulation provides that Member  States without storage 
facilities on their territories store gas volumes in neighbouring countries corresponding to at least 
15% of their annual consumption. However, Member States have made limited use of coordinated 
instruments to fill gas storages. 

In September 2022, Italy and Greece signed a memorandum of understanding on gas storage. It 
allows shippers  from  the Greek National  Natural Gas Transmission System  to  store up to  1.14 
TWh  of  gas  in  Italy.  Agreements  like  this  one  are  crucial  for  Member  States  that  have  no  gas 
storage  capacity  on  their  own  territories.  The  Estonian  government  arranged  the  purchase  of  1 
TWh as a national strategic reserve to be stored at a storage site in Latvia. 

During  the  seminar6  on  the  implementation  of  the  Gas  Storage  Regulation,  many  European 
associations that are members of the Gas Coordination Group, while recognising the effectiveness 
of the Regulation, recommended more use of market-based tools to implement it in an efficient 
way, especially to reduce storage costs.   

Member States have made unprecedented investments throughout 2022 to make the European gas 
infrastructure more resilient and increase access to liquefied natural gas (LNG) in regions highly 
dependent on Russian gas. The situation in 2023 has therefore evolved significantly and Member 
States can now make better use of market-based tools and rely less on more ‘interventionist’ tools 
that were necessary due to the lack of infrastructure or to prevent market manipulation from non-
EU storage operators.  

As a result of all measures, the 80% filling target for 2022 was exceeded. By 1 November 2022, 
94.9% of the EU’s gas storage was filled, with all Member States having reached more than 80% 
(see table and figure below). Latvia, which was the only Member State with a figure lower than 
80%, qualified for a reduced storage obligation due to the large storage capacity compared with 
national consumption. The filling level reached by Latvia largely exceeded its reduced November 
target set in relation to its own consumption.  

5 Published agreement in the official register of Austria: https://www.ris.bka.gv.at/eli/bgbl/III/2023/16. 
6 Register of Commission expert groups and other similar entities (europa.eu) 

3 

 
 
 
 
 
 
 
 
                                                           
 
Table: Filling levels on 1 November2022 

Filling 
level (%) 

Working (gas) 
volume (TWh) 

AT 

BE 

BG 

CZ 

DE 

DK 

ES 

FR 

HR 

HU 

IT 

LV 

NL 

PL 

PT 

RO 

SE 

SK 

EU 

93.1 

100 

90.4 

94.9 

99.2 

99.3 

94.8 

100 

97.0 

86.0 

95.5 

57.7 

91.8 

98.9 

98.3 

96.8 

92.9 

91.3 

94.9 

95.5 

7.6 

5.8 

43.8 

245.2 

9.9 

35.3 

132.6 

4.8 

67.7 

193.4 

24.1 

138.9 

36.4 

4.0 

32.8 

0.1 

38.8 

1116.21 

Source: AGSI database on 1 November 2022 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
Figure: EU storage filling level and EU trajectory 2022 

4.  Storage sites in the EU formerly owned or operated by Gazprom 

In 2021, Gazprom owned or operated approx. 10% of EU storage capacity. The Gazprom storage 
sites, which were not refilled before the start of winter 2021/2022 and were almost depleted at the 
end of the season when gas is withdrawn from storage. These Gazprom sites, were responsible for 
reducing the average filling level of EU storage sites by 6 to 8 percentage points at the end of 2021 
compared with previous years.  

The following graph shows the development of gas volumes in storage sites owned or operated by 
Gazprom (orange dashed line) and the other EU sites (blue dashed line). The black line shows the 
gas in storage of all EU sites together. 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure: Development of gas volumes in storage sites owned or operated by Gazprom 

In summer 2022, Member States with storage sites owned or operated by Gazprom took measures 
to protect their energy security: 

  Germany nationalised its Gazprom sites, formerly owned by Gazprom Germania. The new 

entity’s name is SEFE Securing Energy for Europe GmbH.  

  Austria’s site was given to another operator under newly introduced ‘use it or lose it’ rules. 
On  17  February  2023,  Germany  and  Austria  signed  an  agreement  to  take  on  joint 
responsibility for using and filling the natural gas storage facilities Haidach and 7Fields 
and to transport stored gas volumes in case of shortages. The deal follows a memorandum 
of  understanding  agreed  between  Berlin  and  Vienna  in  July  2022.  The  two  storage 
facilities,  located  in  Austria,  had  already  been  used  by  both  German  and  Austrian 
companies in the past. 
In  the  Netherlands,  the  government  appointed  a  state-run  entity  called  Energiebeheer 
Nederland to transport gas to the Bergermeer storage facility using unused storage capacity, 
including capacity owned by Gazprom.  

 

  Czechia  applied  the  ‘use  it  or  lose  it’  principle  to  force  market  participants  with  spare 
storage capacity, above a certain threshold, to give back injection slots to the government. 
Under this principle, Gazprom’s storage capacity at the Damborice site has been withdrawn 
and placed under the government’s special auction measures. These include the possibility 
of free auctions and payments to traders in exchange for storing gas.  

6 

 
 
 
 
 
 
 
 
As a result of the measures, the storage sites formerly owned or operated by Gazprom were filled 
up to 94% on average by 1 November 2022 compared to a filling level of 26% on 1 November 
2021. 

The table below demonstrates the effectiveness of Member States’ measures, which abolished or 
reduced Gazprom’s influence on gas storage. It compares the aggregated storage capacity owned 
or operated by Gazprom per country in November 2021 and November 2022.  

Table:  Capacity  of  storage  sites  owned  or  operated  by  Gazprom  by  country  in  2021  and 

corresponding filling levels in November 2021 and November 2022 

Country 

Gazprom 
owned/operating 
capacity 2021 (TWh) 

Filling 
2021 

level  1  Nov. 

Filling level 1 Nov. 2022 

32.3 
AT 
2.2 
CZ 
58.2 
DE 
NL 
19.3 
TOTAL  112.0 

20% 
45% 
27% 
30% 
26% 

91% 
85% 
94% 
99% 
94% 

5.  Demand aggregation tool pursuant to Council Regulation (EU) 2022/2576 

Regulation (EU) 2022/2576, adopted by the Council on 19 December 2022 following a proposal 
from the Commission7, provides for a demand aggregation tool that will support EU countries in 
ensuring sufficient gas supplies in time for winter 2023-2024. Furthermore, the joint purchasing 
mechanism introduced by the Regulation will be key to avoiding that European companies bid for 
the same gas and inflate prices as a consequence. 

EU  countries  are  requested  to  aggregate  demand  for  gas  volumes  equivalent  to  15%  of  their 
respective storage filling obligations. Beyond 15%, aggregation will be voluntary but based on the 
same mechanism. 

For this purpose, the Commission has contracted a service provider to put in place the necessary 
services with the aim to aggregate gas demand from European companies and match it with the 
most competitive supply offers in time for the next storage filling season. After demand has been 
matched  with  supply,  companies  can  voluntarily  conclude  purchasing  contracts  with  the  gas 
suppliers, either individually or jointly. This is particularly beneficial for smaller companies and 

7 Council Regulation (EU) 2022/2576 enhancing solidarity through better coordination of gas purchases, reliable 
price benchmarks and exchanges of gas across borders, Official Journal L 335, 29.12.2022, p. 1. 

7 

 
 
 
 
 
 
 
 
                                                           
companies from landlocked countries with less global reach or negotiating power. Joint purchasing 
could also be beneficial for industry that consumes gas, like fertilisers and ceramics.  

To set up the joint purchasing mechanism, EU Member States, Energy Community Contracting 
Parties and industrial players from the EU join forces in different fora in order to provide their 
expertise and advice to the Commission. They do so through an ad hoc steering board, regional 
groups and an industry advisory group. 

6.  Overview of the time needed for the certification procedure 

Member  States  should  ensure  that  each  storage  system  operator,  including  storage  system 
operators  that  are  controlled  by  transmission  system  operators,  is  certified  by  the  national 
regulatory authority or by another authority designated by the Member State. This is to ensure that 
the security of energy supply or any other essential security interest in the EU or any Member State 
is not endangered by influence over the storage system operator.  

The Storage Regulation provides that the certifying authority issues a draft certification decision   
on storage system operators that operate underground gas storage facilities with a capacity of over 
3.5  TWh  where,  irrespective  of  the  number  of  storage  system  operators,  total  storage  facilities 
were filled on 31 March 2021 and on 31 March 2022 at a level which, on average, was less than 
30 % of their maximum capacity or within 150 working days of the date of receipt of a notification. 
For  these  storage  sites,  the  certifying  authority  should  have  already  attempted  to  issue  a  draft 
certification decision by 1 November 2022. 

For  all other storage system operators, the certifying authority  has  to  issue a draft  certification 
decision by 2 January 2024 or within 18 months of the date of receipt of a notification. 

The  Commission  has  to  deliver  an  opinion  on  the  draft  certification  decision  to  the  certifying 
authority within 25 working days of such a notification. The certifying authority must then take 
the utmost account of the Commission’s opinion. 

The certifying authority has to issue the certification decision within 25 working days of receipt 
of the Commission’s opinion. 

In 2022, only one draft certification decision was submitted to the Commission, by the Belgian 
Federal Commission for Electricity and Gas Regulation (CREG) in October 2022.  

To support Member States with issuing draft certifications, the Commission organised a special 
session of the Gas Coordination Group to provide certifying storage operators and owners with 
practical  guidance.  The  Commission  recalled  that  certification  should  reduce  any  risk  to  the 
security of gas supply at regional, national or EU-wide level resulting among other things from:  

(a) ownership, supply or other commercial relationships that could negatively affect the incentives 
and ability of the storage system operator to fill the underground gas storage facility; 

(b)  the  rights  and  obligations  of  the  EU  with  respect  to  a  non-EU  country  arising  under 
international law, including any agreement concluded with one or more non-EU countries to which 
the EU is a party and that addresses the issue of the security of energy supply;  

8 

 
 
 
 
 
(c) the rights and obligations of the Member States concerned with respect to a non-EU country 
arising under agreements concluded by the Member States concerned with one or more non-EU 
countries, in so far as those agreements comply with EU law; or 

(d) any other specific facts and circumstances of the case. 

Emphasis  is  put  on  the  risk  of  security  of  supply  stemming  from  the  ownership  that  could 
negatively  affect  the  ability  to  fill  the  storage  facilities.  One  central  element  for  the  draft 
certification decision is the concept of ‘decisive influence’, which is the ownership or right to use 
all or part of the assets of an undertaking, or rights or contracts that confer decisive influence on 
the composition, voting or decisions of the organs of an undertaking. 

7.  Overview of the measures requested by the Commission to ensure compliance with 

the filling trajectories and filling targets 

The Gas Storage Regulation provides for a monitoring and enforcement mechanism to keep track 
of filling levels in Member States. It ensures continuous progress in refilling storage while leaving 
a certain degree of flexibility to inject more or less gas depending on the market prices at the time. 
This  requirement  introduces  intermediary  two  months  targets,  but  allows  a  deviation  within  a  
tolerance margin of 5 %.  

If a Member State deviates in  a substantial and sustained way from the filling trajectory and it 
endangers the filling target, the Commission will, after consulting the Gas Coordination Group 
and the Member States concerned, issue a Recommendation to that Member State or to the other 
Member States concerned on measures to be taken immediately. If there are continued failures on 
respecting the minimum filling targets following the Recommendation, the Commission may issue 
a Decision on the follow-up. 

All Member States complied with the intermediary targets set for 2022 and their minimum filling 
level did not experience a substantial nor sustained deviation  from the target. The Commission 
therefore did not have to take measures in 2022 to ensure compliance with the filling trajectories 
and filling targets.  

On 25 November 2022, the Commission set out by means of an Implementing Regulation8 the 
intermediate gas storage filling targets that Member States must meet in 2023 in order to reach the 
90% gas storage target by 1 November 2023. As envisaged under the Gas Storage Regulation, the 
Implementing Regulation defined the intermediate targets  for 1  February,  1 May,  1 July and  1 
September  2023  for  those  Member  States  with  underground  storage  on  their  territory  and 
connected to their market area. These targets were based on the proposals made by Member States, 
the filling rates of the previous 5 years and the Commission’s assessment of the general security 
of supply situation.  

8 Commission Implementing Regulation (EU) 2022/2301 of 23 November 2022 setting the filling trajectory with 
intermediary targets for 2023 for each Member State with underground gas storage facilities on its territory and 
directly interconnected to its market area (C/2022/8593) OJ L 305, 25.11.2022, pp. 5–8. 

9 

 
 
 
 
 
 
 
                                                           
The  Commission  also  consulted  the  Gas  Coordination  Group  and  the  recently  established  Gas 
Storage Committee. Also for the year 2023, subject to a margin of five percentage points, these 
binding targets are the minimum thresholds that need to be respected by Member States to ensure 
a certain level of security of supply and the refilling of storage facilities for winter 2023-2024. 

Table:  Intermediate targets for 2023 for Member States with underground gas storage facilities, 

as adopted by Commission Implementing Regulation (EU) 2022/2301  

Member 
State 

AT 
BE 
BG 
CZ 
DE 
DK 
ES 
FR 
HR 
HU 
IT 
LV 
NL 
PL 
PT 
RO 
SE 
SK 

1 February 
intermediate 
target 
49% 
30% 
45% 
45% 
45% 
45% 
59% 
41% 
46% 
51% 
45% 
45% 
49% 
45% 
70% 
40% 
45% 
45% 

1 May 
intermediate 
target 
37% 
5% 
29% 
25% 
10% 
40% 
62% 
7% 
29% 
37% 
36% 
41% 
34% 
30% 
70% 
41% 
5% 
25% 

1 July 
intermediate 
target 
52% 
40% 
49% 
30% 
30% 
60% 
68% 
35% 
51% 
65% 
54% 
63% 
56% 
50% 
80% 
67% 
5% 
27% 

1 September 
intermediate 
target 
67% 
78% 
71% 
60% 
65% 
80% 
76% 
81% 
83% 
86% 
72% 
90% 
78% 
70% 
80% 
88% 
5% 
67% 

To set the filling levels, the Commission considered the estimates of Member States and an assessment of 
the minimum technical level required, taking into account the filling and withdrawing capacity of each site 
in order to reach a level of 90% by 1 November 2023.  

8.  Analysis of the potential effects on gas prices and gas savings  

A rigorous causal analysis would require data from a counterfactual scenario, where the Storage 
Regulation did not exist but other factors (e.g. global developments) that influence European gas 
supply  and  demand  during  the  period  in  which  the  Storage  Regulation  has  been  in  force  were 

10 

 
 
 
 
 
 
 
 
 
unchanged. Information for a counterfactual scenario was not available in a sufficiently detailed 
manner. Accordingly, the Commission has carried out a prescriptive and less causal analysis.  

Although the highest price peak occurred in mid/late August, no direct link could be established 
between the filling of gas storages and the price increase. For instance, the price spikes occurred 
at a moment of rather usual and flat storage injection rates. In contrast, when getting closer to the 
final deadline for meeting the filling target on 1st November, which resulted in additional efforts 
for storing gas due to the start of the heating season, prices were already substantially lower in 
October and November compared to the preceding months. 

The  figure  below  shows  the  ratio  of  2022  values  over  the  2019-2021  average  for  both  storage 
injections and prices. A price ratio of 1 means that the 2022 prices were equal to the 2019-2021 
average. A ratio greater than 1 means that prices were higher in 2022; a ratio of 5 means that prices 
were five times higher in 2022 than the 2019-2021 average. The same calculation applies to the 
line on storage injection. 

According to this figure, the relative price peaks did not coincide with relative storage injection 
peaks.  In  contrast,  available  data  indicate  that  supply  fluctuations  may  have  played  a  more 
significant role in price spikes of gas.  

Nevertheless,  we  cannot  exclude  that  resolute  storage  filling  by  operators  with  or  without 
regulatory interventions from Member States as part of the Storage Regulation has facilitated a 
temporary  overshooting  of  prices.  The  Commission  is  aware  of  claims  that  a  more  gradual 
replenishment of storage, including by using the flexibility left by the 2022 intermediary targets 
set at EU level, could have helped mitigate the price developments.  

Based on available data, no clear conclusions on a potential link between the storage targets and 
price developments are possible. The continued injection of storage reduced the risk of potentially 
lowering storage levels to a dangerous level. 

The  staff  working  document  that  accompanies  this  report  provides  further  details  on  the 
methodology and quantitative results of the analysis.  

11 

 
 
 
 
 
 
Furthermore, following the adoption of the Regulation on Gas Demand Reduction9, Member States 
reduced their gas demand by 19% between August 2022 and January 2023 compared to the average 
of the last 5 years (see figure below). This significantly made up for the lack of Russian gas, with 
42  billion  cubic  metres  of  gas  saved  between  August  2022  and  January  2023,  and  provided 
flexibility  to  the  gas  market.  Against  a  background  of  tension  on  the  gas  market,  it  was 
acknowledged at the Gas Coordination Group meeting in February 2023 that demand reduction 
was the most efficient measure as the increase of supply is limited by global production capacities 
and is subject to global competition. 

Over  the  summer  of  2022,  demand  reduction  facilitated  storage  injections,  while  the  demand 
reduction  measures  limited  withdrawals  during  winter  2022/2023.  This  therefore  ensured  there 
were sufficient storage levels to cope with winter cold spells. 

Since the beginning of winter 2022/2023, the flexibility created by demand reduction therefore 
helped drive gas prices down from record highs to pre-war levels in February 2023.   

9 Council Regulation (EU) 2022/1369 of 5 August 2022 on coordinated demand-reduction measures for gas 
ST/11568/2022/INIT, OJ L 206, 8.8.2022, pp. 1-10. 

12 

 
 
 
 
 
 
 
 
                                                           
9.  Conclusion 

Member  States  made  substantial  and  unprecedented  efforts  in  2022  to  refill  storage.  The  80% 
target of the EU Storage Regulation for 2022 was exceeded. By 1 November 2022, 94.9% of the 
EU’s gas storage was filled. At the end of 2022, the average level was still high, at 83.4%. This 
high level of filling greatly helped strengthen the security of supply in winter 2022/23, which in 
turn reduced the risk premium in the gas market at the end of the year. 

Member States took all necessary measures to meet the filling targets, including the intermediary 
targets. Some Member States reached filling levels well above their targets. All Member States 
reached  their  minimum  EU  filling  trajectories  and  filling  targets  in  2022.  The  mechanism  of 
minimum intermediary targets has helped leave ample room for Member States to set their own 
measures.   

All Member States with storage used a basket of measures, as provided in the Storage Regulation. 
The weight of the different measures differs between Member States. As a first choice they used 
market-based  measures.  Further  preferred  measures  included  the  obligation  to  store  some 
minimum  volumes  of  gas,  the  tendering  of  capacities  to  market  participants,  together  with 
incentives to fill the storage facilities and ensure that the contracted capacities are effectively used.  

With the obligation to certify storage operators and owners, the Storage Regulation aimed to help 
avoid any detrimental influence of non-EU countries on the filling of storage sites. In 2022, one 
draft certification was submitted to the Commission, followed by a positive opinion. 

Although no  other  storage  sites  have been certified,  Member States have taken measures  at  an 
early stage to prevent non-EU countries from negatively influencing the filling of storage sites. 

13 

 
 
 
 
 
 
 
They reported on storage owners being nationalised and the appointment of state entities in charge 
of the filling. Even though Member States still need to submit their draft certification decisions to 
the Commission, there is currently no evidence that filling storage facilities for security of supply 
is still at risk. Most of the certifications will have to be issued in 2023 to ensure the absence of 
detrimental influence on storage owners and operators. 

Based on available data, it is impossible to conclude whether and to what extent the filling targets 
set by the Gas Storage Regulation have had an effect on gas prices. They depend on many non-
storage related factors such as pipeline supplies, LNG availability, gas savings, the weather and 
the premium linked to the security of supply risks perceived by the market. Based on contributions 
received, there seems to be scope for national measures that implement the EU targets in more 
efficient ways to avoid filling trajectories that influence price development in a negative manner. 

With the Storage Regulation, this is the first time that Member States undertake and implement 
storage measures in a common framework that enables and encourages combinations of market-
based and regulatory measures to ensure a minimum level of filling. Even if it is still limited, this 
is also the first time that Member States develop specific arrangements to share storage resources 
and related costs across borders. At the end of winter 2022/2023, the Commission intends to ask 
Member States to report on their experiences with these arrangements.  

14