COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMANT 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  SWD(2023) 73 final  COMMISSION STAFF WORKING DOCUMENT       Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMANT AND THE COUNCIL on certain aspects concerning gas storage based on Regulation (EU) 2017/1938 of the European Parliament and of the Council   {COM(2023) 182 final}  
 
 
The staff working document provides additional details on the: 

  measures taken by Member States to achieve their filling targets, and 
  analytical  background  assessing  the  potential  effects  of  storage  requirements  on  the 

market price of gas in the EU. 

Part 1 

Measures to ensure the Member States’ storage sites are filled 

1. 

Examples of measures listed under the Storage Regulation1(Article 6b(1)) 

Article 6b(1) of the Storage Regulation states that Member States must take all measures 
needed to meet the gas filling targets set out in Article 6a. These measures may include: 

(a) requiring gas suppliers to store minimum volumes of gas in storage facilities, including 
in underground gas storage facilities and/or in LNG storage facilities, those volumes to be 
determined  on  the  basis  of  the  amount  of  gas  supplied  by  gas  suppliers  to  protected 
customers; 

(b) requiring storage system operators to tender their capacities to market participants; 

(c) requiring transmission system operators or entities designated by the Member State to 
purchase  and  manage  balancing  stock  exclusively  for  carrying  out  their  functions  as 
transmission  system  operators  and,  where  necessary,  imposing  an  obligation  on  other 
designated entities for the purpose of safeguarding the security of gas supply in the case of 
an emergency; 

(d) using coordinated instruments, such as platforms for the purchase of LNG, with other 
Member  States  to  maximise  the  utilisation  of  LNG  and  to  reduce  infrastructure  and 
regulatory barriers to the shared use of LNG to fill underground gas storage facilities; 

(e) using voluntary mechanisms for the joint procurement of natural gas; 

(f)  providing  financial  incentives  for  market  participants,  including  for  storage  system 
operators,  such  as  contracts  for  difference,  or  providing  compensation  to  market 
participants  for  the  shortfall  in  revenues  or  for  costs  incurred  by  them  as  a  result  of 
obligations  on  market  participants,  including  storage  system  operators  which  cannot  be 
covered by revenue; 

1 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 (Text with EEA relevance) 
PE/24/2022/INIT, OJ L 173, 30.6.2022, p. 17–33 

1 

 
 
 
 
                                                           
(g) requiring storage capacity holders to use or release unused booked capacities, while 
still obliging the storage capacity holder not using the storage capacity to pay the agreed 
price for the whole term of the storage contract; 

(h) adopting effective instruments for the purchase and management of strategic storage by 
public or private entities, provided that such instruments do not distort competition or the 
proper functioning of the internal market; 

(i) appointing a dedicated entity tasked with meeting the filling target in the event that the 
filling target would not otherwise be met; 

(j) providing discounts on storage tariffs; 

(k)  collecting  the  revenues  needed  to  recover  the  capital  and  operational  expenditures 
related  to  regulated  storage  facilities  as  storage  tariffs  and  as  a  dedicated  charge 
incorporated  into  transmission  tariffs  collected  only  from  exit  points  to  final  customers 
located within the same Member States, provided that revenues collected through tariffs 
are not larger than the allowed revenues. 

2.  Summary and assessment of the measures taken by Member States to fulfil the 
storage obligations and assessment of their effectiveness 

The summary is based on the replies of Member States to a questionnaire. In this questionnaire, 
all Member States were invited to describe the main measures taken to meet the filling target, 
in particular the measures listed in Article 6b(1) of the Gas Storage Regulation. They were also 
asked how effective the measures to reach the filling targets have been. 

Not all Member States provided an answer to the questionnaire. 

Measure 

Adopted 
by  

Take-up of measure  

Impact 

Perceived 
Member State  

impact 

by 

BE  sets  no  minimum  storage 
to  maintain 
obligation,  so  as 
market  forces  on 
the  storage 
market.  

1: Major 
2: 
Significant 
3: Minor 
CZ: 3 
NL: 2 
BE: 3 
PT: 1 
ES: 1 
IT: 2 
SK: 2 

(As  suggested  in  6b 
of the Regulation) 

1  Minimum  volume 
in gas storage  

BE 
CZ 
DE 
ES 
HR 
HU 
IT 
LV 
PT 
SI 
SK 

PT:  sufficient  measure  to 
reach filling target. 

CZ:  supplies  for  protected 
customers  amount  to  5%  of 
storage capacity. 

IT:  early  measure  raising 
awareness of market players. 

NL,  BE,  DK:  burdensome 
for  gas  suppliers  to  supply 

2 

 
 
 
  
 
 
 
  
 
 
 
Tender 

2 
capacities  

of 

3.1  Balancing  stock 
managed by TSO  

AT 
BE 
CZ 
DE 
DK 
ES 
FR 
HR 
HU 
IT 
LV 
NL 
(part.) 
PT  
AT 
BE 
HR 
HU 
IT 
PT  

3.2 
imposed 
designated entities  

Obligations 
on 

AT 
CZ 
DE 
ES 
HU 
IT 
LV 
LT 
PT 
RO  

protected  customers.  Last 
resort measure.  
CZ,  NL:  tendering  storage 
capacity  is  not  enough  to 
ensure storage is filled. 

AT,  BE,  PT,  ES:  necessary 
condition  to  attract  market 
parties. 

only 

BE: 
volumes. 

limited 

gas 

PT: contributes to security of 
supply. 

CZ: balancing stock does not 
use  gas  storage  capacities, 
but accumulation of TSO. 

incentivises  market 
IT: 
participants  when 
price 
signals are not an incentive.  
DK:  state-owned  TSO  has 
experience 
in  procuring 
strategic  storage.  Imposing 
on  market 
obligations 
participants 
too 
burdensome.  

is 

This measure is taken via auctions 
in  all  Member  States  except  PT, 
where it is done by allocation. 

ES:  capacity  required  to  fulfil 
minimum  storage  obligations  is 
allocated  directly.  The  remaining 
storage  capacity 
is  allocated 
through auctions. 

CZ: 3 
NL: 3 
AT: 1 
BE: 1 
PT: 1 
ES: 2 
DK: 2 
IT: 3 

NL, LT, SI find it unnecessary to 
keep balancing stock. 

CZ: 3 
NL: 2-3 
AT: 2 
BE: 3 
PT: 1 
ES: 2 
IT: 2 

HU,  LV  have  state  entities  for 
strategic gas stock. 

PT: 1 

PT,  CZ,  ES,  RO  oblige  market 
parties 
to  maintain  minimum 
stocks of natural gas. 

applies 

IT 
information 
obligations to electricity TSO and 
infrastructure operators. 

NL,  BE,  SI  believe  security  of 
supply is best achieved by market 
forces. 

LT  obliges  designated  entities  to 
store  gas  earmarked  for  protected 
customers  and  for  the  production 
the  event  of 
in 
of  electricity 
isolated  operation  of  Lithuania’s 
electricity system. 

3 

 
 
 
 
  
 
 
 
 
  
 
  
 
 
 
 
 
 
 
Coordinated 

IT  

4 
instruments  

joint 

5  Voluntary 
procurement 
mechanisms  
6 
Financial 
for 
incentives 
market participants  

7  Unused  booked 
capacities  

None  

AT 
CZ 
DK 
ES 
NL 
(part.)  
AT 
BE 
CZ 
DE 
DK 
(under 
consider
ation) 
FR 
HR 
IT 

IT has signed a Memorandum of 
Understanding 
EL, 
allowing  EL  shippers  to  book 
storage capacity of up to 1.14 TWh 
in IT. 

with 

NL: 3 
BE: 2 
IT: 2 

CZ, NL, LT, PT, SI, SK consider 
the current purchasing system to 
be sufficient. 

BE  reports  that  it  does  not  yet 
apply such instruments. 

AT: A small share of the strategic 
gas reserve is currently stored in a 
Slovakian  gas  storage  facility. 
Strategic  and  commercial  gas 
volumes  from  other  countries  can 
of course be stored in Austrian gas 
storage facilities and are. 
Same response as for measure 4.   BE: 2 

NL,  ES,  DK  incentivise  market 
participants to fill gas storages. 

NL: 2 
BE: 1 
DK: 2 

NL:  no  link  with  filling  of 
gas storage. 

IT:  reduces 
the  financial 
exposure  of  gas  market 
players  when 
is 
volatility  on  the  EU  gas 
market.  

there 

NL:  this  is  up  to  market 
participants.  

BE, DK: helps attract market 
participants. 

subsidises 

AT 
diversify gas procurement.  

companies 

to 

NL: should only be measure 
of last resort.  

NL: can prevent hoarding of 
storage capacity, but it does 
not help reach filling targets. 

CZ:  UIOLI  discourages 
booking 
storage 
of 
capacities and it degrades the 
commercial  value  of  gas 
storage. 

ES:  contracted  and  unused 
volumes are very small.  

BE  applies 
if  market 
fines 
participants  do  not  fill  booked 
storage. 

CZ  applies  “UIOLI”  rules  on  gas 
storage capacities. 

CZ: 2 
NL: 2 
BE: 2 
HR: 1 
ES: 3 
IT: 1 

AT: 
the  storage  entity  must 
temporarily deprive storage user of 
unused capacities. 

FR compels gas suppliers that have 
booked  capacities 
in  essential 
underground  gas  storage  facilities 
to  fill  these  capacities  to  at  least 
85%  by  November  1.  Failure  to 
comply  with  this  obligation  can 
lead to a fine up to twice the value 
of the missing gas. 

4 

 
 
 
 
 
  
 
  
 
 
 
  
 
  
 
 
 
 
 
  
 
 
8 Strategic storage   AT 
CZ 
DK 
ES 
HU 
IT 
LV 

CZ:  insufficient  amount  of 
strategic 
reserves,  more 
financial  resources  and/or 
financial  tools  required  to 
expand strategic storage. 

from 

AT:  Strategic  gas  reserves 
cover  demand 
the 
previous January and can be 
topped  up.  In  2022,  the 
reserve was topped up to 20 
TWh and thus covered more 
than 20% of annual demand. 

NL, BE: expensive, provide 
little added value. 

ES:  operators 
supplying 
final  customers  are  best 
placed  to  build  up  strategic 
reserves. 

DK: state-owned TSO holds 
strategic stock.  

HR  automatically  cedes  unused 
capacity  to  other  storage  entities, 
or to the state energy entity HEP. 

ES:  unused  capacity  in  excess  of 
27.5 days of consumption does not 
benefit  from  the  capacity  tariff 
discount. 
All  these  countries  have  procured 
(or are procuring) a state strategic 
reserve 
the 
government in case of emergency. 

to  be  used  by 

CZ: 2 
NL: 3 
BE: 3 
ES: 3 
DK: 1 

NL,  BE  do  not  see  the  added 
value of strategic storage. 

CZ  has  a  state-controlled  reserve 
of 2.3 TWh, designed  exclusively 
to supply protected customers. 

HR  considers  its  storage  capacity 
too small for strategic storage. 

(CORES) 

In  ES,  the  strategic  stockholding 
is 
organisation 
authorised to store gas, but has not 
seen the need to do so yet. In ES, 
storage  is  filled  by  commercial 
parties. Additionally  and  in  the 
event  of  an  emergency,  Enagas 
GTS is able to buy gas to fulfil the 
underground  storage  targets  set 
under  the  COM if  necessary  after 
approval of the Royal Decree Law 
6/2022 and 20/2022. 

is  considering  a  strategic 

PT 
reserve, form as yet unknown. 

AT  obliged  the  distribution  area 
manager  to  procure  the  strategic 
gas  reserve  and  the  distribution 
area manager is also the owner of 
the strategic gas reserve. AT aims 
to increase strategic storage levels 
to 20 TWh – or the equivalent of 2 
winter months’ consumption. 

LV  Ministry  of  Economics  has 
initiated  the  creation  of  Energy 

5 

 
 
 
  
 
 
 
 
 
 
 
 
  
 
 
 
 
9  Appointment  of  a 
dedicated entity  

BE 
(under 
discussio
n) 
DE 
ES 
HR 
IT 
NL 
SE 
(under 
discussio
n) 
SK 

Security Reserves. Goal: 1.8 – 2.2 
TWh in 2023. 
NL has granted a subsidy for state-
owned  entity  EBN 
to  ensure 
filling,  in  the  event  the  subsidy 
scheme  for  capacity  holders  does 
not deliver. 

DE: 1 
NL: 2 
BE: 2 
HR: 1- 

DE:  essential  instrument  to 
ensure targets are reached. 

NL,  BE:  this  should  be  a 
measure of last resort.  

DE’s  market  area  manager  takes 
over storage capacity of users who 
do not reach filling target alone. 

HR  state  energy  entity  HEP  has 
reached  an  agreement  with  two 
entities, which volunteered to cede 
capacity to the state entity. 

SE 
is  currently  discussing  an 
obligation  to  the  TSO  to  ensure 
filling  of  the  gas  storage,  as  a 
measure of last resort. 

ES  has  already  incorporated  this 
measure  in  national  Law (DT2  of 
the Royal Decree Law 6/2022), so 
it  is  no  longer  under  discussion. 
Now the Technical Manager of the 
System (Enagas GTS) is entitled to 
acquire gas for storage, in the event 
that traders fail to inject sufficient 
gas to meet the requirements. 

SK  ministry  of  Economy  can  fill 
storage  through  the  largest  gas 
entity  in the  country,  in  the  event 
that market participants do not fill 
the storage to the required level. 

10 Discounts storage 
tariffs  

BE 
DK 
ES 
IT  

Countries  that  do  not  take  this 
measure  point  out 
they  have 
reached filling targets.  
CZ, NL, AT: no regulated storage 
tariffs,  storages  operate  based  on 
negotiated third party access. 

NL: 3 
BE: 1 
ES: 2 
DK: 3  

ES  has  a  transitional  measure  for 
this from 1 April 2022 to 31 March 
2024.  Storage  capacity  contracted 
for  more  than  20  days  of  firm 

NL: 
little  added  value, 
damaging to business model 
of storage system operators. 

ES: 

BE, 
incentivising 
market  participants  to  buy 
storage  capacity,  combined 
with measures 2 and 6. 

6 

 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
11  Capital 
operational 
expenditures  

and 

CZ 
ES 
HU 
IT 
LV 

consumption  will  be  charged  a 
zero tariff for storage.  
IT:  storage  costs  covered  by 
auctions revenue. Remaining costs 
are  covered  by  the  transmission 
tariff  on  exit  points  to  reach 
national final consumers. 

NL: 3 
ES: 2  

DK:  zero  tariffs  for  storage 
are helpful, but not pivotal.  
CZ,  NL:  no 
regulated 
storage facilities. 

LV: storage has its own tariffs, set 
by government agency. 

ES  calculates  storage  service  fees 
on  an  annual  basis,  based  on 
expected  demand,  capital  and 
operating costs. 

into 

account 

the  recognised  costs  are 
HU: 
calculated on a case-by-case basis, 
taking 
the 
committed/expected  capacities,  to 
achieve  the  sales  revenue  needed 
for  operation,  based  on 
the 
methodical  guide  to  calculating 
fees. 

NL: no need for this.  

7 

 
 
  
 
 
 
 
 
 
 
Analysis of gas prices, gas consumption, storage levels and storage injections 

Part II 

A.  Introduction 

The purpose of this document is to analyse the extent to which the Storage Regulation may have influenced 
(i) gas consumption (or gas savings); and (ii) gas prices, in addition to its impact on storage filling levels 
and storage injections. 

This document provides a descriptive analysis of the different variables, which may help shed some light 
and provide some detail on the circumstances affecting gas prices, consumption and storage. 

B.  Analysis 

First, we analyse EU gas consumption, gas prices, storage levels and storage injections individually. 

Consumption 

Figure 1: Monthly gas consumption in petajoules 

8 

 
 
 
 
 
 
Figure 1 shows that, since May 2022, EU domestic gas consumption has been below the monthly average 
over the five preceding years, and that the gap has gradually widened. For the later months of the year, gas 
consumption was substantially lower than even in the lowest recent year for that month. This finding is 
confirmed by Table 1, which shows that gas consumption in the first 4 months of the year was roughly in 
line with the previous years’ average, before falling to a significantly lower level. 

Table 1: Monthly gas consumption in petajoules 

Month 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 

2017 
2211 
1606 
1401 
1167 
954 
835 
889 
815 
948 
1162 
1647 
1855 

2018 
1762 
1891 
1732 
1003 
838 
815 
816 
813 
890 
1156 
1573 
1689 

2019 
2123 
1662 
1500 
1166 
1058 
821 
951 
849 
960 
1226 
1571 
1732 

2020 
1944 
1596 
1518 
968 
908 
856 
925 
872 
958 
1237 
1548 
1851 

2021 
2071 
1710 
1655 
1388 
1025 
840 
825 
769 
871 
1163 
1629 
1887 

2022  2017-2021 avg. 
2022 
1939 
1693 
1554 
1561 
1542 
1138 
1125 
957 
834 
833 
775 
881 
786 
824 
709 
925 
793 
1189 
902 
1594 
1214 
1803 
-  

2022 v avg. 
-4% 
-8% 
-1% 
-1% 
-13% 
-7% 
-11% 
-14% 
-14% 
-24% 
-24% 
-  

Source: ENER/CET based on Eurostat series nrg_cb_gasm in TJ (GCV) as of 4 Jan 2023, 11:00. 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Prices 

Figure 2: Month ahead Title Transfer Facility (TTF) gas prices (EUR/MWh) 

Figure 2 shows that prices remained rather flat in 2019-2020, with early 2020 prices being even lower than 
the previous years. Prices started to increase in the spring and summer of 2021 and then spiked dramatically 
(compared to past levels) several times, in: October 2021, December 2021, March 2022 and August 2022. 

The August 2022 price spike was the highest and longest lasting, beginning in early June and lasting until 
approximately mid-October. This would indicate that, even if the price rise was driven primarily by storage 
refilling, it was probably not caused by the Storage Regulation, which was adopted and entered into force 
at the end of June. 

Although the highest peak occurred in mid/late August, after the entry into force of the Storage Regulation, 
there are reasons to doubt that the Regulation caused the price spike: 

 
the first storage target is 1 November 2022, and prices had fallen substantially before that date; 
  Member  States  had  strong  incentives  to  fill  storage  levels  irrespective  of  the  EU  Storage 
Regulation,  and  several  Member  States  (including  the  EU’s  largest  gas  consumer,  Germany) 
adopted storage regulations of their own, in some instances stricter than the EU’s; 
there are other plausible explanations for the price peak (see Figure 5 and Figure 6). 

 

10 

 
 
 
 
Storage 

Figure 3: Storage levels (TWh) 

Figure 3 shows that, in January 2022, storages were at the lowest level for that month for six years. By the 
end of the withdrawal season, they were still low, but higher than in 2018. Since May 2022, storage levels 
increased essentially in line with past years (except 2019) until September 2022 (parallel lines). Thereafter, 
they increased faster and stayed higher than in past years until the end of November. 

This would suggest that the adoption of the Storage Regulation did not cause a faster than usual refilling of 
storage levels, as there was no change from the past trends in July or August. The higher storage levels in 
the autumn is more likely to have been caused by lower consumption due to the mild weather. 

Figure 4 below on storage injections confirms this explanation. 

11 

 
 
 
 
 
Figure 4: Storage injections (GWh/day) 

Storage injections were in line with past years except in May, October and early November, when they 
were higher. The increase seen in May was before the Storage Regulation was adopted, and in October 
and November it was after the price spike (see previous section) and therefore unlikely to have caused it. 

12 

 
 
 
 
 
Imports 

Figure 5: Monthly gas imports from Russia (bcm): LNG, pipeline and total supplies 

Figure 5 above plots the volume of gas imports from Russia in billion cubic metres (bcm). It shows that 
imports of LNG (blue line) have increased slowly since early 2018, while imports by pipeline (maroon line) 
have fallen sharply since early 2022. Total import volumes fell to about one-third of past average levels by 
mid-2022. 

Figure 6 below plots total monthly imports by year. It shows that imports from Russia have been below the 
past average range since October 2021, with the gap widening substantially from June 2022. 

Figure 2 shows that prices peaked in October 2021, December 2021, March 2022 and August 2022. The 
August 2022 peak was by far the highest and longest lasting, the upward trend having started in June 2022. 

The parallel trend in price increases and import volumes is striking. The initial drop in imports from Russia 
in October 2021 may explain the peak prices in October and December 2021, while the steep fall in imports 
from June 2022 may explain the beginning of the summer 2022 price peak2. 

2 The fourth peak identified in Figure 2, in March 2022, may be explained by the beginning of Russia’s war on Ukraine 
on 24 February 2022. 

13 

 
 
 
 
                                                           
Figure 6: Total monthly gas imports from Russia (billion cubic metres) 

Storage injections and prices 

Having analysed the different variables individually, we now analyse the combined effect of gas prices 
and gas storage injection levels. 

Figure 7 depicts the ratio of 2022 values over the 2019-2021 average, for both storage injections and 
prices. 

For example, a price ratio of 1 means that 2022 prices were equal to the 2019-2021 average. A ratio 
greater than 1 mean that prices were higher in 2022; a ratio of 5 would mean that prices were 5 times 
higher in 2022 than the 2019-2021 average. 

14 

 
 
 
 
Figure 7: Storage injections (blue) and prices (maroon) in 2022 relative to the 2019-2021 average 

Figure 7 shows that relative price peaks do not tally with relative storage injection peaks. 

Therefore, in summary: 

 

 

It is impossible to ascertain with certainty whether any reductions in gas use (i.e.  ‘gas savings’) 
were caused by the Storage Regulation or by high prices and a response to Russia’s war on Ukraine. 
It is impossible to ascertain with certainty whether any price increases were caused by the Storage 
Regulation or by the need to fill storages in response to reduced supplies from Russia3. 

Instead, by analysing the timeline of the Storage Regulation, consumption levels, prices, storage levels and 
injections, and imports, it's possible to collect evidence for and against different hypotheses. The evidence 
analysed supports the assessment made in Section C, but there is no statistical proof of causality. 

3 As well as a host of other factors, such as the weather, global demand and the availability of alternative electricity 
sources. 

15 

 
 
 
 
 
 
 
                                                           
C.  Data sources 

The following data were used in this analysis: 

  gas consumption (monthly): Eurostat series nrg_cb_gasm in TJ (GCV) as of 4 Jan 2023, 11:00; 
  gas prices (weekly): TTF month ahead in EUR/MWh from S&P Global Platts; 
  gas storage levels (daily): AGSI+ data as of 5 Dec 2022 in TWh; 
  gas storage injections (daily converted to weekly): AGSI+ data as of 5 Dec 2022 in GWh; 
  gas import volumes (monthly): ENTSOG and Refinitiv data in mcm, converted to bcm. 

To conduct the analysis, the data were processed as follows: 

  Data on storage injections were converted to weekly data by averaging across 7-day periods starting 
on  1  January  each  year.  This  serves  two  purposes:  (i)  it  makes  the  diagram  more  readable  by 
removing noise (excessive vertical movement); (ii) it makes the gas storage injection data directly 
comparable to the gas price data for the last section of the analysis. 

  The data for 29 February 2020 (the only leap year in the range) was removed for comparability. 

16