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: 2024-02-27
Institutions: Directorate-General for Energy, European Commission
Subjects: Community certification, EU energy policy, activity report, application of EU law, energy demand, gas supply, natural gas, price of energy, security of supply, storage of hydrocarbons

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.2.2024  COM(2024) 89 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       
 
 
1.  INTRODUCTION 

Article  17a  of  Regulation  (EU)  2017/1938,  as  inserted  by  Article  1(5)  of  the  Regulation  (EU) 
2022/1032, hereafter the “Gas Storage Regulation”, states that the Commission has to submit 
annual  reports  to  the  European  Parliament  and  the  Council,  so  that  each  report  contributes  to 
broadening the knowledge base on best practices for filling gas storage sites in the Union. 

Underground gas storages (UGS) are instrumental to the security of energy supply of the EU. They 
provide essential seasonal flexibility to the EU gas system in winter. On cold periods, gas storages 
can  be  the  main  gas  supply  source.  Gas  storages  also  provide  the  electricity  system  with  a 
dispatchable energy source for power generation. Typically, storages provide 25-30% of the gas 
consumed in the EU during winter. Furthermore, gas storages enable an efficient design of the EU 
gas  system  by  reducing  the  need  of  high  import  flows  during  the  winter  months  and  prevent 
oversized import and transmission infrastructure. Gas imports are therefore rather stable over the 
year with surplus of imports injected during the summer period (April to October/November) while 
storage  withdrawals  complement  gas  imports  during  the  winter  period  (October/November  to 
March).  Gas  storages  therefore  contribute  to  price  stability  thanks  to  their  long-term  storage 
capabilities, and they contribute to absorbing supply shocks with their significant capacity (1100 
TWh or 100 bcm).  

In 2021, the EU experienced a prolonged period of volatile and high energy prices due to lower-
than-usual  storage  filling  levels,  among  other  factors.  The  increased  geopolitical  tensions  after 
Russia’s invasion of Ukraine in the beginning of 2022 amplified uncertainties and highlighted the 
need for well-filled gas storage for future winters.  

The amendments introduced by the Gas Storage Regulation, require all Member States with gas 
storage capacity to ensure their underground gas storages are filled up to 90% by 1 November of 
each year. Member States without gas storages are also required to contribute to the overall storage 
objectives by ensuring 15% of their annual consumption is stored in other Member States. 

Gas storage facilities are critical infrastructure in the meaning of Directive (EU) 2022/2557 on the 
resilience of critical entities and system storage operators falls within the scope of the directive.1 
Apart from that, all Storage System Operators (SSOs) in the EU have to go through a certification 
process by the beginning of 2024 at the latest, to reduce the risks of negative external interference. 
The Commission services have already received certifications from several Member States and are 
issuing  the  related  opinions.  This  report  takes  stock  of  the  implementation  of  the  Gas  Storage 
Regulation  in  2023  and  beginning  of  2024  based  on  information  provided  by  Member  States 
regarding gas storage measures and their certification procedures, in accordance with Article 17a 
of Regulation (EU) 2017/1938. 

1 As defined by  Directive (EU) 2022/2557 on the resilience of critical entities,  ‘critical infrastructure’ means an asset, 
a facility, equipment, a network or a system, or a part of an asset, a facility, equipment, a network or a system, which 
is necessary for the provision of an essential service; according to the Annex of the Directive, Storage system operators 
(SSOs) fall furthermore in its scope as types of entities in energy sector, sub-sector gas.  

1 

 
 
 
 
 
 
 
 
2.  LEGAL BASIS AND CONTEXT  

On 1 November 2023, gas storages in the EU were 99.4% full, well above the 90% target. All 
Member  States  achieved  their  regulatory  targets2  individually.  At  the  end  of  2023,  i.e.  on  15 
December 2023, gas storages were still 89% full. The EU entered winter 2023/2024 well prepared, 
considering that gas storages provide 25-30% of the EU gas demand during winter. 
Article  17a  of  Regulation  (EU)  2017/1938,  inserted  by  Article  1(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 

The amendments introduced by the Gas Storage Regulation provide that Member States must 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 and non-exhaustive list of potential measures and 
tools. The Commission sent a survey to Member State authorities in autumn 2023, to collect the 
measures  and  tools  they  have  used  to  ensure  that  their  storage  sites  were  filled.  The  measures 
adopted by Member States also included agreements, Memoranda of Understanding (MoUs), or 
burden-sharing mechanisms signed by Member States without UGS that include arrangements for 
utilisation of underground storage facilities. 
The Member States with underground gas storage confirmed that most measures in force in 2022 
were continued in 2023. Some of the measures existed prior to the gas storage Regulation of 2022, 
while others were established after the gas storage Regulation. Demand reduction contributed to 
favourable market conditions during the 2023 injection season, with lower gas prices compared to 
2022 and positive summer-winter spread, which eased the effective filling of the storage sites in 
time with no need to enforce the measures of last resort that were used during injection season in 
2022.  Member  States  also  generally  underlined  the  importance  of  flexible  intermediary  filling 
targets to provide a balance between ensuring the technical feasibility of the trajectory and offering 
market flexibility to storage users. 
Among the most common measures implemented by Member States were:  
-  Minimum volume in gas storage: imposing an obligation on SSOs on the minimum filling level 

to achieve, in line with the national objective; 

2 Regulation (EU) 2022/1032 amending Regulations (EU) 2017/1938 and (EC) No 715/2009. 

2 

 
 
 
 
 
 
-  Tender capacities: requiring SSOs to tender the capacities to market participants (via capacity 

auctions in most cases); 

-  Appointment  of  a  dedicated  entity:  designating  an  entity  to  provide  a  last  resort  service  for 

storage; 

-  Strategic storage: adopting effective instruments for the purchase and management of strategic 

stocks by public or private entities; 

-  Unused booked capacities: ensuring that the capacities booked are effectively used by applying 

use-it-or-lose-it congestion mechanisms to release booked but unused storage capacities. 

On the gas storage implementation also ACER, in its opinion on ENTSOG Winter Supply Outlook 
2023-20243,  “welcomes  that  the  EU  collective  90%  storage  filling  rate  objective  was  already 
achieved in mid-August, nearly 2-months ahead of the 1 of November deadline. Where possible, 
NRAs have checked the accuracy of storage filling levels reported in ENTSOG’s Winter Outlook.” 
ACER further reports that “The recently published ACER consultancy study “On the impact of EU 
and national gas storage regulations” shows that the measures implemented in the Members States 
effectively helped to reach the storage filling levels at national and European level.” 

Further details on the implementation measures are provided by Table 1 and Annex. 

Table 1 – Measures on implementation of filling targets  as of  Article  6b of the Gas Storage Regulation  per 
Member State with Underground Gas Storage (UGS)  

T means temporary measure 
Source: Member States' responses to EC survey and ACER and VIS gas storage report 2023 

The burden-sharing mechanism, as identified by the Article 6c of the Regulation, provides that 
Member States without storage facilities on their territories store gas volumes in other Member 
States corresponding to at least 15% of their annual consumption. 

3 OPINION No 11/2023 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY 
REGULATORS of 14 December 2023 on ENTSOG’s Winter Supply Outlook 2023/2024, ACER_Opinion_11-
2023_on_ENTSOG_Winter_Supply_Outlook_2023-2024.pdf (europa.eu). 

3 

 
 
 
 
 
 
 
 
 
The Commission survey indicates that in 2023 the burden sharing mechanism has been applied in 
at least three Member States without gas storage facilities. Estonia arranged the purchase of 1 TWh 
(30% of the annual consumption) as a national strategic reserve to be stored in Latvia. Lithuania 
confirmed it stored ca. 2.05 TWh stored in Latvia, equivalent to the average usage of the preceding 
5 years. Slovenia also confirmed that its suppliers store gas on commercial basis corresponding to 
15% of the previous 5-year consumption.  

At the end of the winter 2022-2023, EU storage were 56% full. This higher-than-average level has 
been significantly supported by a reduced gas demand of 18% which participated to the favourable 
market conditions that ease the refilling. In 2023, 505 TWh (around 45 bcm) of gas was stored as 
a result of storage measures. Around 60% of the gas stored during the summer 2023 was injected 
in the months of May-July (see Figure 1), probably incentivised by the drop of gas prices at the 
beginning  of  the  injection  season.  This  early  injection  was  decisive  to  achieve  the  90%  filling 
target by mid-August, more than 2 months in advance. By 1 November 2023, EU’s gas storage 
was 99.4% full, with all Member States exceeding the 90% filling target (Figure 2). 

Figure 1 - Net injections in EU gas storages by month  

Figure 2 - Gas in EU underground storages in the year 2022 and year 2023, in comparison with the previous 
6-year average and range.

4 

 
 
 
 
 
 
 
 
4.  OVERVIEW OF THE CERTIFICATION PROCEDURE 

According  to  Article 3a  of  the  Regulation  (EC)  No  715/2009,  as  inserted  by  the  Gas  Storage 
Regulation, Member States have to ensure that each storage system operator, including any storage 
system  operator  controlled  by  a  transmission  system  operator,  is  certified.  In  this  context,  the 
certifying authorities of Member States have to issue a draft certification decision in respect of 
storage system operators that operate underground gas storage facilities with a capacity of over 3.5 
TWh where, regardless  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 by 1 February 2023.  The certifying authority  has  to  notify its draft 
certification decision to the Commission without delay, together with all relevant information, so 
that the Commission shall deliver an opinion on the draft certification decision to the certifying 
authority.  
In  2023,  several  Member  States  submitted  draft  decisions  for  the  certification  of  gas  Storage 
System Operators (SSOs) to the Commission. The Commission adopted ten certification opinions 
which,  after  the  confidentiality  check  by  the  certifying  authority,  were  published  in  the 
Commission’s  Transparency  Registry  and  on  DG  ENER  website.  The  Commission  is  still 
receiving draft certification decisions and is in close contact with the Member States experiencing 
delays in submitting their draft decisions. The Commission notes that  many Member States, in 
particular those with a high number of sites, are actively working on the certification process. It is 
important to make timely progress to ensure a proper implementation of the Storage Regulation 
and strengthen the EU security of supply.  

Table 2 – Overview of the certification procedure at the end of 20234,5 

Draft certifications notified by 
Nº Operators (Nº sites ) 

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

1 (1) 
1 (1) 

1 (2) 
2 (4) 
3 (16) 
1 (1) 
2 (5) 

1 (1) 
3 (4) 
1 (7) 
1 (1) 
2 (6) 
1(1) 
2 (2) 

Pending draft 
certifications  
Nº Operators (Nº sites ) 
3 (7) 

1 (1) 
4 (9) 
25 (50) 

3 (13) 

1 (3) 

Total 
Nº Operators (Nº 
sites)[2] 
4 (8) 
1 (1) 
1 (1) 
4 (9) 
25 (50) 
1 (2) 
2 (4) 
3 (16) 
1 (1) 
2 (5) 
3 (13) 
1 (1) 
4 (7) 
1 (7) 
1 (1) 
2 (6) 
1 (1) 
2 (2) 

4 The certifications are issued by operator and/or by storage site. 
5 Based on exchange with MSs, GIE AGSI+ and ACER and VIS Gas Storage report 2023. 

5 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TOTAL 

22(52) 

37 (83) 

59 (135) 

To  support  Member  States  with  the  issuance  of  draft  certifications,  the  Commission  organised 
special sessions of the Gas Coordination Group to provide practical guidance for certifying SSOs 
and storage owners. The Commission recalled that the certification should reduce risk for security 
of gas supply at regional, national, or Union-wide level resulting, inter alia, from:  

a)  ownership, supply or other commercial relationships that could negatively affect the incentives 
and the ability of the storage system operator to fill the underground gas storage facility; 
b)  the  rights  and  obligations  of  the  Union  with  respect  to  a  third  country  arising  under 
international  law,  including  any  agreement  concluded  with  one  or  more  third  countries  to 
which the Union is a party, and which addresses the issue of the security of energy supply;  
c)  the  rights  and  obligations  of  the  Member  States  concerned  with  respect  to  a  third  country 
arising under agreements concluded by the Member States concerned with one or more third 
countries, in so far as those agreements comply with Union law; or 

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

5.  COMPLIANCE WITH THE STORAGE FILLING OBJECTIVES  

In order to ensure security of gas supply over the years and to comply with the gas storage target 
of  90%  on  1 November  of  each  year,  the  Gas  Storage  Regulation  has  conferred  implementing 
powers to the Commission to set the filling trajectory for each Member State with underground 
gas storage facilities from 2023 and the following years, as based on the draft filling trajectory 
submitted by each such Member State. In 2023, according to Article 6a of the Regulation (EU) 
2017/1938,  as  inserted  by  the  Gas  Storage  Regulation,  all  Member  States  complied  with  the 
intermediate targets set for 2023 by the Implementing Regulation (EU/2022/2301), adopted on 23 
November  2022.  Several  Member  States  reached  100%  (or  surpassed  their  declared  capacity6) 
before the 1 November 2023. The Commission therefore did not have to take measures in 2023 to 
ensure compliance with the filling trajectories and filling targets.  

6 The physical storage capacity of some storage facilities could, under certain conditions, be higher than the working 
gas volume reported by the storage operators. 

6 

 
 
 
 
 
 
 
 
 
 
 
Table 3 - Compliance with the filling targets of storage Regulation for 2023 

Source: filling levels based on GIE AGSI+ 
On 20 November 2023, the Commission set out, by means of an Implementing Regulation7, the 
intermediate gas storage filling targets that Member States must meet in 2024. As envisaged under 
Article 6a(7) of the Regulation (EU) 2017/1938, as inserted by the Gas Storage Regulation, the 
Implementing Regulation defines the intermediate targets for each of 1 February, 1 May, 1 July 
and 1 September 2024 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 and aim at ensuring that the 90% overall storage filling goal is reached by 1 
November 2024. 

7 Commission Implementing Regulation (EU) 2023/2633. 

7 

 
 
 
 
 
 
 
 
 
Table 4 - Intermediate targets for 2024 for Member States with underground gas storage facilities, as adopted 
by Commission Implementing Regulation (EU) 2023/26338. 

6.  IMPLEMENTATION OF THE GAS STORAGE REGULATION IN 2024 

the  Commission  of 

The intermediate targets of the filling trajectories are based on the input from Member States and 
the  general  situation  of  security  of  supply. 
an  assessment  by 
The Member States’ filling trajectories proposed for 2024 were similar to the trajectories adopted 
in 2023. The assessment of the security of gas supply for the gas year 2023-2024 (from 1 October 
2023  to  30  September  2024),  based  primarily  on  the  results  of  the  ENTSOG  Winter  Supply 
Outlook 2023/24, indicates that the intermediate targets as originally proposed by Member States 
might require an upward adjustment if the supply-demand conditions were altered with respect to 
the previous year. Moreover, when following the advice of the Members of the Gas Coordination 
Group to keep intermediate targets aligned with 2022-2023 as proposed by Member States and 
give  a  maximum  of  market  flexibility,  the  Commission  had  made  clear  that  demand  reduction 
efforts should continue in order to provide the same level of security of supply.  
Based on analysis using the ENTSOG outlook9, the Commission estimated (see recital 8 of the 
Implementing  Act  of  November  2023)  that  the  EU  should  reach  at  least  45%  in  May  2024  to 
facilitate storage refilling in the event of higher demand and/or reduced supply during summer 
2024. Not reaching this target could pose a serious risk of not meeting the 90% storage target of 1 

8 The table is subject to the pro rata obligations of each Member State under Regulation (EU) 2017/1938, in 
particular Articles 6a, 6b and 6c thereof. 
9entsog.eu/sites/default/files/2023-10/SO0052-23_Winter Supply Outlook 2023-24 with Summer 2024 Overview.pdf. 

8 

 
 
 
 
 
 
 
November 2024.  This intermediary target ensures the necessary flexibility to meet the 90% filling 
target by 1 November 2024, even without Russian supplies during the summer, provided that other 
supplies are kept at current levels and with sustained gas demand reduction (Figure 3).  

Figure  3:  Evolution  of  the  European  UGS  filling  level  under  full  Russian  supply  disruption  in  a  reference 
scenario  with  LNG  supply  potential  as  observed  in  2022-2023  and  low  LNG  (40%  decreased)  targets  for 
February and May, aiming at reaching collectively 45% filing level in May. 

Source: ENTSOG Winter Outlook 2023-2024  

Energy Community outlook 
In line with the developments in the EU, the Energy Community transposed the Storage Regulation 
(EU) 2022/1032 at unprecedented speed. It requires the Contracting Parties to ensure that their 
undergoing storage is filled up to at least 90% of its capacity by 1 November. The Regulation also 
imposes the obligation on the Contracting Parties to ensure that storage system operators located 
on their territories are certified.  

According to the report by the Energy Community Secretariat on the implementation of Storage 
Regulation, of 1 June 2023, Serbia and Ukraine, Contracting parties with gas storage facilities, 
fulfilled  the  targets  including  intermediary  targets.    The  Report  calls  for  Contracting  Parties 
without storages to make additional efforts to implement the storage obligations and use available 
instruments in place, such as signing Burden Sharing Agreements and ensuring they have storage 
capacities for a portion of their annual demand (at least 15%) in the neighbouring countries. 

9 

 
 
 
 
 
 
 
 
Ukraine transposed the majority of the requirements from Regulation (EU) 2022/1032, fulfilled 
the  obligations  concerning  the  storage  system  operator  and  the  trajectory  levels  of  gas  in  the 
storages. Regarding the certification of SSOs in the Energy Community, only Ukraine and Serbia 
have storage capacities. In Ukraine, Ukrtransgaz has been certified in April 2023 and Serbia has 
not yet transposed the Regulation as the legal basis for certification. In addition, Ukraine storage 
and  transmission  system  operators  performed  a  storage  stress-test,  based  on  a  set  of  selected 
scenarios aiming to identify whether the gas stored by foreign traders under warehouse custom 
regime could be evacuated to the owners in a crisis. 
On 13 November 2023, the Energy Community Secretariat adopted comprehensive storage filling 
trajectories for 2024.  

7.  ANALYSIS OF POTENTIAL EFFECTS ON GAS PRICES 

Storages are key to ease tension in the markets as they can provide large quantities to the market 
when the supply is tight, and therefore mitigate price fluctuations and spikes. 
Gas demand tends to be price-inelastic in the short term. Consequently, market tightness due to 
supply scarcity can rapidly translate into significant price increases. In this context, the availability 
of flexibility sources, such as the storage, is paramount to increase short-term available supply and 
preserve the demand-supply balance in the system.  

The storage role in alleviating price pressure is widely acknowledged in the industry and in the 
economic literature.  

For example, the International Energy Agency noted in the Medium-Term Gas Report 2023 that 
high storage level, together with subdued demand, ‘weighed on spot gas prices in Europe’ in the 
third quarter of 2023. Similarly, in its report of June 2023 ACER indicated that ‘storage filling 
levels are significantly above last years’ average and have contributed to driving prices down.’  

Several economic articles assessed the impact of gas storage on prices. For example, Brown and 
Yücel (What Drives Natural Gas Prices, 2008) looked at the US gas data between 1997 and 2007 
and found that storage above the seasonal norm depresses natural gas prices. Hulshof et al. (2015)10 
analysed the TTF day-ahead spot price during the period 2011–2014 and similarly found that when 
the filling degree of storage facilities is below the average, spot prices tend to be higher. Obadi 
and Korcek (2020)11 also looked at the TTF prices between 2016 and 2019 and concluded that 
storage levels  below historic average result in  tighter markets  which  inevitably lead to  upward 
pressure on prices.  

As  shown  in  the  graph  below,  wholesale  gas  prices  have  been  fluctuating  between  30  and  50 
EUR/MWh in  recent  months.  While still significantly  higher than pre-crisis, prices  have fallen 
considerably since the peak of the crisis in summer 2022 when prices reached unprecedented levels 
above 300 EUR/MWh.  

Member  States  and  the  Commission  put  in  place  a  comprehensive  package  of  measures  that 
together contributed to improve the market situation and helped  alleviate the pressure on price. 
The commitment to store minimum volumes of gas prior to the winter, as set out in Regulation 

10 What Drives Natural Gas Prices? on JSTOR. 
11 EconPapers: Examining the Drivers of Natural Gas Price in Europe - Focus on the Role of Speculators 
(repec.org). 

10 

 
 
 
 
 
 
(EU) 2022/1032 played an important role in this set of initiatives and the very high level of storage 
filling  observed  since  late  Autumn  2022  has  been  a  key  (while  not  the  unique)  determinant  in 
easing the market tension and driving gas prices down. 

Figure 4 - TTF month-ahead prices – January 2021 - September 2023 

Source: ENER based on S&P Global data 

8.  CONCLUSION 

In 2023, all the objectives set by the Storage Regulation have been met or surpassed. The 90% 
storage target was met by mid-August, and on 1 November gas storage levels were reported over 
99%. At the end of 2023, the average level was still close to record high levels, above 85%12. The 
measures implemented by the Member States, supported by  the gas demand reduction,  both  in 
terms  of  level  and  timing,  proved  efficient  for  market  participants  to  keep  storage  levels  at  an 
adequate level through 2023 and fulfil the storage target. The fulfilment of the objectives ahead of 
the regulatory schedule even allowed to further inject additional 2.5 bcm in Ukraine storages over 
the summer mutually reinforcing the security of gas supply of the EU and Ukraine.  
The mechanism of minimum  intermediary targets leaves ample room for Member States to  set 
their  own  measures  and  schedules.  Achieving  the  objectives  set  by  storage  regulation  greatly 
helped strengthen the security of supply in winter 2023/24, which in turn reduced the risk premium 
in the gas market at the end of the year.  
With the obligation to certify gas storage, the Storage Regulation aims at avoiding any detrimental 
influence  of  non-EU  countries  on  the  filling  of  storage  sites.  The  certification  process  is  well 
advanced for a substantial share of the storage operators and sites. The Commission is in contact 
with the Member States which still need to submit draft certification decisions. While a number of 
certifications are still pending, there is currently no available evidence that storage ownership or 
storage operators could put the security of gas supply of the EU at immediate risk.  

12 86.40 % at EU level as from Gas Infrastructure Europe - AGSI (gie.eu). 

11 

 
 
 
 
 
 
 
 
It is widely acknowledged that storage levels have had a positive effect with respect to gas prices 
although it is difficult to assess precisely to which extent. The trajectories and targets set by the 
regulation therefore contributed to alleviate the pressure on gas prices by setting minimum storage 
levels that were largely surpassed in 2023. Gas market volatility and gas prices were significantly 
lower in 2023 compared to 2022. Furthermore, it is essential to consider the effects of the storage 
together with the reduction of demand. The reduction of demand will continue to be a crucial factor 
to  achieve  a  sufficient  level  of  storage  filling,  which  is  part  of  the  same  security  of  supply 
architecture as demand-side measures.  

12 

 
 
 
 
 
 
 
ANNEX - Detailed table of measures implemented per Member State with UGS 

Measure  (as suggested 
in 6b of the Regulation)  
Minimum  volume  in 
gas storage 

MS  Description  

AT  

BG  

CZ  

ES 

HU  

Gas suppliers of protected customers required to fulfil the Supply Standard (Art. 
6 of SoS Regulation)  
Market participants with clients with irregular consumption obligated to maintain 
a strategic reserve related the security of supply and seasonal fluctuation 
Gas traders directly supplying gas obligated to maintain gas stocks corresponding 
to 30 days of exceptionally high gas demand 
Suppliers  obligated  to  maintain  gas  stocks  corresponding  to  27.5  days  of  their 
consumption in previous year 
Universal gas suppliers obligated to maintain security stocks based on the winter 
peak consumption of the last 120 months 

PT   Market participants obligated to maintain security and additional reserves 

2.Tender capacities  

3.1.  Balancing  stock 
managed by TSO  
3.2. 
Obligations 
imposed on designated 
entities  

4.Coordinated 
instruments  
5.Voluntary 
procurement 
mechanisms  
incentives 
6.Financial 
for market participants  

joint 

RO  

 Gas suppliers and heat producers obligated to establish and maintain gas stocks 
until the end of October each year 
 Secure gas volumes to meet the supply standard. The Ministry decides whether 
these volumes must be stored or contractually secured 
BE   SSOs to tender capacities to market participants via auctions  

SK  

DK  Tender capacities via auctions* 

ES 

FR  

IT  

PT  

Capacity obligation directly assigned, and the remaining is auctioned 
Holders of storage have the obligation to store 85% of the booked capacity by 1 
November each year  
 Increased number of auctions for monthly storage capacity products. 
  Market participants to book capacity exclusively for the security and additional 
reserves 

IT  

  Procurement of gas and injection for operation of transmission and storage 

CZ 

Storage  users  obligated  to  store  sufficient  gas  in  accordance  with  the  filling 
trajectories 

DE  Obligations of THE to conduct tenders for storage options 
DK  Energinet responsible for procuring filling requirements and emergency storage 
IT 

Only in case of activated crisis level  
Gas  suppliers  and final  consumers  importing  gas must  maintain  mandatory  gas 
stocks covering 30 days of imports 

PL 

BE  

  Incentivize market participants to fill gas in storages* 

CZ 

DK 

ES 

Financial  incentives  provided  to  CEZ  for  delivering  gas  from  the  Dutch 
Eemshaven LNG terminal to the Czech VTP (3 bcm/y) 
  Incentivize market participants to fill gas in storages* 
Costs of the technical manager are recovered from the state budget and from the 
market participants 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
   
 
 
 
7.  Unused 
capacities  

booked 

8.Strategic storage  

9.Appointment  of  a 
dedicated entity  

10.  Discounts  storage 
tariffs  

IT   

NL  

 Contracts for differences. Provision of a stock premium. Penalty for stocks below 
the level assigned by storage operator.* 
Subsidy scheme extended for 2023-2024 (insurance type in case market conditions 
are not favorable during injection season). UGS Bergermeer not included.  

AT   Requiring capacity holders to use or release unused booked capacities  

BE   Measure approved by NRA (use-it-or-lose-it)  

CZ  

DE 
ES 

HR 

AT  

BG  

Releasing booked capacity back to the market if this is underutilized by a storage 
user  
SSOs release booked but unused capacity to THE  
Oversubscription and buy-back mechanism 
Automatically  ceding  unused  capacity  to  other  storage  companies,  or  to  state 
energy company HEP* 
20 TWh of strategic gas reserves intended for security of supply purposes only  
Bulgartransgaz  is  obliged  to maintain  up  to  a  maximum  70  mcm  related  to  the 
security of supplies  

CZ  ASMR to maintain gas stocks to be used in case of crisis 

DE 

DK 
ES 

HU  

IT  

Part of the storage options tendered by THE maintained in storage with a call-off 
option 
State-owned TSO holds strategic stocks*  
Gas stocks of the 20 days out of the 27.5 that are minimum obligation 
  Maintaining  two  distinct  gas  reserves:  the  natural  gas  security  stocks  and  the 
special natural gas stocks 
  49.3 TWh (4.62 bcm) strategic reserves that can only be withdrawn in case of 
emergency 

LV   Strategic reserve for 2023 defined in the Law: 1.8-2.2 TWh  

ES 

The technical system manager (Enagás GTS) to cover the gas stocks’ obligations 

DE 

IT  

FR  

NL  

SE 

THE to purchase and inject its own gas to meet the filling targets 
Snam  and  GSE  tasked  to  ensure  that  sufficient  gas  is  in  storage  during  winter 
period 
SSOs responsible for filling the gap to meet the filling targets, upon government 
request  
Appointment of a designated party to fill up to 20 TWh of UGS Bergermeer (actual 
storing 14.1 TWh)  
Swedegas responsible for ensuring meeting the filling targets 

BE   Offering capacity at reserve prices at a discount compared to the regulated tariff 

ES 

Discounts offered for market participants that meet their obligation for minimum 
stocks and for storage users that procured capacity via auctions and filled 90% of 
their booked capacity on 1 November 

Capital 

11. 
operational 
expenditures  

and 

BE   Last resort solution* 

IT  

In place if any cost remains uncovered. Otherwise, the system decreases the tariff 
scheme on final customers using the extras from storage auction revenues. 

*Measure collected by Commission that is not part of the 2023 ACER gas storage report 
Source: Member States' responses to EC survey and ACER gas storage report 2023. 

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