REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on solidarity and certain aspects concerning gas storage based on Regulation (EU) 2017/1938 of the European Parliament and of the Council
Date: 2025-03-05
Institutions: Directorate-General for Energy, European Commission
Subjects: EU energy policy, activity report, application of EU law, approval, energy demand, gas supply, natural gas, price of energy, security of supply, storage of hydrocarbons

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 5.3.2025  COM(2025) 98 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on solidarity and certain aspects concerning gas storage based on Regulation (EU) 2017/1938 of the European Parliament and of the Council       
 
 
1.  INTRODUCTION 

Underground gas storages (UGS) are instrumental to the security of energy supply of the EU. With 
a total capacity of 1147 TWh (ca. 105 bcm, corresponding to about one third of EU’s aggregated 
demand), it provides essential seasonal flexibility to the gas system, typically providing 25-35% 
of the actual gas consumption in the EU, during winter often as the main supply source. Gas storage 
enables a more efficient  use of the EU gas system  by reducing  the need  for high  import flows 
during  peak  consumption  periods  when  gas  prices  are  higher  thereby  helping  to  avoid 
overinvestment in transmission infrastructure contributing to price stability and absorbing supply 
shocks.  
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  tension  after 
Russia’s  full-scale  invasion  of  Ukraine  in  the  beginning  of  2022  amplified  uncertainties  and 
highlighted the need for adequately filled gas storage for future winters.  
In June 2022, the co-legislators therefore adopted the Commission’s proposal for the amendment1 
of the Regulation (EU) 2017/1938 on Security of Gas Supply (hereinafter Gas SoS Regulation)2. 
The amendment sets, among other things, mandatory annual filling targets by 1 November each 
year: 80% in 2022 and 90% from 2023 onwards, as well as filling trajectories to meet those targets. 
Member  States  without  gas  storage  are  required  to  store  at  least  15%  of  their  annual  gas 
consumption in another Member State. Moreover, Regulation (EU) 2022/1032, or the Gas Storage 
Regulation,  also  introduced  the  obligation  to  certify  storage  system  operators  in  each  Member 
State.  
Collectively, these measures have proven instrumental in weathering the gas supply shortages and 
have contributed significantly towards the reduction of market uncertainties and price volatility. 
The 2022 dramatic gas price spikes scenario was not repeated in 2023 or 2024 and the obligation 
to  certify storage system  operators  eliminated the practice from  2021  where some of the third-
party  owned  gas  storage  facilities  were  intentionally  filled  below  capacity  or  late  ahead  of  the 
winter months.  
However, the EU’s security of supply remains exposed to risks due to the geopolitical instability 
notably possible further weaponisation of supply by Russia in the context of its military aggression 
against Ukraine. These risks are likely to prolong the period of gas market tightness and uncertainty 
and underline the pivotal role storage facilities will continue to play for the EU’s security of supply. 
This conclusion was recently confirmed by an extensive Court of Auditors’ report  on the EU’s 
energy security measures.3  
The current report takes stock of the implementation of the Gas Storage Regulation in 2024. It 
largely follows the structure established by the previous two annual reports but introduces some 

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 (Gas Storage Regulation), (OJ L 173, 30.6.2022, p. 
17–33). 
2 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 (Gas SoS Regulation) 
(OJ L 280 28.10.2017, p. 1). 
3 Special report 09/2024: Security of the supply of gas in the EU. 

1 

 
 
 
 
 
 
 
new elements, reflecting the legislative changes brought by the adoption of the Regulation (EU) 
2024/1789  on  the  internal  markets  for  renewable  gas,  natural  gas  and  hydrogen  (Gas  Market 
Regulation),  amending  the  Gas  SoS  Regulation.  The  new  elements  relate  mainly  to  the  risk 
assessment and solidarity provisions. Updates on gas storage measures, progress on certification 
procedures, as well as measures related to risk assessment and solidarity presented in this report 
are  mainly  based  on  information  provided  by  Member  States,  complemented  by  data  from 
Eurostat, the Joint Research Centre, ACER and ENTSOG. 

2.  LEGAL BASIS AND CONTEXT 

Article 17a of Gas SoS Regulation, states that the Commission must 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 their storage obligations;  
an overview of the time needed for the certification procedure, previously4 set out in Article 
3a of Regulation (EC) No 715/20095 (Gas Regulation);  
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).  

Amendments to Article 17a of the Gas SoS Regulation introduced by the Gas Market Regulation 
further requires the Commission to provide a general assessment of the application of Articles 6a 
to 6d, Article 7(1) and (4), point (g), Article 13, Article 13a, Article 16(3), Article 17a, Article 
18a, Article 20(4), and Annexes Ia and Ib. 

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.  The  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 2024 to collect the 
measures  and  tools  they  have  used  to  ensure  that  their  storage  sites  were  filled.  This  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 storage facilities confirmed that most measures used in 2022 
and 2023 were continued in 2024. Last year, Austria, Latvia, the Netherlands and Spain adopted 

4 The obligation to certify Storage System Operators is now in Article 15 of  Regulation (EU) 2024/1789 of the 
European Parliament and of the Council of 13 June 2024 on the internal markets for renewable gas, natural gas 
and hydrogen amending Regulations (EU) No 1227/2011, (EU) 2017/1938, (EU) 2019/942 and (EU) 2022/869 and 
Decision (EU) 2017/684 and repealing Regulation (EC) No 715/2009 (recast) that started to apply from 5 February 
2025 (OJ L, 2024/1789, 15.7.2024) (Gas Market Regulation). 
5 Regulation (EC) No 715/2009 of the European Parliament and of the Council of 13 July 2009 on conditions for 
access to the natural gas transmission networks and repealing Regulation (EC) No 1775/2005 (Gas Regulation) 
(OJ L 211 14.8.2009, p. 36). 

2 

 
 
 
 
 
 
 
new  measures  and/or  prolonged  or  cancelled  the  existing  measures.  Austria’s  state  controlled 
strategic reserve was prolonged, Latvia introduced a new bundled product to incentivise long -
term usage of the storages and the Netherlands re-assigned the designated party with the task of 
filling the storage facility. In Spain, the discount on storage tariff for capacities of more than 20 
days of firm consumption was discontinued. The favourable market conditions during the 2024 
injection  season  eased  the  effective  filling  of  the  storage  sites  in  time  with  no  need  to  enforce 
measures of last resort. Among the most common measures implemented by Member States were:  
-  Minimum volume in gas storage: imposing an obligation on Storage System Operators (SSOs) 

on the minimum filling level to achieve, in line with the national objective; 

-  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. 

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

Table 1 - Measures of article 6b implemented per Member State with UGS  

AT 

BE 

BG 

CZ 

DE  DK 

ES 

FR  HR  HU 

IT 

LV  NL 

PL 

PT 

RO 

SE 

SK 

Minimum  volume  in  gas 
storage 

x 

x 

X 

Tender of capacities  

x 

x 

T 

x 

X 

X 

x 

Balancing  stock  managed 
by TSO 

Obligations 
designated entities  

imposed  on 

Coordinated instruments 

Voluntary 
procurement mechanisms 

joint 

Financial 
market participants 

incentives 

for 

Unused booked capacities  

Strategic storage 

Appointment  of  dedicated 
entity  

Discount on storage tariffs  

Capital  and  operational 
expenditures 

Other  

X 

x 

x 

T 

X 

X 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

X 

X 

X 

X 

T 

x 

x 

x 

x 

x 

T 

x 

 x 

T 

T 

T 

x 

x 

T 

x 

x 

x 

x 

x 

x 

T 

T 

x 

x 

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

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4.  OVERVIEW OF THE CERTIFICATION PROCEDURE 

The provisions of the Gas Storage Regulation,introduced into the Gas Regulation6,  established 
the obligation to certify Storage System Operators by the competent national authorities aimed at 
reducing any 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 SSO 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. 

The legislation requires the Member States to issue draft certification decisions by 2 January 2024 
and  notify  them  to  the  Commission.  Some  Member  States  submitted  their  storage  certification 
decisions  already  in  2023  and  the  Commission  issued  six  opinions.7  In  2024,  the  certification 
process continued and so far, five opinions have been issued, whereas 17 opinions for four Member 
States are in various stages of the adoption procedure. Submission of draft decisions from some 
Member States is still pending. In limited number of cases, drafting of the opinion depends on the 
amendments of the national legislative or regulatory framework and therefore they take longer to 
be issued. The perspective of having completed the certification procedure by the end of 2025 for 
the  majority  of  the  Member  States  seems  realistic.  Through  the  successful  completion  of  the 
certification process  Member States regained  full control  over  their strategic assets, preventing 
repetition of the 2021 scenario when certain SSOs intentionally kept storages at very low level.  

Table 2 – Overview of the certification procedure during 2024 

MS 

Submissions 

AT 
BE 
BG 
CZ 
DE 
DK 

4 
1 

5 
1 

Pending submissions             
Number of operators                    
(Number of storage 
sites) [1] 

Total number of 

operators                    

(Number of storage 
sites) [2] 

1 (1) 
4 (9) 
20 (24) 

4 (8) 
1 (1) 
1 (1) 
4 (9) 
25 (50) 
1 (2) 

6 As previously mentioned, the obligation to certify Storage System Operators is now in Article 15 of  the Gas Market 
Regulation (Regulation(EU) 2024/1789).  
7 https://energy.ec.europa.eu/topics/energy-security/gas-storage_en#certification-for-storage-system-operators. 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ES 
FR 
HR 
HU 
IT 
LV 
NL 
PL 
PT 
RO 
SE 
SK 
TOTAL 

2 
3 
1 
2 

1 
4 
1 
1 
2 
1 
2 
31 

3 (13) 

1 (3) 

29 (50) 

2 (4) 
3 (16) 
1 (1) 
2 (5) 
3 (13) 
1 (1) 
4 (7) 
1 (7) 
1 (1) 
2 (6) 
1 (1) 
2 (2) 
58 (122) 

`[1] The certifications are issued by operator and/or by storage site. 
[2] Based on exchange with MSs, GIE AGSI+ and ACER and VIS Gas Storage report 2023 

5.  COMPLIANCE WITH THE STORAGE FILLING OBJECTIVES IN 2024 

In November 2023, the Implementing Regulation (EU2023/2633)8 setting the 2024 intermediary 
filling targets was adopted. The intermediary filling targets provide the necessary flexibility for 
the Member States, allowing them to reach the ultimate 90% filling target by the start of the heating 
season in November. During 2024, the filling trajectory proceeded according to the established 
goals.   
At the end of March 2024, the EU’s UGS stock level was reaching 60% (670 TWh), reflecting 
continued above-average filling rates compared to historic levels. Gas storage levels in the second 
and third quarter of 2024 were closely aligned with those of 2023, with the EU reaching an overall 
90% level on 19 August, almost on the same day as in 2023 (16 August).  Since stocks were already 
high after the withdrawal season of 2023/2024, the filling was slower than usual during the last 
months of the injection period. Around 60% of the gas stored during the summer was injected in 
the months of May-July (see Figure 1). By 1 November 2024, EU’s gas storage reached 95%, with 
all Member States exceeding the filling target, with the exception of Denmark (see Figure 2). 

8 Commission Implementing Regulation (EU) 2023/2633 of 20 November 2023 setting the filling trajectory with 
intermediary targets for 2024 for each Member State with underground gas storage facilities on its territory and 
directly interconnected to its market area (OJ L, 2023/2633, 23.11.2023) 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 1 – Daily historical net injections 

Source: JRC Security of Supply Dashboard 9 

Figure 2 - Gas in EU underground storages in the year 2024 and year 2023 (until December) in comparison 
with the previous 6-year average and range. 

Source: JRC Security of Supply Dashboard 

By 1 November, almost all Member States filled their storages by more than 90%, thereby meeting 
the target set by the Implementing Regulation. The sole exception was Denmark, where storage 
levels  were at 75%  on 1  November. The below target  storage filling in  Denmark  was  due to  a 

9 Link to the JRC Security of Supply Dashboard  

6 

 
 
 
 
 
 
 
 
 
combination of technical infrastructure issues linked to the commissioning of the Tyra production 
platform, and unplanned maintenance on the Nybro gas terminal. In addition, Germany had applied 
a so-called gas storage levy until 31 December 2024, a tax duty on gas transported created to cover 
the costs of filling storage sites. Importing gas from the German direction therefore had appeared 
less attractive and encouraged market players to rather withdraw gas from gas storages, including 
Danish storages, instead. Despite not meeting the 1 November target, the overall energy security 
situation in Denmark remained stable, mainly thanks to the recent commissioning of the Baltic 
Pipe and continuously rising share of biomethane production covering nearly 40% of domestic gas 
consumption. However, the situation draws attention to the detrimental effects a measure adopted 
in one Member State can have on the energy security situation in another Member State and the 
need to avoid unilateral national measures. The European Commission has been in active dialogue 
with Denmark and the national competent authority that adopted measures allowing Denmark to 
meet the 1 February 2025 intermediary target.  
It should be noted that the storage capacities of Latvia and the Netherlands are substantially larger 
than the domestic consumption  volumes  and for this reason, in  line with  Article  6a of the  Gas 
Storage Regulation, the ultimate annual target for these two Member States is set differently and 
therefore, both countries did comply with the 90% filling target, even if the nominal value was 
slightly lower (see also footnote  11 for additional explanation of the reduction methodology).   
As regards the Energy Community, there have been some progress on the implementation of the 
gas storage provisions of the Gas SoS Regulation. Serbia and Ukraine, the two Contracting Parties 
with storage facilities were fulfilling their storage targets (situation as of May 2024).  For further 
details, please refer to the Energy Community Secretariat's 2024 annual report.10  

Table 3 - Compliance with the filling targets of storage Regulation for 202411 

Member 
State 

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

1 
February 
intermedi
ate target 
50% 
30% 
52% 
40% 
45% 
45% 
59% 
41% 
46% 
51% 
45% 
45% 
43% 
50% 
70% 

Filling 
Level 1 
Februar
y 
81% 
60% 
67% 
75% 
74% 
75% 
81% 
59% 
51% 
76% 
64% 
57% 
65% 
75% 
103% 

1 May 
intermedia
te target 

Filling 
level 1 
May 

1 July 
intermedia
te target 

Filling 
level 1 July  

1 September 
intermediat
e target 

40% 
5% 
33% 
25% 
10% 
40% 
60% 
11% 
29% 
37% 
36% 
41% 
30% 
35% 
70% 

75% 
52% 
44% 
62% 
68% 
55% 
83% 
50% 
33% 
71% 
65% 
46% 
55% 
43% 
92% 

58% 
40% 
55% 
30% 
30% 
60% 
66% 
39% 
51% 
65% 
54% 
63% 
50% 
60% 
80% 

83% 
73% 
72% 
82% 
82% 
64% 
95% 
68% 
59% 
78% 
82% 
58% 
69% 
73% 
102% 

72% 
78% 
77% 
60% 
65% 
80% 
80% 
81% 
83% 
86% 
72% 
90% 
68% 
80% 
80% 

Filling 
level 1 
Septembe
r  
92% 
94% 
88% 
93% 
95% 
75% 
100% 
90% 
88% 
90% 
93% 
71% 
91% 
98% 
102% 

1 
Novembe
r filling 
target 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 

Filling 
level 1 
Novembe
r 
94% 
98% 
100% 
92% 
98% 
75% 
100% 
95% 
91% 
91% 
99% 
80% 
89% 
98% 
103% 

10 https://www.energy-community.org/news/Energy-Community-News/2024/05/28b.html. 
11 Regulatory targets of Table 3 are subject to reduction according to Art. 6a of the Gas SoS Regulation. The table indicating the 
targets  is  taken  from  the  Annex  of  the  Commission  Implementing  Regulation  2023/2633.  Annex  is  subject  to  the  pro  rata 
obligations of each Member State under Gas SoS Regulation, in particular Articles 6a, 6b and 6c thereof. For Member States falling 
under Article 6a(2), the pro rata intermediate target shall be calculated by multiplying the value indicated in the table by the limit 
of 35 % and by dividing the result by 90 %. 

7 

 
 
 
 
 
 
 
RO 
SE 
SK 

40% 
59% 
45% 

63% 
77% 
73% 

41% 
30% 
20% 

58% 
63% 
70% 

65% 
61% 
27% 

77% 
63% 
79% 

85% 
79% 
67% 

94% 
91% 
95% 

90% 
90% 
90% 

103% 
91% 
95% 

Source: filling levels based on GIE AGSI+ 

Demand reduction  
Gas demand was reduced by 18% between August 2022 and September 2024, exceeding the 15% 
voluntary  reduction  target  set  out  in  the  Regulation  (EU)  2022/136912  and  Council 
Recommendation C/2024/2476.13  

Figure 3 - Monthly gas demand  

Source: JRC Security of Supply Dashboard 

Risk assessment 

The EU-wide Security of Supply Simulation performed by ENTSOG in November 2024 takes into 
account scenarios of prolonged disruption of a single supply source. In particular, the complete 
disruption of Russian supply is considered as a baseline in all scenarios. All scenarios also assume 
exceptionally  low  storage  levels  at  the  beginning  of  the  winter  season  and  explore  additional 
infrastructure  disruptions  that  reflect  risks  relating  to  the  control  of  infrastructure  relevant  for 
security of gas supply, such as misuse of existing infrastructure including capacity hoarding or 
infringement of Union law. The conclusions confirm the resilience of the EU gas system and also 
highlight the key role of gas demand reduction by means of energy savings or energy efficiency 
measures. 

12 Council Regulation (EU) 2022/1369 on coordinated demand-reduction measures for gas 
13 Council Recommendation C/2024/2476 of 25 of March 2024 on on continuing coordinated demand-reduction 
measures for gas  

8 

 
 
 
 
 
 
 
 
 
 
 
 
6.  SOLIDARITY 

The solidarity mechanisms introduced by Gas SoS Regulation play a crucial role in ensuring that 
protected  customers,  such  as  households  and  hospitals,  maintain  access  to  gas  during  extreme 
crises.  Solidarity  was  initially  implemented  through  voluntary  bilateral  solidarity  agreements 
between directly connected EU Member States, with the exception of Malta, Cyprus and Ireland 
benefiting from a derogation (as they are not directly connected to any other Member State). There 
are  nine  solidarity  agreements  signed  to  date,  out  of  the  forty  expected,  including  agreements 
between Germany, Italy, and Switzerland that were signed in 2024. In 2022, at the peak of the gas 
crisis, the low number of agreements ratified was exposing the EU to a security of supply risk and 
the concept of voluntary agreements was reassessed. Consequently, the concept of solidarity was 
strengthened  through  the  Gas  Market  Regulation,  establishing  default  solidarity  provisions  to 
operationalise the solidarity principle in case of a crisis and in a situation where bilateral solidarity 
agreements are not in place.  

In  addition,  the  Gas  Market  Regulation  also  extends  the  solidarity  obligation  to  indirectly 
connected Member States, allowing them to access a larger market-based solidarity, inter alia, via 
LNG  supplies.  A  November  2024  table-top  crisis  exercise  ("dry  run")  organized  by  the 
Commission demonstrated the effectiveness of the new solidarity provisions, highlighting the role 
of market-based measures that reduce the overall cost of solidarity for the EU. Moreover, LNG 
can  play  a  key  role  in  solidarity  requests,  as  Member  States  can  play  a  facilitating  role  in  the 
discussion between market actors, while having no legal obligation to require LNG shippers to 
divert their deliveries. The exercise also identified areas for improvement of the implementation 
of solidarity in case of crises, including the need for clearer procedures, guidelines on monitoring 
actions, and contractual arrangements between concerned parties to facilitate the implementation 
of the solidarity mechanisms. 

7.  IMPLEMENTATION OF THE GAS STORAGE REGULATION IN 2025 

The intermediary filling trajectories targets for 2025 are based on the information provided by the 
Member States and the Commission’s assessment of the general security of supply situation, taking 
into account the filling rates of the previous five years and ENTSOG’s Winter Supply Outlook. 
The  2025  targets  were  formally  set  in  November  2024  by  the  Commission  Implementing 
Regulation (EU) 2024/2995, assisted by the Gas Storage Committee. These intermediary targets 
are deemed as minimum targets offering maximum market flexibility to reach the 90%, as long as 
demand reduction efforts continue and supplies are maintained on the level similar to the previous 
year.  

9 

 
 
 
 
 
Table 4 -  Intermediate targets for 2025 for Member States with underground gas storage facilities, as 
adopted by Commission Implementing Regulation (EU) 2024/299514. from 29.11.2024 
(https://energy.ec.europa.eu/publications/implementing-regulation-setting-filling-trajectory-intermediary-
targets-2025-member-states_en)  

Member 
State 

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

1 February 
intermediate 
target 
64% 
30% 
55% 
40% 
45% 
45% 
58% 
41% 
46% 
59% 
55% 
45% 
47% 
50% 
70% 
41% 
53% 
45% 

1 May 
intermediate 
target 
52% 
5% 
36% 
25% 
10% 
40% 
53% 
11% 
29% 
38% 
45% 
41% 
39% 
35% 
70% 
42% 
5% 
20% 

1 July 
intermediate 
target 
66% 
40% 
57% 
30% 
30% 
60% 
64% 
39% 
51% 
61% 
54% 
63% 
57% 
60% 
80% 
63% 
5% 
29% 

1 September 
intermediate 
target 
77% 
78% 
77% 
60% 
65% 
75% 
80% 
81% 
83% 
84% 
72% 
90% 
72% 
80% 
80% 
84% 
5% 
74% 

1 November 
filling target15 

90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 
90% 

The ENTSOG’s Winter Supply Outlook 2024/2025 suggests that under a reference winter scenario 
(no protracted cold spell periods), Europe could still reach 40% stock level of gas at the end of this 
winter season, even without Russian pipeline gas. 

8.  ANALYSIS OF POTENTIAL EFFECTS ON GAS PRICES 

Gas storages continue to be instrumental in  easing tension  on gas  markets as they  can provide 
significant gas volumes when supply is tight and therefore, mitigate price fluctuations and spikes. 
It has been observed that the gas spot prices tend to be higher when the filling levels are below the 
average.16 In this context, 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.’ 
As  shown  in  the  graph  below,  wholesale  gas  prices  have  been  fluctuating  between  30  and  50 
EUR/MWh in recent months. Prices have fallen considerably since the peak of the crisis in summer 
2022  when  prices  reached  unprecedented  levels  above  300  EUR/MWh  but  they  are  still 

14 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. 
15See Article 6a(1)(b) 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. 
16 What Drives Natural Gas Prices? on JSTOR 

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significantly  higher  than  pre-crisis  and  experiencing  a  number  of  episodes  of  pronounced 
volatility.  

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 Gas Security 
of Supply Regulation 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. 

However, during late autumn 2024 / early 2025, in a context of a tight market and higher demand 
due  to  colder  weather,  the  European  gas  market,  started  to  experience  the  trend  of  negative 
summer-winter spread. This price configuration is not favourable for storage injections during the 
summer, the usual  time  period  for storage filling.  The trend is  relatively  recent and  in  January 
2025, the time of drafting of this report, there was still no unanimity around the exact causes for 
this development. The phenomenon could be observed also on other markets (e.g. South-East Asia) 
and can therefore not be explained solely by the demand-supply situation in Europe. Some recent 
European-specific factors, such as the cold weather, low renewables production, may contribute 
to  the  recent  increase  in  gas  prices  and  higher  withdrawals  from  storage.  It  is  likely  that  the 
upcoming wave of additional LNG capacity that is to come online in the coming years will have a 
downward effect on future global prices. In the meantime, to reduce system stress and avoid market 
distortions  linked  to  gas  storage  refilling,  the  Commission  will  make  use  of  the  margin  of 
manoeuvre provided within the regulation towards Member States and is issuing a Commission 
Recommendation,  to  support  Member  States  to  better  coordinate  and  provide  an  even  higher 
degree of flexibility on filling trajectories to fulfil filling targets for gas storage at their own pace. 

Figure 4 - TTF day-ahead and month-ahead prices – June 2021 - September 2025 

Source: ENER based on S&P Global data 

9.  CONCLUSION 

In 2024, the objectives set by the Gas Storage Regulation have been largely met or surpassed. By 
1 November, nearly all Member States complied with the regulatory target, Denmark being the 
only exception to the rule. However, the lower filling levels did not endanger Denmark’s overall 
energy security situation and Denmark was able to meet the 1 February 2025 intermediary target. 

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The ENTSOG Winter Supply Outlook 2024/2025 as well the Commission’s 2024 quarterly gas 
market reports indicate relatively smooth filling trajectories throughout 2024. This is confirmed 
by the fact that during 2024 no Member State has adopted any new filling measures compared to 
the last year. There was no resort to non-market-based measures and there are reasons to believe 
that  the  mechanism  of  minimum  intermediary  targets  continues  to  enable  sufficient  level  of 
flexibility for Member States to set their own measures and schedules. At the same time, achieving 
the objectives set by the Gas Storage Regulation helped in reducing the risk premium in the gas 
market at the end of the year. 
The certification process of gas storage facilities continued during 2024. National authorities made 
progress on adopting certification decisions and the Commission has issued several opinions in 
the course of the year. Even though some Members States have yet failed to submit their decisions, 
the EU’s control over the strategic assets have improved and the room for market manipulation 
has diminished considerably compared to 2021.  
During 2024, no Member State has declared new crisis levels referred to in Article 11 of the Gas 
SoS Regulation. Finland went back from alert level to early warning and Denmark, Sweden and 
Estonia deactivated the early warning. Declaring a crisis is a precondition for a Member State to 
request application of solidary measures and accordingly, no solidarity requests were made during 
2024.  Based  on  the  survey  to  Member  States,  the  Commission  was  informed  that  no  bilaterial 
burden sharing agreements were signed during 2024.  
The test of the solidarity provisions introduced by  the Gas  Market  Regulation 2024/1789,  also 
confirms that the Member States, the Commission and ENTSOG are prepared for a gas emergency 
and the application of the existing and newly agreed EU provisions on solidarity generally provide 
an  adequate  framework  to  activate  a  rapid  and  effective  crisis  response.  The  new  solidarity 
provisions  extending  the  mechanisms  to  indirectly  connected  Member  States,  allow  access  to 
larger and supposedly cheaper market-based solidarity when the directly connected neighbours are 
in  emergency.  Moreover,  LNG  can  play  a  key  role  in  case  of  a  solidarity  request,  but  the 
effectiveness eventually depends on contractual arrangements between concerned parties. 

Europe’s energy security situation in 2024 is undoubtedly better than in 2022 and stable gas storage 
filling  trajectories  have  contributed  positively.  However,  the  relatively  cold  start  of  the  winter 
2024-25 is depleting gas storages at a faster pace than in 2023, and the overall EU storage level, 
that was historically high during the previous years, decreased to a level equivalent to the pre-
crisis average in just four weeks. In addition, the overall geopolitical context, the stagnating global 
LNG supply and steady  global LNG demand may lead to a tighter global gas balance in 2025. 
Current  market  indicators  do  not  foresee  that  gas  prices  in  the  EU  will  reach  the  record  levels 
observed  in  2022  but  the  risks  associated  with  a  continuously  strained  geopolitical  situation, 
including the potential weaponisation of supply of Russian gas,   remain high and may put some 
pressure on prices.  
This combination of factors is  confirming the relevance of the Gas  Storage Regulation and the 
importance of ensuring high storage levels before the next winter season. 

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