Considerations on COM(2025)99 - Amendment of Regulation (EU)2017/1938 as regards the role of gas storage for securing gas supplies ahead of the winter season

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dossier COM(2025)99 - Amendment of Regulation (EU)2017/1938 as regards the role of gas storage for securing gas supplies ahead of the winter season.
document COM(2025)99 EN
date March  5, 2025
 
(1) Regulation (EU) 2022/1032 of the Parliament and of the Council 2 was adopted in reaction to the gas-supply crisis and unprecedented price increases caused by the escalation of the Russian military aggression against Ukraine since February 2022, impelling the Union to act in a coordinated and comprehensive manner to avoid potential risks resulting from further gas-supply disruptions.

(2) Regulation (EU) 2022/1032 amended Regulation (EU) 2017/1938 by introducing a temporary legal framework for measures regarding the filling level of underground storage facilities to strengthen the security of gas supply in the Union, in particular gas supplies to protected customers.

(3) Gas-storage facilities provide for 30% of the Union’s gas consumption during the winter months, and well-filled underground gas-storage facilities contribute substantially to the security of gas supply by providing additional gas in the event of high demand or supply disruptions.

(4) The laying down of a mandatory target to ensure that gas-storage facilities are 90% full by 1 November (filling target), with a series of intermediate targets for each Member State in February, May, July and September of the year thereafter (filling trajectory), proved to be fundamental amidst the energy crisis sparked by the weaponisation of Russian gas supplies and invasion of Ukraine in both: (i) weathering the gas-supply shortages; and (ii) reducing market uncertainties and price volatility.

(5) Despite the substantial improvement of the gas market situation compared to 2022-2023 period, the European gas market remains tight. More intense competition for global LNG supplies can increase Member States exposure to price volatility. The gas price development during the 2024/2025 winter may confirm the trend. In such situation, the role of gas storages remains paramount. Predictable filling trajectories increase transparency and prevent market distortion.

(6) Pursuant to Regulation (EU) 2017/1938 the obligation of the Member States to follow an annual filling trajectory and to ensure that the filling target is achieved by 1 November of each year expires on 31 December 2025.

(7) At the same time, the overall framework to meet this 1 November target must be flexible enough during the filling season to allow a swift reaction to constantly changing market conditions and in particular to take advantage of the best purchasing conditions.

(8) The purpose of intermediary filling targets, agreed upon each year by the Member States, is to ensure that the mandatory 1 November target is met. However, these targets are indicative and should allow for storage filling in such a way that there is sufficient flexibility available for market participants throughout the year in accordance with Recommendation XXX.

(9) Commission’s assessment of the current energy-security framework has confirmed the positive impact of the storage-filling requirements on the security of gas supply and those positive effects should be preserved beyond 2025.

(10) It is therefore necessary to extend by two years the relevant gas storage filling provisions that provide predictability and transparency as to the utilisation of gas-storage facilities across the Union. 

(11) Regulation (EU) 2017/1938 should therefore be amended accordingly.