(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 (1) introduced binding minimum gas storage targets to enhance energy security and resilience in the Union. The implementation of these targets has been instrumental in safeguarding gas availability, especially during periods of high gas demand and market volatility and uncertainty, as evidenced by the EU’s gas storage facilities reaching a filling level of 90 % or more ahead of each of the last three winters. Gas storages continue to provide for 30 % of the EU’s winter gas consumption and flexibility to the electricity system.

(2)

The situation on the European gas market has improved considerably since 2022, although the exposure to price volatility remains notably due to the higher share of LNG in the European energy mix and increased competition for global LNG supplies under the geopolitical context.

(3)

Since November 2024, the European gas market experiences a situation when contracts for gas deliveries during summer 2025 are more expensive than contracts for gas deliveries during the winter 2025-26 (negative summer – winter price spread) and as a consequence, commercial incentives for gas undertakings to store gas for next winter are weaker than in the previous filling seasons.

(4)

At the same time and while the gas demand in Europe has dropped by almost 20 % since 2022, the gas storage levels at the end of the heating season 2025 are expected to be lower compared to the last two years, although similar to the pre-crisis average filling levels (2) and significantly above 2022 levels. This will require injection of more volumes over the summer to fill the storages ahead of the winter 2025/2026 compared to the previous two seasons.

(5)

In this volatile and complex environment, it is crucial to maintain the essential role of gas storage facilities in ensuring security of supply by upholding the mandatory 1st of November filling target. At the same time, providing Member States with sufficient flexibility to fill storage facilities throughout the summer season at optimal purchase conditions, will reduce system stress and avoid market distortions under current market circumstances.

(6)

It is equally important in this context to abstain from national measures that may negatively affect the gas market or compromise the energy security situation in another Member State or of the European Union. Where there are entities mandated to implement gas storage filling, these should strive to pursue prudent trading strategy that seeks to avoid a significant negative impact on the spot and derivatives markets.

(7)

The gas storage provisions currently in force, in particular Article 6(a) and 6(b) of Regulation (EU) 2017/1938 of the European Parliament and of the Council (3), expire in December 2025.

(8)

This implies that the flexibility to fill storages throughout 2025 must be sought within the existing legislative framework. Guidance on how to identify and apply flexibility provisions within the existing legislative framework may assist the Member States to better coordinate and smartly design their storage filling policies ahead of winter 2025/2026.