EU Minimum Filling Storage Obligation

The European Union has adopted a new Gas Storage Regulation to foster security of gas supply:

Storage Filling target. On June 29, 2022, the European Parliament adopted Regulation (EU) 2022/1032 to protect against risks of future supply disruptions. Pursuant to the Regulation, gas storage facilities in the EU must be filled to at least 90% of their capacity (see current storage filling levels here). The 90%[1] filling target must be reached “by 1 November each year”, i.e., before wintertime. Intermediate targets apply through the year.

Solidarity. To share the financial burden involved in filling EU storage capacities, Member States lacking storage facilities on their territories must store 15% of their annual domestic gas consumption in Member States with storage facilities.

Certification of storage system operators. Authorities of each Member State are in charge of ensuring that storage system operators are free from external influence which could endanger security of supply or “any other essential security interest at national, regional or Union level”. The authorities can make certification subject to conditions, including that the storage system owner or storage system operator transfer management of the storage system. If certification is refused, the authorities can require disposal of the shareholding or rights over the storage system ownership or storage system operator. They can also adopt interim measures.

Statement on Energy by President von der Leyen issued on September 7^th, 2022:

“We have created a joint storage, and this is really a success story, because now we are already at 82% with the joint storage in Europe. As you know, our goal was to reach 80% at the end of October. So we overshoot it, and that is good.”

Links to EU Regulations/Statements and News Stories on EU Gas Storage:

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January 2023:

• German gas storage operators optimistic for next winter | Reuters

November 2022: 

• Regulation (EU) 2022/2301 of 23 November 2022 setting the filling trajectory with intermediary targets for 2023 for each Member State with underground gas storage facilities on its territory and directly interconnected to its market area
• Commission sets trajectories for filling gas storage in 2023 (europa.eu)
• Column: Europe’s gas storage peaks after record refill season | Reuters
• German gas storage could quickly empty after a few frosty days - network regulator chief | Reuters
• Preparing for winter, Italy gas storage hits 95% capacity | Reuters

October 2022:

• Germany hits 95% gas storage target ahead of schedule, urges gas savings | S&P Global Commodity Insights (spglobal.com)
• Berlin Claims to Have Reached its 95% Gas Reserves Filling Target - Energynews.pro

September 2022:

• Dutch gas reserve now at 90% of capacity, exceeding EU target of 80% | NL Times
• Gas, in Italia stoccaggio al 90%. Siamo autonomi per l’inverno? - Il Sole 24 ORE
• France has filled up its strategic gas reserves ahead of winter - minister | Reuters

August 2022:

• Belgium fills gas reserves but winter shortages still likely (brusselstimes.com)

July 2022:

• All eyes on gas storage - Florence School of Regulation (eui.eu)

June 2022:

• Council adopts regulation on gas storage - Consilium (europa.eu)
• Energy Security: Commission welcomes swift adoption of new gas storage rules

[1] Please note that: (1) For 2022, on a transitional basis, the 90% target is reduced to 80%; (2) had a Member State significant storage capacity (in excess of its gas demand), the 90% filling target could be reduced up to 35% of its average annual gas consumption over the past five years.