Andrey Delchev & Partners Law Firm, represented by attorneys Boryana Chotekova and Ivaylo Katov, successfully defended before the court of first instance a decision of the Energy and Water Regulatory Commission (EWRC) imposing a financial penalty of BGN 604 064 on Kozloduy NPP EAD for a violation of Article 3(1)(a) of Regulation (EU) 1227/2011 of the European Parliament and of the Council of 25 October 2011 on wholesale energy market integrity and transparency (“REMIT”), namely: violation of the prohibition on the use of inside information for wholesale energy trading to which that information relates. By Decision No. 37454/13.11.2025, the Administrative Court of Sofia City rejected the appeal of Kozloduy NPP EAD against the Decision of the EWRC.
The violation took place in 2021 and involved Kozloduy NPP EAD conducting transactions on the “Day Ahead” and “Intraday” segments of the Bulgarian Independent Energy Exchange EAD before publicly announcing the completion of the planned annual maintenance of Unit 6. This constitutes the unauthorized use of inside information, in breach of REMIT.
The contested decision is the first decision of the regulator establishing a violation of art.3 of REMIT. The Regulation, as amended by Regulation (EU) No 2024/1106 of the European Parliament and of the Council of 11 April 2024, strengthens rules against energy market abuse by adding obligations like registering with national regulators, detailed data reporting to Agency for the Cooperation of Energy Regulators, disclosing inside information, and strict prohibitions on insider trading and market manipulation for electricity, gas, and LNG markets.
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