Amendments to the natural gas network operating code – natural gas on the energy exchange – Commentary

On December 29, 2021, the Greek Energy Regulatory Authority (RAE) issued a decision(1) on the Seventh Amendments to the Natural Gas System Operation Code (the Code). The Code includes amendments regarding the operation of the natural gas trading platform by the Hellenic Energy Exchange (HEnEx). The modifications were initially proposed by the natural gas network operator (DESFA) and were then subject to public consultation. On December 19, 2021, DESFA and HEnEx proposed the Model Trading Platform Agreement, and on December 24, 2021, DESFA’s final proposal was adopted by the RAE.

Since 2015, the DESFA has, on a provisional basis(2), organized and operated the balancing platform until the natural gas exchange platform is organized and operational. In 2020, HEnEx initiated the procedures for setting up the natural gas trading platform with a view to finalizing it in January 2022.

Changes to the Code relate to:

  • the transactions carried out within the trading platform and over the counter, which participate in the virtual trading point and the methods of their notification to the DESFA;
  • the main principles of exchange platform agreements regulating cooperation between DESFA and HEnEx in accordance with Regulation 312/2014;
  • the procedures and methods (through continuous exchanges and/or auctions) by which DESFA undertakes exchanges with short-term standardized products for system balancing; and
  • the methodology for calculating settlement prices for negative and positive imbalances.

For more information on this subject, please contact Mira Todorovic Symeonides at the Rokas law firm by telephone (+30 210 361 6816) or by e-mail ([email protected]). The Rokas Law Firm website can be accessed at


(1) n° 1060/2021 (OJ B’ 37/10 January 2022).

(2) RAE Decisions 274/2015 and 774/2019.

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