The Autoriteit Consument & Markt (ACM), the National Regulatory Authority of the Netherlands, has published guidance on compliance with REMIT Article 4, the requirement to disclose Inside Information on an Inside Information Platform (IIP). An announcement can be found here and the actual guidance here (in Dutch).

The guidance covers several points, including that:

• There were late publications of Inside Information in 2022 and that further sanctions may result this year if this continues.
• The minimum level at which disclosures should be made is usually 50-100MW (in the Netherlands) with a focus on those over 100MW by ACM.
• Disclosures should be made when an asset is impacted by external factors, such as a lack of TSO capacity.
• It is important to separate information flows between those exposed to/disclosing Inside Information and those who trade products affected by the information.