Germany's Federal Financial Supervisory Authority has opened a consultation on a draft general administrative order to reintroduce and reset position limits for the European Energy Exchange AG’s German Power Future (Base) and German Power Option (Base) commodity derivative contracts. The draft would set the limit at 20,926,290 MWh for the spot month and 49,873,450 MWh for other months, applying to an account holder’s aggregated net position in trading venue positions and economically equivalent OTC contracts. The draft explains that the contracts now qualify as a significant commodity derivative because open interest, calculated using BaFin’s position reporting data and the methodology in Commission Delegated Regulation (EU) 2022/1302, exceeds the threshold tied to 300,000 tradable units. BaFin also describes the calculation inputs and adjustments, including a deliverable supply estimate of 209,262,895 MWh per calendar month based on ENTSO-E capacity figures and an open interest estimate of 249,365,623 MWh across maturities (with options delta-weighted), and notes that volatility considerations support setting limits below the 25% reference values in the EU methodology. Comments are due by 12 December 2025, after which BaFin will decide whether to adopt the measure. The draft states the order would take effect on 4 February 2026, with immediate enforceability ordered for the position-limit decision, and notes BaFin’s ability to revoke the order if new facts warrant an adjustment.

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