Electricity market agents must adapt to 96 intraday trading rounds

The National Commission on Markets and Competition (CNMC) has issued a resolution modifying the operating rules for the daily and intraday electricity markets to implement 96 negotiation rounds within the continuous intraday market. This regulatory change, detailed in BOE-A-2026-17570, aims to refine the procedures for trading, offer limitations per file, and the participation of agents in the electricity market ecosystem.

What changes

The core of this resolution lies in the structural shift of the intraday market. By increasing the frequency to 96 rounds, the CNMC is fundamentally altering the temporal rhythm of electricity trading. According to the resolution, several key technical and procedural adjustments are now in effect:

• Intraday Market Frequency: The transition to 96 negotiation rounds in the continuous intraday market requires a complete reconfiguration of how trades are executed and settled. This is specifically addressed under the updated rules for sellers (Rule 5.2) and buyers (Rule 6.2).
• Agent Participation: The criteria for who can act as an agent in the daily and intraday markets have been refined. Rule 4.1 establishes the specific subjects qualified to participate, ensuring that the increased frequency does not compromise market stability or integrity.
• Offer Management: The resolution introduces adjustments to the limitation of offers per file and the minimum time required for revising offers following the integration of the PDVP (Price Determination and Verification Platform).
• Communication Protocols: There is a strict new requirement regarding the communication of the registration (altas) and cancellation (bajas) of bidding units. Under Rule 9.1, agents must adhere to specific communication channels involving both the Ministry for the Ecological Transition and the CNMC.

Context

The Spanish electricity market has been undergoing a continuous evolution toward greater flexibility and real-time responsiveness. The previous market structure, while functional, did not allow for the granular level of adjustment required by the increasing penetration of renewable energy sources into the grid. As variable generation increases, the need for a more reactive intraday market becomes critical to balance supply and demand with minimal deviation.

This resolution by the CNMC is not an isolated measure but part of a broader effort to align the Spanish electricity market with European standards of market efficiency. By increasing the number of rounds, the regulator is providing market participants with more opportunities to hedge risks and adjust their positions as real-time weather conditions and consumption patterns change. This move shifts the market from a more static daily model toward a highly dynamic, continuous-flow environment.

Who is affected and how

This regulation does not affect the general public or small businesses (SMEs) directly, but it has a profound impact on the professional entities operating within the energy sector.

Large Companies and Energy Market Agents

This is the primary group affected. Any entity acting as a buyer or seller in the daily or intraday electricity markets must undergo a significant operational overhaul. For these agents, the impact is twofold:

• Operational Complexity: The shift to 96 rounds means that trading desks and automated algorithms must be capable of processing information and executing trades at a much higher frequency. The margin for error in manual processes is effectively eliminated.
• Regulatory Compliance: Under Rule 4.1, agents must ensure their status is correctly maintained and that all bidding units are communicated according to the new standards in Rule 9.1. Failure to comply with these communication protocols could lead to suspension or limitation of participation as per Rules 10.1 and 10.2.
• System Integration: Companies must ensure their internal systems are fully compatible with the updated procedures for offer submission and the new timeframes for offer revision after PDVP integration.

Market Operators

The market operator is tasked with the technical implementation of these 96 rounds. They are responsible for managing the increased data load, ensuring the integrity of the continuous negotiation process, and maintaining the transparency of the information published to agents under Rules 19 and 20.

What to do and when

While the resolution does not specify a single universal deadline for all technical adjustments, the implementation of the 96 rounds implies an immediate need for readiness. Based on the requirements of BOE-A-2026-17570, agents should follow this roadmap:

• Technical Audit: Immediately assess current trading software and algorithmic capabilities to ensure they can handle 96 rounds of negotiation without latency or error (Ref: Rule 5.2 and 6.2).
• Update Communication Protocols: Review and update internal procedures for the registration and cancellation of bidding units to ensure they meet the strict requirements of Rule 9.1.
• Compliance Verification: Ensure that all active bidding units are correctly registered and that the legal status of all agents is compliant with the updated Rule 4.1.
• Risk Management Adjustment: Re-evaluate intraday risk management strategies, as the increased frequency of rounds will change the volatility profile and the speed at which positions can be adjusted.

Given the complexity of these technical changes, we recommend that all affected entities consult with the specialized energy and regulatory department at BMC to evaluate their specific operational impact and ensure full compliance with the new CNMC framework.