Confindustria has submitted its comments to ARERA on Consultation Document 198/2026/R/gas, concerning the implementation of the liquidity service provided for in Article 10 of the 2026 Energy Bills Decree.

This measure is of particular interest to the industrial sector, as it aims to increase liquidity in the PSV gas market and to promote greater alignment with the TTF, with potentially significant effects both on the direct costs of gas for gas-intensive businesses and, indirectly, on electricity costs.

In its response, Confindustria emphasises the need for operational procedures to be defined in such a way as to ensure that the measure is genuinely effective, stable and measurable in the reduction in the PSV-TTF spread, ensuring that the benefits are passed on to businesses.

In particular, Confindustria supports the introduction of an integrated, multilateral auction on the MGP-GAS, but stresses the need to carefully assess its impact on market indices, particularly the IGI and ICIS-Heren, which are currently used as benchmarks in wholesale natural gas purchase and sale contracts.

The main points highlighted include:

• the need to ensure transparency regarding the outcomes of the procedures and the actual pass-through of benefits to industrial customers;
• the opportunity to define in advance the service allocation sessions, both annual and interim, in line with the timetable for the allocation of transmission capacity on the PRISMA platform;
• the need to align premiums and volatility charges with the actual costs of transmission capacity, particularly in the case of allocations on an infra-annual basis;
• the need to ensure transparent conditions for access to capacity on the Swiss section, which is relevant to the application of the measure at the Passo Gries entry point;
• the need to provide for appropriate exemptions from the application of charges in the event of maintenance work, unavailability of transmission capacity or force majeure;
• the proposal to assess two separate services – one for annual baseload and one for the winter months – taking into account the higher volumes and wider spreads during the winter period.

Confindustria also believes that any decision to make the MGP-GAS auction a permanent feature should only be taken following in-depth assessments by ARERA and with sufficient advance notice, in order to avoid impacts on market indices and existing contracts that have not been adequately considered.

As regards the integration of the Italian and German gas markets via Swiss infrastructure, Confindustria believes it would be appropriate to defer the discussion to a subsequent ARERA consultation paper, in which specific proposals are set out.