French energy regulator fines German company 500,000 Euros for failure to provide requested information

In a landmark decision, France’s energy regulator has fined J.P. Morgan SE (JPMSE) €500,000 for failing to provide critical information during an investigation into soaring electricity prices in 2022. This marks the first-ever sanction by the Dispute and Sanctions Committee (CoRDiS) of the Commission de régulation de l’énergie (CRE) for non-compliance with data disclosure obligations under the French Energy Code.

What Happened?

Amid an unprecedented spike in wholesale electricity prices in 2022—especially for contracts covering winter 2022–2023—the CRE launched a broad inquiry. It contacted 44 market participants to understand pricing strategies and market behavior. 43 companies complied. JPMSE, headquartered in Germany, did not.

JPMSE argued that the CRE lacked authority to demand information from firms based in other EU countries. Despite repeated requests and a formal warning, JPMSE refused to disclose key client data related to electricity trading activities in France.

The Legal Basis

Under Article L. 134-18 of the French Energy Code, the CRE has the right to collect all necessary information from any company operating—directly or indirectly—on the French electricity market. CoRDiS ruled that JPMSE, by facilitating trades for clients, was indeed active in the French market and therefore subject to this obligation.

Eventually, on 22 April 2025, CoRDiS imposed a €500,000 fine on JPMSE. The decision will be:

• Published on the CRE’s website for one year, naming the companyIncluded in JPMSE’s next financial statement, with a mandatory disclosure banner
• This case sets a precedent for cross-border regulatory enforcement in the EU energy sector and reinforces the CRE’s authority to demand transparency from all market players.

With appreciation to Amineh Farasatmand for her contribution in preparing this blog.