Reff & Associates | Deloitte Legal advised Tinmar Energy in challenge against ANRE’s €73 Million fine

The litigation team of Reff & Associates | Deloitte Legal assisted and represented Tinmar Energy S.A. in proceedings challenging a decision of the National Energy Regulatory Authority (ANRE), which imposed on the company a fine of approximately RON 364 million (EUR 73 million at that time), in 2024, for an alleged breach of the EU Regulation on Wholesale Energy Market Integrity and Transparency (REMIT).

The sanction was based on allegations of energy market manipulation allegedly through so-called A-B-A transactions (involving the same market participants reappearing in successive transactions, but on reversed positions).

The fine remains, to date, the largest individual sanction ever imposed in the European Union for an alleged breach of the REMIT Regulation.

Following the proceedings initiated in 2024, the Bucharest Court of Appeal issued a ruling in September 2026 ordering the full annulment of both the ANRE decision imposing the fine and the investigation report on which the sanction had been based. The decision may be challenged before the High Court only on limited grounds expressly provided by law.

Tinmar Energy S.A. was represented in these proceedings by a consortium of three law firms, coordinated by the Reff & Associates | Deloitte Legal team.

The Reff & Associates | Deloitte Legal litigation team involved in the matter was led by Mihnea Galgoțiu-Săraru, Partner, and Alina Stan, Senior Managing Associate, and also included Lucian Savin, Managing Associate, Alin Alecsii, Senior Associate, Sorin Sirbu, Senior Associate, and Iris Manea, Associate.

“Tinmar Energy S.A. is grateful to the Romanian justice for this ruling, which confirms the position consistently maintained by the company since the outset of the proceedings and confirms that the sanction imposed in 2024 lacked both factual and legal grounds. We will continue, both in this case and more generally, to use all legal means available to protect the company’s reputation and interests. We also thank the Reff & Associates | Deloitte Legal team for its assistance and for coordinating the consortium involved in the representation,” said Augustin Oancea, Founder of Tinmar Energy S.A.

“We are honored to have contributed to achieving a result that protects our client’s interests in a case of exceptional complexity and scale. Beyond the specific stakes involved, this judgment represents an important benchmark regarding the standards of evidence and procedural safeguards that must be respected when imposing sanctions of such magnitude, as well as the essential role of judicial review in these circumstances,” said Mihnea Galgotiu-Sraru, Partner, Reff & Associates | Deloitte Legal.