Opacity in the EU Gas Market: Governance, Power, and the Politics of Transparency

The European Union (EU) is one of the world’s largest gas markets and has recently faced unprecedented disruptions, most notably following Russia’s invasion of Ukraine. The EU’s liberalized gas market structure delegates regulatory oversight to EU institutions, while purchasing and delivery remain largely in the hands of private, often transnational, commercial entities. This hybrid governance structure has created a significant informational asymmetry. While the EU bears responsibility for ensuring security of supply and managing crises, it lacks direct access to critical data on gas import contracts, including their duration, volume, and counterparties. Interviews with EU officials reveal a striking disconnect between regulatory oversight and market operations. Even today, there is no centralized repository or systematic overview of gas import contracts. Efforts by the European Commission to collect such information have been repeatedly hindered by claims of commercial confidentiality from importing companies. This opacity has direct implications for multiple policy domains - ensuring security of supply, enabling effective crisis management, and monitoring progress toward decarbonization. This study focuses on one of these dimensions: crisis management. The 2021-2023 energy crisis highlighted how limited contractual transparency undermines the EU’s capacity for coordinated and timely response. Without visibility into who holds which contracts, for how long, and under what conditions, the EU’s collective tools for demand reduction, burden-sharing, and emergency planning remain constrained. This qualitative case study analysis will draw on principal–agent theory and regulatory governance approaches to explain this transparency deficits. From a principal–agent perspective, the European Commission (principal) depends on private companies (agents) for critical information but lacks the mechanisms to compel disclosure. Regulatory governance literature, meanwhile, highlights how transparency is not simply a technical issue but a political one - negotiated among actors with conflicting interests in information control, market stability, and accountability.