Europe’s gas storage was about 72.4% full on 3 October, the lowest for that date since records began in 2011, according to the think tank IEEFA. The law says it should be 90% full. But no rule has been broken: the target has built-in exits that can take it down to 70% on paper, and the deadline is 1 December.
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The gas storage target with a trapdoor
Under the amended EU gas storage regulation (Regulation 2025/1733), member states must reach 90% at any point between 1 October and 1 December each year. Before the 2025 change the deadline was 1 November. A country that hits the figure once does not have to hold it until the end of the window, as the Parliament’s own summary of the deal puts it.
Then come the exits. In “difficult conditions” a member state may deviate “by up to 10 percentage points”. A further five points are available if the country produces more gas than it consumed on average over the previous two years, or if a large storage site can only be filled slowly for technical reasons.
And the Commission may add another five points for one filling season by delegated act (a decision it takes without a new law) if unfavourable market conditions persist. The text caps that last increase at “an additional five percentage points”. Stacked together, a 90% target can shrink to 70% on paper.
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A lower bar before the test
The loosening did not wait for this autumn. In March 2026, as gas prices rose with the war in the Middle East, Energy Commissioner Dan Jorgensen suggested “legislative flexibilities” to reach a target of 80%, Romanian outlet Informat.ro reported.
IEEFA says the Commission called on countries to lower their targets to 80% to avoid panic buying. The Commission’s own storage page mentions no such request and says only that it “has the possibility to further reduce the target, if unfavourable market conditions persist”.
The regulation applies until the end of 2027. So the rule that exists to protect households and industry from a winter shortage comes with a standing right to relax it exactly when the market makes it expensive to follow.
Who pays for the gap
IEEFA projects that storage could deliver 7.3 billion cubic metres less gas this winter (November to March) than last winter. Combined with the ban on Russian LNG imports from January 2027, it says the EU may need to burn 14 billion cubic metres less, about 7% of consumption. Filling the storage gap with extra imports instead would cost about EUR 3 billion, 12% above what the same volume cost in 2025.
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IEEFA argues for demand cuts and against leaning on storage, so its framing deserves scepticism. The national measures it lists are on the record. The Netherlands cleared up to EUR 993 million in June for state-owned EBN to build reserves, Germany ordered state-owned importer SEFE to store 8 terawatt-hours by 15 December, and Spain raised the LNG held at its terminals by more than 25%.
IEEFA itself says the low level “does not mean EU gas storage will run dry this winter”. Europe’s gas grid operators, quoted by Euronews, warn that a severe winter could leave the bloc up to 15% short of the gas it needs.
A statistic inside an open window
The 72.4% reading on 3 October describes the tanks, and the law has not been broken, because the window runs to 1 December and every deviation clause is still available. The real test comes when the figure for 1 December arrives and a member state or the Commission explains which of the three exits it used. A target that can be lowered by 20 points, one season at a time, is a forecast with a legal stamp on it.
SOURCES & METHOD
How this article was made. The article rests on six sources. Three are official: the Council text PE-CONS 27/25 amending the gas storage regulation, the Commission’s gas storage page and the European Parliament’s note on the deal with the Council. The think tank IEEFA and Euronews supply the winter demand warning, and Informat.ro, a Romanian outlet, reports the lower target.
Sources
- Council of the EU: PE-CONS 27/25, Regulation amending Regulation (EU) 2017/1938 on gas storage (2025) – Article 6a: filling window and the deviation clauses 5a, 5b and 5c.
- European Commission: Gas storage – the 90% target, the 1 October to 1 December window, Regulation 2025/1733, validity to end 2027, the possibility to reduce the target further.
- European Parliament: Gas storage, deal with Council on refill flexibility (23 June 2025) – the agreed flexibility, extension to 31 December 2027.
- IEEFA: EU may need to cut winter gas demand by 7% with gas storage at a record seasonal low (9 October 2026) – storage at 72.4% on 3 October, 7.3 bcm and 14 bcm projections, EUR 3 billion cost, the 80% request.
- Euronews: EU may need to cut winter gas demand by 7% as storage hits record low, IEEFA warns (9 October 2026) – the same figures, national measures, grid operators’ warning.
- Informat.ro: The EU reduces gas storage targets for next winter (21 March 2026) – Commissioner Jorgensen’s suggestion of an 80% target.









