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FAQs on transaction reporting – Question II.1.1.31

As on 1 July the company “XXX” is going to be deconsolidated from the consolidated financial statement of the company “YYY” and it changes status, in the Agency’s view it is reasonable that company XXX should report all its contracts on T+1 month from its status change with the date of its status change.

1         Case1: TSO inserts buy offer for block contract 15:00 – 18:00 at 14:30 (in Balancing phase) with BAL parameter. Other market participant inserts sell offer for the same contract at 14:31 with price and volume which fully match the offer inserted by TSO. The trade match time is 14:40 (in balancing phase).

Which data should be reported in this case to ACER?

2         Case2: TSO inserts buy offer for block contract 15:00 – 18:00 at 14:30 (in Balancing phase) with BAL parameter. Other market participant inserts sell hourly offers 15-16, 16-17 and 17-18 (the same time period as block contract inserted by TSO) at 14:31 with price and volume which fully match the block offer inserted by TSO (cross trade enabled – matching of block contracts with hourly and quarterly contracts). The trade match time is 14:40.

Which data should be reported in this case to ACER?

3         Case3: TSO inserts buy offer for block contract 15:15 – 15:45 at 15:05 (in balancing phase) with BAL parameter. Other market participant inserts sell offer for the same contract at 15:06 with price and volume which fully match the offer inserted by TSO. The trade match time is 15:06 (in balancing phase).

Which data should be reported in this case to ACER?

1.  As is written in the TRUM, we are obliged to report offers and trades inserted/concluded outside the balancing phase. In this case, the block contract starts in the regular Intraday trading and ends in the Balancing phase.

Because we cannot divide the block contract into part of Intraday and part of Balancing phase we are planning to report both block offers and trades as is inserted/matched in the trading platform.

2.  In this case one block contract is matched with 3 hourly contracts and last hour of the block contract is in Balancing phase.

With the same reason as it mentioned on topic 1, we are planning to report all offers (block contract and 3 hourly contracts) and also all trades.

3.  Since offer and trade were submitted/concluded in a balancing phase it is our understanding that these market data will not be reported to ACER.


Answer:

We consider the interpretation provided above reasonable. Whenever a contract for balancing purposes cannot be separated from a contract for the supply, that contract should be reported as contract for the supply.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.1.1.32

We are having some issues with the submission of back loading transaction as they are rejected by a validation rule.  Could the Agency clarify further if back loading transactions can still be reported to the ARIS system?


Answer:

Commission Implementing Regulation (EU) No 1348/2014 clearly establishes that details of wholesale energy products in relation to the supply of electricity and gas executed at organised market places, including matched and unmatched orders, entered into application as of 7 October 2015 and for any other transactions as of 7 April 2016.

The Commission Implementing Regulation also establishes that details of wholesale energy contracts which were concluded before the date on which the reporting obligation becomes applicable and remain outstanding on that date shall be reported to the Agency within 90 days after the reporting obligation becomes applicable for those contracts. Please see also paragraph 3.4 “Start of reporting and reporting frequency” in the TRUM available in the REMIT portal.

This means that back-loading of transactions concluded at organised market places was due by no later than 90 days after 7 October 2015 and 90 days after 7 April 2016 for any other transactions.

The Agency’s system was set to allow back loading of historical data skipping several validation rules. This was done through the submission of an XML file with a date in the filename prior (<) to the date of 5 Oct 2015 00:00:00Z. In this case most of the validation rules were ignored.

This was done to allow market participants to report their back-loading transactions even in those cases where they did not have the full set of information as required by Commission Implementing Regulation (EU) No 1348/2014 for reportable records of transactions, including orders to trade, entered into as 7 October 2015 and 7 April 2016.

However, the Agency had left open the back-loading channel for more than one year in addition to the deadlines set by the Commission Implementing Regulation: 90 days after 7 October 2015 and 90 days after 7 April 2016.

The Agency would like to take this opportunity to reiterate that any transaction executed at an organised market place has to be reported on T+1 day basis and any other transaction on a T+1 month basis and that any transaction reported 90 days after 7 October 2015 and 90 days after 7 April 2016 cannot and will not be considered back-loading, but rather late reporting.

In cases of late reporting, market participants and organised market places should liaise with their RRM as these regularly receive instructions on this topic from the Agency.

The Agency would like to remind that late reporting may constitute a breach of Article 8(1) of REMIT.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.1.1.33

MP has concerns about reports in which one of his counterparties has changed ACER Code during the organization transition process.

Example:
There is a scenario in which there is a contract between party A and party B (ACER codes: ACER-A1 and ACER-B1 respectively) already reported, and at some point in time party A1 (as a result of organizational rebranding/division) receives a new ACER code (ACER-A2). How should such an event be reported to the Agency? In the form of a modification to the original contract or maybe a cancellation of the original one followed by reporting a new contract?


Answer:

In the Agency’s view, the change of the ACER code is a case of novation. As stated in Question 1.1.26 in the FAQ document, all open trades have to be novated with the name of the new legal entity in order to notify the change of the counterparty to the contract. In order to report a novation, an early termination with the old UTI (Action type “C”) and a new trade with a new UTI (Action type “N”) should be reported. This applies to both sides of the trade/contract.
This is also consistent with the ARIS validation rule available on the Agency’s REMIT portal. A change to Field No (1) ID of the market participant or counterparty is not possible, as this is a key component for the identification of the uniqueness of the submitted report. As a result, it is not allowed to report it as “M” (‘Modify’).

RSS_Icon Last update: 20/07/2018  

FAQs on transaction reporting – Question II.1.1.34

Reporting of novation and “novation like” activities.
There are different views in the industry about the reporting process that could require a “novation”. The old contract should terminate when the new contract starts or the new reporting should have the original date of the contract as starting date?


Answer:

In the Agency’s view, the new contract has to be reported with a new date (using Action type “N”), while the old contract has to be terminated (using Action type “C”). Please see also Question II.1.1.17, Question II.1.1.26, and Question II.3.5.6.

RSS_Icon Last update: 20/07/2018  

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