FAQs on transaction reporting – Question II.2.1.31

Data Field (35), (38), (40), 41 and (42)

Does ACER care if we submit a trade in kWh and the counterparty submits the opposite side in MWh? Or I submit one side in GBX (pence) and the other side is submitted in GBP (pounds)?

This is unlikely to be a problem where the OMP generates both sides of the trade, but it could happen if the MP is deriving the information themselves.

Second question – if I report NBP gas as an example in one unit, and another broker reports it in the other unit – will that cause a problem? Will ACER define a standard list of units for each delivery point, or will ARIS internally convert all units into one ACER common reference unit for comparison.

I would prefer you to accept all variants of this, otherwise you will have to describe a “reference” implementation for everything, which takes time to do and then time for everyone to implement and time is something that we don’t have a lot of!


Answer:

Transaction reports for orders to trade and trades executed at Organised Market Places should be reported in the unit as advertised by the Organised Market Place. If market participants decide to report their transactions through third parties (e.g. RRMs), they should not indicate other units or currency than the ones advertised by the Organised Market Place for that contract.

With regard to calculated values such as Total Notional Amount and Total Notional Quantity, it is possible to report the information in different units, e.g. EUR or EUX (but not GBP instead of EUR) and MWh or KWh (but not MWh instead of GJ).

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FAQs on transaction reporting – Question II.2.1.32

Data Field (39)

The TRUM requires field 39 to be in the “major” unit to avoid “avoid unnecessarily large values”.

Is this necessary to stipulate?

Can we remove this recommendation as it will cause a layer of hard coding and translation that I do not believe is necessary and adds additional complication to our interface as the more things we hard code, the more things we potentially get mixed up.
The schema allows a 15+5 decimal number, so even if you report in the minor unit this allows 13 digits for a GBP or EUR amount – so a single trade of up to 9.9 trillion GBP, which is about the GDP of the whole of Europe for a year.


Answer:

The current version of the TRUM is under revision and the description of field 39 will be amended to clarify this further. Reporting parties can report in the currency stored in their system, but only for notional amount and notional quantity. For prices displayed on the Organised Market Place’s screen, the unit visible to the market should be reported. This applies to both Quantity/Volume and Price.

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FAQs on transaction reporting – Question II.2.1.33

Data Field (40)

Trading Electricity day shaped voice brokered order. Is it possible to report zero power quantity <TradeList/TradeReport/priceIntervalQuantityDetails/quantity> in example 03.11? OMP provide market participants with possibility to trade orders through broker screen with different power in different hours. In some hours the power can be 0 (zero) MW or nothing.  Do we have to report these “empty” hours?

Hours where there is power offered doesn’t need to be reported.

Both trades and the order will have the same Unique Transaction ID that will link them together.


Answer:

Please see Annex II of the TRUM, trading examples for auction and continuous markets.

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FAQs on transaction reporting – Question II.2.1.34

Data Field (43)

TerminateDate is defined as DateTime in the schema but as a date in the TRUM document.

Suggested solution:

<xs:element name=”terminationDate” type=”xs:dateTime” minOccurs=”0″>

<xs:annotation>

<xs:documentation>Field No. 43</xs:documentation>

</xs:annotation>

</xs:element>


Answer:

When reporting the termination date this can be reported as YYYY-MM-GGT00:00:00, for example:

<terminationDate>2014-07-31T00:00:00</terminationDate>

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FAQs on transaction reporting – Question II.2.1.35

Data Fields (48 to 57)

Cash-settled trades reported under EMIR do not require a delivery schedule. Can ACER confirm that MPs who report such trades to their EMIR repository have no obligation to report the delivery schedule?

Example: Participant reports a cash-settled trade to an EMIR trade repository. The Participant omits the delivery schedule from the trade report.

If a MP reports a trade under EMIR, this is sufficient to meet the MP’s REMIT reporting obligation, even if the MP reports the trade without a delivery schedule.


Answer:

Market participants that report a cash-settled trade to EMIR trade repositories (TRs) should seek TRs or ESMA’s guidance.

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FAQs on transaction reporting – Question II.2.1.36

Data Field (48)

Reference to documents: Annex Table 1 (details of reportable contracts) of Regulation (EU) No 1348/2014

Please be advised of the following data issue which has been identified by our company (OMP)

For pure financial products which never result in physical delivery, what should be filled in for field 48 (delivery point or zone).

Two examples

  1. Spread Dutch TT / Italian PSV
  2. German Power Financial

Please note that there is no consistency between the OMPs. For example for German Power. There are 4 different EIC codes used, but also not applicable and blank.

See https://www.acer-remit.eu/portal/standardised-contract

Because there is no physical delivery, the most logical approach is to make this field not applicable. To avoid misunderstanding (parties forgot to add a EIC code where applicable), it is advisable to use a fictive EIC code, for example 99X-NOT-APPLIC–


Answer:

It is our understanding that every contract related to the supply of electricity or gas, irrespective of if the contract is a spot, a physical forward, a future or an option contract has a reference to a delivery period and a delivery point. Also financial products that are settled in cash and never result in physical delivery have a reference price or other attributes which relate to the commodity. In this case, reporting parties should refer to the reference price or other attributes which relate to the electricity or gas and report its delivery point.

For contracts that involve more than one delivery point, all of them should be reported.

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FAQs on transaction reporting – Question II.2.1.37

Data Field (48)

A Market Participant is buying gas for its own needs (fuel gas) outside an OMP via bilateral contract. The delivery point of the gas under the contract conditions (where the commodity changes hands) is an Entry point ABC from production facility. The point ABC is a connection point between the production facility and the gas transmission system of the TSO.

For reporting purposes under the requirements of Article 3(1)(a) of Commission Implementing Regulation (EU) N1348/2014, what data shall be provided in the respective field of schema REMITTable 1 or REMITTable 2: DELIVERY POINT OR ZONE – the EIC of the Entry point ABC or the EIC of the Balancing zone to which the gas is entering?

If the EIC of the Entry point ABC shall be filled in the XML field DELIVERY POINT OR ZONE, the MP needs to add said EIC code to the list of valid EICs. Could you please confirm that it will be possible to add such an EIC via the Agency’s web-tool for mapping/supply of EIC information, e.g. via using “Other” in the point type drop down?


Answer:

The EIC of the Balancing zone should be reported. There is no need to add the Entry point ABC via the Agency’s web-tool for mapping/supply of EIC information.

The same would apply to Domestic/Industrial aggregate points and Distribution zones/networks. If these points are connected to a balancing zone from where the gas/electricity is withdrawn/supplied from, the EIC of the balancing zone should be reported.

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FAQs on transaction reporting – Question II.2.1.38

Data Field (48)

A Market Participant is buying gas for its own needs (fuel gas) outside an OMP via bilateral contract.

The delivery point of the gas under the contract conditions (where the commodity changes hands) is a connection point between a storage facility and gas transmission system. The point name is XYZ. Point XYZ is bidirectional.

XYZ (entry) is the point direction from the Storage facility to the Gas transmission system;

XYZ (exit) is the point direction from the Gas transmission system to the Storage facility.

Q. 1  For reporting purposes under the requirements of Article 3(1)(a) of Commission Implementing Regulation (EU) No 1348/2014, what data shall be provided in the respective field of schema REMITTable 1 or REMITTable 2:

  • DELIVERY POINT OR ZONE, if the commodity changes hands at XYZ (entry) or
  • the EIC of the connection point between a storage facility and gas transmission system (XYZ entry) or the EIC of the Balancing zone to which the gas is entering?

Q. 2  For reporting purposes under the requirements of Regulation (EU) No 1348/2014, point 3.1 (a), what data shall be provided in the respective field of schema REMITTable 1 or REMITTable 2: DELIVERY POINT OR ZONE, if the commodity changes hands at XYZ (exit)?


Answer:

Q 1. The Balancing zone the gas is entering into.

Q 2. The Balancing zone the gas storage facility belongs to.

Q 3. There is no need to add a connection point between a storage facility and gas transmission system via the Agency’s web-tool for mapping/supply of EIC information.

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FAQs on transaction reporting – Question II.2.1.39

Data Field (48)

Could the Agency clarify the reporting of EICs and their mapping to the balancing zones/areas, interconnection points, LNG and storage facilities?


Answer:

In the Transaction Reporting User Manual (TRUM) after consulting the industry through two public consultations, the Agency has indicated that the Energy Identification Code (EIC) to be reported for transaction reporting purposes for Table 1 and Table 2 has to identify the commodity delivery point or zone.

This field reports the EIC Y code (or an alternative code to be agreed with the Agency if the EIC is not available) to identify the delivery and/or balancing point for the contract. In addition, the TRUM clarifies that since gas can also be delivered at the interconnection point, then the EIC Z Code for that interconnector may be used.

Furthermore, in the FAQs on transaction reporting – Question II.3.1.23, the Agency has indicated that where the gas is delivered at an LNG or a gas storage facility, then the EIC W code for that facility should be reported.

Based on more than 1 billion transactions (Table 1 and Table 2) reported to the Agency, it was found that market participants and organised market places are using more than 4000 codes to indicate the delivery points. In some occasions more than 1000 different codes were used to indicate the same balancing zone.

Since the Agency (supported by the input provided by the industry) does not find this diversification reasonable and has seen that 95% of the overall transactions have been reported with the correct EICs, on 26 June 2017 the Agency has published Annex VI to the TRUM (including the list of accepted EICs) in the REMIT portal and will only consider the codes listed in the list of accepted codes.

In the Agency’s view, if 95% of the reported transactions are compliant with REMIT, there is no reason for the remaining 5% of transactions to be reported with alternative codes.

Market participants that use different codes for nomination purposes at domestic/industrial aggregate points, distribution zones/networks or production sites should report in any case the EIC of the balancing zone these points are connected to. While they may want to keep using those codes for nomination purposes, they will need to translate those codes into the EIC of the balancing zone they are related to when reporting the transaction to the Agency for REMIT purposes.

With regard to interconnection points, the Agency has explained in Annex VI to the TRUM that the reportable Y EIC code has to belong to the interconnection point where gas is delivered and then transferred to the other side of the interconnection point by the system operator. This case applies to unbundled interconnection capacity only.

In Annex VI to the TRUM the Agency has explained that only the EICs in the list of accepted codes are reportable codes. All the other codes available in the sheet “EICs Validity Check” and flagged as “Invalid” , “ENTSO-E” and “Missing” (please carefully read Annex VI to the TRUM) are not considered compliant with the Agency’s guidance according to Article 5(2) of Commission Implementing Regulation (EU) No 1348/2014.

However, in order to help market participants and organised market places to comply with REMIT, the Agency has given the opportunity to clear their transaction reporting history (related to the EICs) through the online “EIC mapping form” (please see Annex VI to the TRUM for the link).

The online form allows reporting parties to map a previously reported EIC (Missing, Invalid, ENTSO-E list) to a code listed in the “List of Accepted EICs” and to report a code for a zone/area/facility that is not included in the “List of Accepted EICs” (or changing its name/function).

However, market participants that have submitted new codes for domestic/industrial aggregate points, distribution zones/networks or production sites connected to a balancing zone, should not expect the inclusion of those codes in the list of accepted codes, unless the Agency believes there is reasonable ground for their inclusion in the list.

The Agency has already updated the list of EICs codes to accommodate TSOs or market participants requests where the Agency believed there was a reasonable ground for the inclusion of new EICs (this is visible in the EIC list of accepted codes spreadsheet attached to Annex VI to the TRUM).

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FAQs on transaction reporting – Question II.2.1.40

Data Field (48)

A Market Participant is buying gas for its own needs (fuel gas) outside an OMP via bilateral contract. The location where commodity changes hands under the contract conditions is a Gas storage facility.

For reporting purposes under the requirements of Regulation (EU) No 1348/2014, point 3.1 (a), what data shall be provided in the respective field of schema REMITTable 1 or REMITTable 2: DELIVERY POINT OR ZONE – the EIC of the Gas storage facility or the EIC of the Balancing zone to which the Gas storage facility belongs?


Answer:

 

Assuming that the seller is withdrawing the gas from the system and injecting it into the storage, then handing it over to the buyer, or if the seller sells the gas that he already owns in the storage to the buyer, the EIC of the Gas storage facility should be reported.

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