FAQs on transaction reporting – Question II.3.1.44

As we are going to finalize our RRM registration process, we will be very grateful if you could clarify our doubt as regards the way of transmitting our non-standard contract. We have bilateral contract for the purchase of electricity to cover losses, concluded in result of public procurement. The price and volume is known in the moment of concluding of this agreement. We have prepared both: Table 2 (which we are going to send to ACER once a year) and Table 1 (with executions which we are going to send each month).

In your documentation (TRUM) it is said that non-standard contracts specifying at least an outright volume end price shall be reported using Table 1. Is it mean that we should report only Table 1 or that we should report Table 2 and Table 1.


Answer:

If each transaction has a price and quantity defined prior to the delivery of the electricity, these should be reported as bilateral contracts with Table 1. Please see FAQ 3.1.14.

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FAQs on transaction reporting – Question II.3.1.45

Our issue is about bilateral contracts signed after a tender procedure. In France, at the end of the contract award procedure, suppliers whose offer was rejected have 11 days to bring an action against the rejection decision. The contracts are signed at the end of this withdrawal period. Under REMIT, standard contracts have to be reported to the agency no later than the working day following the conclusion of the contract. Under REMIT, what is the date of conclusion of the contract that must be retained: the date on which both parties agree on the transaction or the contract signing date (12 days after)?

Example: A tender procedure ends on January 14th, 2016 by awarding the contract to a supplier. On January 14th suppliers who have not been selected are informed of the decision. They can challenge the decision until January 25th, 2016. If there is no dispute, the contract between the buyer and the supplier selected is signed on January 26th, 2016. When do both parties have to report the transaction to the agency (assuming it is a standard contract)?


Answer:

In case of bilateral contracts signed after a tender procedure the contract signing date should be considered as the date of the contract.

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FAQs on transaction reporting – Question II.3.1.46

I’m responsible for the obligations regarding REMIT at a German energy service supplier and I have a question regarding the allocation of subordinate balancing groups of our clients to our company’s invoicing balancing group.

Those clients may fix forward transactions (specified amount and price) for certain periods in the future. Furthermore those clients can make such transactions with third parties agreeing upon delivery into our company’s invoicing balancing group. The subordinated balancing groups will then be equalized by our company’s invoicing balancing group. In cases clients did not fix forward transactions with neither party subordinated balancing groups’ consumption will be cleared using Day Ahead prices (/ Daily reference prices for Gas).

It is my understanding that it will be sufficient if both (clients and we) will report the contracts governing the balancing group management between us and client to ACER and will then for each delivery period (every month) notify ACER about the monthly measured consumption rated at the average price resulting from the transactions as described above. The forward transactions fixed with third parties will have to be reported to ACER by our clients and their trading partners directly.


Answer:

In our view, when market participants fix forward transactions (price and volume) prior to the delivery of the gas or electricity these transaction should be considered as bilateral contracts. Please see FAQ 3.1.14.

For those transactions where market participants did not fix forward transactions and their consumption will be cleared using Day Ahead prices these should be reported with Table 1 as EXECUTIONS under the framework of non-standard contracts reported with Table 2.

If market participants have a non-standard contract with some flexibility/optionality and the opportunity to also fix the price and quantity ahead of the delivery period they should report Table 2 for the non-standard contract, forward trades with fix price and volume within Table 1 and EXECUTIONS for those transaction where the price and quantity was not fixed. Please see FAQ 3.1.28.

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FAQs on transaction reporting – Question II.3.1.31

Table1 document is rejected because of missing quantity tag. Update from user:

During the 02.25th webinar it was definitely stated, that not necessary to provide quantity value in execution.

Please give us an official recommendation how we can calculate MW value in case:

  1. We have 1-1 for-a-month aggregated delivered energy value for peak, off-peak, deep-offpeak periods.– The unit price is known, and is different at peak, offpeak, and deep-off-peak period.
  2. The 1-1 total amount (cost) is known for peak, offpeak, deep-offpeak period.
  3. Not kwown that how many hours was operating the unit during the contracted periods.
  4. Example :

We have 1000000 HUF total cost, 100 MWh total delivered energy for January for a generating unit, the unit price is 10000 HUF (/MWh). All of the values concerns now the peak period.

What should we calculate for MW value if not known the number of operating hours of the unit in question.


Answer:

Based on the information provided above, it is our view that given that operating hours are not known, this type of contract should be reported using Table 2; Table 1 should be used for the EXECUTION.

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FAQs on transaction reporting – Question II.3.1.47

If we purchase a power schedule (every single hour has another quantity) we ask ourselves, if it’s necessary to report the load profile?

For example: Reporting 8760 single hours, and 35.040 quarter-hour, respectively? Or not?

In our view, we are unsafe, how to report an power schedule. The documents are unequivocal and in this case ambiguous.


Answer:

If transactions with a load profile have different quantity and price for each time interval, each time interval should be reported within the report. If a shaped transaction has 365 * 24 * 4 = 35040 quarterly hour values, all of them should be reported.

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FAQs on transaction reporting – Question II.3.1.32

Reference to documents: TRUM

We are a utility and fall under the REMIT regulation. We ask you to answer us the following questions concerning transaction reporting:

  1. There is a non-standard contract with a defined price and a fixed (no flexibility) volume for the delivery period. The profile of the volume is shaped (every hour another volume). Is it necessary to report executions for this contract, although it is possible to determine the notional amount (data field 38) and the total notional contract quantity (data field 41) for table 1 of the trum?
  2. Market participants are required to report (within table 1) the data fields „Load delivery intervals“ (data field 54), „Delivery capacity“(data field 55), „Quantity unit used in field 55“ (data field 56) and „Price/time interval quantity“ (data field 57). The examples in the annex II of the TRUM implicate that these data fields only have to be populated in case of deals/contracts which have been concluded at an OMP (e.g. an auction). In all other examples in the annex II (including examples for non standard deals) these data fields aren´t populated. Given that we ask you to answer us the following questions:
    1. Have these data fields to be populated in case of OMP contracts/deals only or also in the case of non-OMP deals/contracts?
    2. Have these data fields to be populated only in case of standard contracts or also in case of non-standard-contracts (executions of non-standard-contracts)?
  3. The examples of the annex II in the TRUM indicate that the load type for gas deals is in all cases “Gas day (GD)” irrespective if the load is variable or not variable. Is this correct or do we have to define the load type of deals with variable load profile as “shaped” (as in the case of power contracts)?

Example for 1:

Delivery Period: 01.01.16 (06:00) – 01.01.17 (06:00)

Price: 25 EUR/MWh

Total Volume: 20.000 MWh

Hourly Volume:

01.01.16 06:00 2,3 MWh

01.01.16 07:00 1,8 MWh

01.01.17 06:00 1,2 MWh

Our interpretations of the two cases are

The contract has to be reported using Table 1 of the Implementing Acts because it has a defined price and volume. It’s not necessary to report executions.


Answer:

Based on the information provided above, it is our understanding that, since the contract has defined price and volume, it has to be reported using Table 1 of Commission Implementing Regulation (EU) No 1348/2014. It is not necessary to report executions.

Annex II to the TRUM suggests that examples from one type of contract can be used to report another type of contract.

Based on the information provided above, it is our understanding that the reporting will depend on the contract. If the contract defines the shape, then the shape should be reported. If the contract defines the amount of gas for a day but nomination can be done at any hour of the day, then the gas day values should be reported.

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FAQs on transaction reporting – Question II.3.1.33

I have a few questions related to REMIT reporting I am hoping you can help with.

  1. Is the aggregate delivery point or the sub terminal delivery point required? For example, for Beach contracts at Bacton, would we report the main Bacton terminal, or Bacton SEAL, which is the sub terminal?
  2. In table 1 – fields 38 (notional amount) and 41 (total notional contract quantity) – since we can report non-standard executions after invoicing, do these fields refer to the value of the invoice for that month, rather than the full agreement (which is not a defined amount) which may stretch over a year?

Answer:

Based on the information provided in the first question above, it is our understanding that the delivery point should be reported according to the terminal indicated in the contract. For example, if the contract indicates the sub-terminal, then both parties should use that EIC code.

OR

If the delivery point is at a terminal (e.g. for Beach contracts at Bacton), then the EIC code for the aggregate main terminal can be reported.

With regard to question 2, please see Annex II to the TRUM. (To be finalised)

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FAQs on transaction reporting – Question II.3.1.34

For transactions with a load profile is there the whole profile to be reported? 365 * 24 * 4 = 35040 quarterly hour values for a year profile?

Example: Shaped transaction (load profile) for 2017.

I don’t need to provide the whole load profile but just the information “shaped”.


Answer:

If transactions with a load profile have different quantity and price for each time interval, each time interval should be reported within the report. If a shaped transaction has 365 * 24 * 4 = 35040 quarterly hour values, all of them should be reported.

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FAQs on transaction reporting – Question II.3.1.35

Reference to documents: Implementing regulation No. 1348/2014, Annex (Details of reportable contracts), Table 1, data field 32 Linked Transaction ID

Reporting geographical swaps across EU borders (e.g. one leg with delivery in EU, other leg with delivery out of EU).

Example:

  1. EU market participant performing geographical swap – selling in Germany, Buying in Switzerland
  2. EU market participant performing geographical swap – selling in Hungary, buying in Serbia

Possible interpretations:

  1. Only transaction with delivery in EU is reportable. Linked transaction outside EU is out of scope of REMIT. The respective EU leg is reported as a single transaction

Or

Both legs of geographical swap is reportable as linked transactions as long as one side of trade is in EU.


Answer:

In case of a geographical swap where one leg has delivery in the Union and the other leg has delivery outside the Union, only the leg with the delivery in the Union shall be reported according to Article 3(1)(a) of Commission Implementing Regulation (EU) No 1348/2014.

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FAQs on transaction reporting – Question II.3.1.36

We are a service providers for public utilities. We will conduct REMIT messages for our customers. Regarding the reports we have a question.

Please tell us, if also load profile data, in an hourly (gas) or quarter-hourly granularity (power), must in addition be reported with the messages for shaped gas products (with fixed price)? Or must the shaped-products be reported as standard products (without additional load data)?

Profiled gas contracts with a defined price and quantity should be reported with Table 1.

Must load profile data, in an hourly (gas) or quarter-hourly granularity (power), in addition be reported with the table1-messages?

Example for shaped product:

Company A sells 6000 MWh @ €21 to Company B. The profile of the delivery is:

Jan16: 1,0 MW

Feb16: 2,0 MW

Mrz16: 1,5 MW

Apr16: 0,8 MW

May16: 0 MW

Jun16: 0,2 MW

… etc.

we believe that no load profiles must be reported additionally to the table1-Data.


Answer:

If transactions with a load profile have different quantity and price for each time interval, each time interval should be reported within the report. If a shaped transaction has 365 * 24 * 4 = 35040 quarterly hour values, all of them should be reported.

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