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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FAQs on transaction reporting – Question II.3.1.21

Contracts for the supply of LNG before the entry flange (FAQs on REMIT transaction reporting, Answer to Question 1.1.9) of an EU LNG regasification terminal  include, for example an exchange of title on the high seas with a free delivery clause/full diversion rights or at a non- EU liquefaction terminal. Based on the principle that the above delivery points are not at an EU LNG regasification terminal, then these contracts should not be reported.

However, if the buyer subsequently decides to send a cargo bought under this type of contract to an EU LNG regasification terminal, the cargo unloading will be subject to fundamental data reporting by the buyer. If the cargo — once bought under this type of contract — is “re-traded” by the buyer at or after the entry flange of an EU LNG regasification terminal then the contract relevant to this new transaction will be subject to reporting.


Answer:

In the Agency’s view contracts for the supply of LNG before the entry flange of an EU LNG regasification terminal, for example an exchange of title on the high seas outside the E.U., are not subject to transaction reporting.

Cargos traded under such contracts are subject to the reporting of fundamental data provided once the cargo is unloaded at an EU LNG regasification terminal.

If the cargo – once bought on the high seas outside the E.U. under this type of contract is re-traded by the buyer at or after the entry flange of an EU LNG regasification terminal then the transaction related to the new contract will be subject to reporting.

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FAQs on transaction reporting – Question II.3.1.22

Contracts for the supply of LNG at the flange of an LNG regasification terminal should not be reported unless there is an obligation to deliver to at least one EU LNG regasification terminal.  In case of contracts with flexible delivery location including non EU destinations, this obligation arises only when a commitment is made to deliver a cargo at an EU LNG regasification terminal.

Once a cargo is confirmed to be delivered at an EU LNG regasification terminal, the transaction and commercial details relating to the cargo delivery can be reported using table 2 and after delivery, an “execution” via table 1 will be reported.  Such reporting would apply to each cargo under “multi cargo or single cargo deliveries” contracts.

For multi cargo deliveries where all terms are similar for every cargo (e.g. price, delivery location, etc), the Market Participant could take a more efficient approach and ignore the “per cargo” approach. It could report the transaction and commercial details via a single table 2 and the aggregated volume and price of executions once known via table 1.

Please see examples in Annex I.


Answer:

The Agency has discussed the following scenarios with its stakeholders. In the Agency’s view the following scenarios may occur:

Scenario 1: Single cargo supply contract agreement is made on the day the contract is signed (10th April 2016) that delivery will be at an EU LNG terminal. Delivery is due on 1st June. Cargo is made on 1st June and volume is 99% of estimated total.

This should be reported with: Table 2 for Non-standard contracts within 1 month from the day the delivery into the EU was agreed + Table 1 for the EXECUTION (delivery) within 1 month from the when price and volume are known.

Scenario 2: Single cargo supply contract, originally agreed to deliver to a Non-EU LNG terminal on the day the contract is signed, (April 10th 2016) but at a later date (May 12th 2016) the delivery optionality is exercised and parties agree  to deliver to an EU LNG terminal . Delivery is due on 1st August. Delivery is made on 1st August and is 98% of estimated total.

This should be reported with: Table 2 for Non-standard contracts, within 1 month from the day the delivery into the EU was agreed + Table 1 for the EXECUTION (delivery) within 1 month from the when price and volume are known.

Scenario 3: Multi cargo supply contract and buyer has the option to choose where delivery is made globally depending on commercial preference at the time. Signed on 10th April 2016- agreed to deliver 10 cargos (each cargo 3million mmbtu) over 3 years to any LNG terminals in the world. On 7th September 2016, the parties agree to deliver one of the cargos to an EU LNG terminal. Delivery is due 1st December 2016. Delivery is made on 1st and 2nd December and is 102% of the estimated total.

This should be reported with: Table 2 for Non-standard contracts for the cargo, within 1 month from the day the delivery into the EU was agreed + Table 1 for the EXECUTION (delivery) within 1 month from the when price and volume are known. Any subsequent delivery / cargo delivered into the EU will be reported similarly.

Scenario 4. Single cargo supply contract, originally agreed to deliver to an EU LNG terminal on the day the contract is signed, (April 10th 2016) but at a later date (May 12th 2016) the delivery optionality is exercised and parties agree to deliver to a non-EU LNG terminal  instead.

This should be reported with: Table 2 for Non-standard contracts within 1 month from the day the delivery into the EU was agreed + Lifecycle event (Cancel) once the commercial agreement has been made to deliver to a non-EU location within 1 month from the day it was agreed to deliver the cargo to a non-EU LNG terminal.

Scenario 5: Multi cargo supply contract signed on 10th April 2016- agreed to deliver 10 cargos (each cargo 3million mmbtu) over 3 years, all with the same volume, price and delivery location which is an EU LNG terminal. First delivery is due 1st May. Delivery is made on 1st May and volume is 101% of estimated total.

This should be reported with: Table 2 for Non-standard contracts within 1 month from the day the delivery into the EU was agreed + Table 1 for the EXECUTION (delivery) per cargo, within 1 month from when price and volume are known.

Scenario 6: Spot in tank transfer Agreed to deliver gas in tank at an EU LNG terminal – fixed quantity of gas with spot delivery, at a fixed price. Contract is signed on 1st October for delivery on 2nd October.

This should be reported with: Table 1 for Non-Standard BILCONTRACT contracts with outright price and volume for the contract (as per normal pipeline gas supply contracts with outright price and volume) within 1 month from the when price and volume are known.

Scenario 7: Term in tank transfer. Agreed to deliver gas in tank at an EU LNG terminal – variable quantity over a 3 month delivery, with a formula based price. Contract signed 1st May and first months deliveries occur daily over May, June, July.

This should be reported with: Table 2 for Non-standard contracts within 1 month from the day the delivery at EU LNG terminal was agreed + Table 1 for the EXECUTION (delivery) per invoicing cycle period (i.e.  monthly as per normal non-standard pipeline gas supply contracts) within 1 month from the when price and volume are known

Any contracts that were outstanding on 7 April 2016 should be reported as back loading, same as for any other contract for the supply of gas or electricity.

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FAQs on transaction reporting – Question II.3.1.23

Contracts for the supply of LNG after the entry flange of an EU LNG regasification terminal should be reported by both parties and the EIC W code for the facility should be used. Depending on the characteristics of the contract, table 1 or Table 2 formats may be used, according to TRUM guidance article 3.2.5.


Answer:

In the Agency’s view the EIC W code is the correct EIC code to be reported. Please see FAQ 1.1.16: “Where contract for the supply of gas may be delivered at an LNG or a gas storage facility, then the EIC W code for that facility should be reported.”

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FAQs on transaction reporting – Question II.3.1.24

LNG commercial transactions, associated with reloads at an EU LNG regasification terminal, (which are physical operations), are only  reportable when the contract explicitly specifies a delivery point to be at or after the entry flange of an EU regasification terminal.  For example, a reload can be associated with the following commercial transactions:

1. At the origin EU regasification terminal:

  • No title transfer happens, so there is no transaction reporting required (eg counterparty A reload gas from its in-tank inventory).
  • A title transfer happens in tank or at or after the entry flange, then this transaction is reportable (counterparty A transfers title to counterparty B at the flange which loads a cargo).

2. At the destination regasification terminal:

  • In case of a title transfer happens, paragraph A1-3 applies.
  • If there is no title transfer or commercial transaction, there is no transaction reporting.

NB: The physical operation of reloading is covered by fundamental data reporting.


Answer:

One terminal

In the Agency’s view it is reasonable to say that, if the reload occurs at the origin EU regasification terminal and no-title transfer happens there is no transaction reporting required. Market participant A reload gas from its in-tank inventory.

However, if a title transfer happens in tank or at after the entry flange, then this transaction is reportable if counterparty A transfers title to counterparty B at the flange which loads a cargo.

Two terminals

Whereas a title transfer happens at an EU destination (Market participant A reload its own cargo from any (EU or non-EU) LGN facility and sell it to Market participant B at another EU LNG facility, destination) this transaction is reportable.

If there is no title transfer or commercial transaction, there is no transaction reporting.

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FAQs on transaction reporting – Question II.3.1.25

In the event that a decision is taken to divert a cargo from the EU terminal already notified to ACER then there might either be an amendment to the original transaction (where the new destination is within the EU) or a cancellation of the original transaction (where the new destination is outside of the EU/not known by the seller).


Answer:

In case of cargo diversion from an EU terminal for a transaction already reported to the Agency, a modification (M) to the original transaction (where the new destination is within the EU) or a termination (C) of the original transaction (where the new destination is outside of the EU/not known by the seller) should be reported.

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FAQs on transaction reporting – Question II.3.1.26

“Downstream LNG transactions”, for example LNG truck loading and LNG marine fuel deliveries. These transactions are in scope as they are understood to take place at or after the entry flange of an EU LNG regasification terminal. Similar guidance to pipeline gas applies for reporting.


Answer:

The Agency has already clarified in the FAQs on fundamental data and inside information document (Q. 3.2.2) that LNG truck loading is out of scope for reporting fundamental data reporting.

For the same reason, the Agency believe that transaction for the supply to LNG trucks are non-reportable.

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