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FAQs on transaction reporting – Question II.3.5.1

What happens if an event has been reported with an error?

Do we have to send a first report with “Error” and then a second one with “New” or another status?

Do we still have to send the report no later than one working day after the sell for the standard contract (than one month after the invoicing for the non-standard contract)?


Answer:

When a wrongly submitted trade needs to be cancelled, then an “error” report should be submitted to the Agency. No other reports shall be sent or re-sent (such as the original one). For the reporting of lifecycle events, the same timeline for the first report applies.

If a “new” report is due to be reported on T+1 basis, all of the life cycle events related to that report have to be reported on a T+1 basis. If a “new” report is due to be reported on T+1 month basis, all of the life cycle events related to that report have to be reported on a T+1 month basis. Examples of “modification”, “early termination” and “error” reports are available in Annex II to the TRUM (e.g. examples 4.51 to 4.54).

RSS_Icon Last update: 16/02/2016  

FAQs on transaction reporting – Question II.3.5.2

What does the status “Cancel” (Lifecycle information) mean exactly for a contract? The contract has been cancelled or the energy delivery is completed?

Moreover if a supplier went bankrupt (for example) before the delivery starts, how can we report this? A new report with “Cancel” or only in “EXECUTION” (contract name) reporting in the case of a non-standard contract?


Answer:

The status “cancel” in “Action Type” data field No. 45 of Table 2 indicates the termination of an existing contract. “Cancel” should be used to indicate that the market participant or the execution venue has removed the order transaction from trading or, when a contract is terminated before the original end date.

If a supplier went bankrupt either before the delivery starts or after delivery has begun and an early termination of the contract takes place, then a “Cancel” report for the non-standard contract already reported with Table 2 has to be reported to the Agency indicating the date of cancellation. (Please see example 4.53 of cancellation of a standard contract in Annex II to the TRUM.

RSS_Icon Last update: 16/02/2016  

FAQs on transaction reporting – Question II.3.5.3

Same question for “Modify” (Lifecycle information). Do we only have to send a new report as soon as there is a new action such as change of volume, price or counterparty (novation)?


Answer:

The first submission of a transaction to the Agency of a bilateral contract is an event which will be identified as “new”. Any modification of the previously submitted report has to be notified to the Agency and reported as “modify”. An example of report modification is when two parties agree to amend one or more terms of the original agreement (e.g. price, quantity or any other value previously reported). Please see example 4.51 in Annex II to the TRUM.

RSS_Icon Last update: 16/02/2016  

FAQs on transaction reporting – Question II.3.5.4

Reference to Article 7 of the Implementing Acts.

Details of non-standard contracts including any modification or the termination of the contract and transactions referred to in the second subparagraph of Article 5(1) shall be reported no later than one month following the conclusion, modification or termination of the contract.

1)  In case of trade modification after end of delivery date, is there reporting obligation for market participants under REMIT?

2)  Would ARIS accept modification on a deal after end of delivery date? Is there any special process or guidance, which needs to be followed by Market Participants?

Business Case: Market Participant A is invoicing monthly settlements as part of standard processes. Occasionally a correction of settlement is required, due to price/volume adjustments or data collected by third party provider. In consequence, an existing invoice might need to be corrected or a new invoice generated relating to a previous period. It can be that such invoice correction / new invoice generation occurs after end of the delivery period.


Answer:

In the REMIT transaction reporting regime, nothing prevents a market participant from amending a report after the end of the delivery period.

The Agency recommends market participants to consider an amendment to the execution already reported in order to avoid that the discrepancy between the reported volume (or price) and the new information acquired may cause false positive signals to the market monitoring activity of the Agency and/or the National Regulatory Authorities.

RSS_Icon Last update: 16/02/2016  

FAQs on transaction reporting – Question II.3.5.5

This question is related to intraday lifecycle events for Phase 2 Reporting.

When two companies have agreed a bilateral non OMP standard or non-standard contract, there is the possibility that once agreed, the volumes and/or values may change several times during the day until the end of the business day. At the end of the business day, the contract is considered binding and finalised volumes and values recorded accordingly.

Is it acceptable to report the final transaction details as a single new trade report or do you need to have the initial new and subsequent modifications to the trade reported?

Also, it may happen that after several modifications to the initial contract, it is cancelled at the end of the business day, so is it acceptable to report the trade as New and then Cancelled without reporting the modifications?”

“Example 1

Company A and Company B agree a bilateral contract at 10:00 of 1,000 units at a price of €50 per unit for a next day delivery.

During the course of the day the number of units and/or the price agreed changes several times as follows…

11:00 – 1,100 units at €49 per unit

13:30 – 1,000 units at €50 per unit

15:15 – 900 units at €50.50 per unit

17:00 – 750 units at €51.35 per unit

At the end of the business day a final agreement of 750 units and a price of €51.35 is made and contracted to.

Example 2

Company A and Company B agree a bilateral contract at 09:00 of 500 units at a price of €55 per unit for a next day delivery.

During the course of the day the number of units and/or the price agreed changes several times as follows…

10:00 – 600 units at €52.50 per unit

12:00 – 450 units at €56 per unit

17:00 – Contract cancelled

At the end of the business day the contract is cancelled.


Answer:

Based on the information provided above, life cycle events of a trade agreed at 10:00 am have to be reported as such. If during the course of the day the number of units and/or the price agreed change several times including the cancellation of a contract, they should be reported as life cycle events.

RSS_Icon Last update: 26/09/2016  

FAQs on transaction reporting – Question II.3.5.6

We experienced several novations in the past and were confronted with different proposals on how to report such events to ACER. Could you please further specify the different data fields which need to be populated?

Could you please provide more clarity about the precise reporting requirements in case of novation? What values have to be reported?

Supply contract for gas for 1.4.16-1.4.17 was concluded on 15.02.2016. Novation agreement was signed on 15.12.2016 with effective date on 01.01.2017.

For the old transaction the following scenarios are possible:

Scenario Start of delivery End of delivery Contract date Termination date Event
(fields table 1 / 2) (# 49 / # 42) (# 50 / # 43) (#30 / #12) (#43 / – ) (# 58 / #45)
Reported 1.4.16 1.4.17 15.2.16   NEW
A 1.4.16 1.4.17 15.12.16 1.1.17 Cancel
B 1.4.16 1.1.17 15.12.16 1.1.17 Cancel
C 1.4.16 1.1.17 15.12.16   Modify

 

For the reporting of the new contracts the following scenarios are possible:

Scenario Start of delivery End of delivery Contract date Event
(fields table 1 / 2) (# 49 / # 42) (# 50 / # 43) (#30 / #12) (# 58 / #45)
I 1.4.16 1.4.17 10.2.16 NEW
II 1.4.16 1.4.17 15.12.16 NEW
III 1.1.17 1.4.17 10.2.16 NEW
IV 1.1.17 1.4.17 15.12.16 NEW

 


Answer:

All the open trades have to be novated with the name of the new legal entity to notify the change of the counterparty to the contract. In order to report a novation, an early termination with the old UTI and a new trade with a new UTI should be reported.

Both market participants, MP1 and MP2 have to submit an early termination report with Action Type “C” to cancel the old trade and MP1 and MP3 have to provide a new submission with Action Type “N” for the new trade between MP1 and MP3 with a new UTI. In addition:

  • The early termination should be reported with the timestamp/contract date of the early termination agreement day.
  • The termination date refers to the date the contract ceases to exist, and not the agreement date (timestamp/contract date, see above).
  • “Modify” should not be used.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.3.5.7

FAQ Question 3.1.17 states that for a Phase 2 reports in the Table 1 format that a change in UTI may be implemented through a modification of the existing report using either the <previousUniqueTransactionIdentifier>  for the Version 1 schema or the < additionalUtiInfo> field in the case of the Version 2 schema. The following question has been raised: For Table 1 Phase 2 reports is this process mandatory, or can the Phase 1 Table 1 process of erroring out the first report and resubmitting a new report with a new UTI (without a link to the previous UTI) be used as an alternative process?

Practical example: a new Phase 2 Table 1 report is successfully submitted by an MP but subsequently they wish to correct the UTI after discussion with the counterparty. They submit a report for that UTI with ActionType = “E” and they then submit a new report for the same deal with a new UTI (matching the counterparty’s UTI) with ActionType = “N”, they do NOT include any information about the original report or its UTI in the newly submitted report. Is this an acceptable process for correcting the UTI?


Answer:

Market participants should clearly distinguish the Error “E” from the Modification “M” case. As indicated in the TRUM, “E” for Error should be used to denote a cancellation of a wrongly submitted report, while “M” for Modification should be used for the modification of the details of a previously reported contract.

In order to correct the UTI that was wrongly submitted, the original report needs to be cancelled with Action type “E” and a new report with a new UTI (matching the counterparty’s UTI) has to be submitted for the same deal with Action type “N”. The new report does not have to include any information about the original report or its UTI, since the original report was wrongly submitted in the first place.

However, with regard to Question 3.1.17 of the FAQs on REMIT transaction reporting, if a market participant’s counterparty provides the UTI after T+1 day or T+1 month, or alternatively not at all, the market participant who is reporting its reports should submit a temporary UTI. Once they have received the UTI from their counterparty, a ‘Modify’ report should be submitted to modify the previous report, recalling the old UTI.

If a report is due to be reported on a T+1 day basis, all life cycle events related to that report have to be reported on a T+1 day basis. Otherwise, if a new report is due to be reported on a T+1 month basis, all life cycle events related to that report have to be reported on a T+1 month basis. Examples of ’modification‘, ’early termination‘ and ’error‘ reports are available in Annex II to the TRUM.

RSS_Icon Last update: 20/07/2018  

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