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.3.2.14

Data field (30)

Reference to documents: TRUM, Annex 2, Table 15.02 – field 30 (non-standard contracts and transactions) All details of transaction executed within the framework of non-standard contracts specifying at least an outright volume and price are not necessarily available to both parties to the contract at the latest by the invoicing date (if we refer to the invoice issuance date). Indeed there may be a significant time gap (sometimes over 30 days) between the date where a producer issues its invoice and the date where the buyer actually receives it. Our below proposal aims at preventing from any breach of timely reporting due to a counterparty. We are requested by our NRA to check with ACER this would not create any operational issues.

For instance, a producer issues an invoice on 2nd February, however this invoice is only sent to the buyer on 28th February and received on 3rd March.

In that situation, the buyer will have all the details of the transaction only from 3rd March and will not therefore be able to use the invoice issuance date. The seller does not have any visibility of the date the invoice will be received and is not able to use the invoice reception date to populate the field.

We noted that ACER publicly stated at several times (in particular at the workshop of January 27th) that the reported transaction timestamps do not need to be the same for both parties.

Besides, during our meeting of January 8th, our NRA confirmed it does not use field 30 for reconciliation purposes unlike the fields related to the price, volume and delivery dates.

In this respect, as a buyer, we intend to populate field 30 with the invoicing reception date and expect sellers (producers) to populate this field with the date of issuance of the invoice.

Our NRA agrees with this methodology, but requested us to check with ACER this would not create any operational issues.


Answer:

In the examples illustrated in Annex II to the TRUM it is indicated that the time and the date of the EXECUTIONS may be different between market participants. Market participants should report their EXECUTIONS concluded under the framework of non-standards contract within one month from when they know their price and quantity. In those circumstances where market participants do not know the price and volume until they receive the invoice from their counterparty, they should report their EXECUTION within one month from the receipt of the invoice.

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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.3.6.3

Market participants are required to backload their trades. For the backloading, is it enough to report a contract once or should we do monthly executions on this specific contract for the duration of the contract in the past also?

As an example: we report a bilateral contract, which runs from 01.01.2010 until 31.12.2020. For the Backloading, would it be sufficient to report the contract once with the non standard contract Template and do the monthly execution from April 2016 on? Or should we report the monthly executions with the std contract Template for the time in the past (01.01.2010-01.04.2016), which in this example would mean 75 execution reports.


Answer:

Please refer to FAQ. 3.6.2:

Any outstanding contract has to be reported as back loaded. Execution under the framework of non-standard contracts concluded before the 7 April 2016 do not fall under the scope of back-loading.

Executions under the framework of non-standard contracts should be reported with Table 1 and linked to non-standard contracts that have already been reported to the Agency with Table 2. See examples in Annex II to the TRUM.

Since there is a three-month period time for the back loading of outstanding non-standard contracts, the reporting of transaction executed under the framework of non-standard contracts are reportable if they take place after the reporting of the back loaded report.

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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.3.1.37

Reference to documents: REMIT Implementing Regulation Article 5

Definitions of known price and volume for reportable executions are unclear. For non-standard supply contracts of gas or electricity, where there is not a fixed price commodity rate defined in the contract, which volume and price is considered to be the reportable execution?

Example: If a customer makes multiple forward-purchases ahead of a delivery month through their supplier for a specific volume for this specific delivery month at a specific price, with any remaining un-hedged volume then priced on a market index; all of which are subsequently used in calculating a weighted average invoice unit rate; what should the customer report?

  1. Each trade made at the time of trade, only.
  2. Each trade made at the time of trade, and the remaining volume on the index price at time of invoicing (once volume and price are known).
  3. Just the final weighted-average unit rate and total consumption at time of invoicing (and then a final monthly average, or each settlement period price).

Our view: Option 1 above.

It is our understanding that only the executions for forward purchases are reportable as it is these transactions which could affect the market.


Answer:

Based on the information provided above, it is our view that all the contracts have to be reported. If the forwards with defined price and quantity are agreed and the price remains unchanged, then these contracts have to be reported as BILATERAL contracts. Any remaining un-hedged volume priced on a market index should be reported as EXECUTIONS. Please see FAQ 3.1.28

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