FAQs on transaction reporting – Question II.3.1.16

Implementing Acts – Article 3(1)(a)(vi) – Other contracts for the supply of electricity or natural gas with a delivery period longer than two days where delivery is in the Union irrespective of where and how they are traded, in particular regardless of whether they are auctioned or continuously traded.

Tolling agreements allow for the conversion of a fuel into electricity between one party and another. The fuel that is nominated to the party converting the fuel remains in the ownership of the party requiring the electricity and the resultant electricity belongs to this same party. There is no transfer of title of either commodity and the financial settlement of the agreement relates to the availability of the converting party to convert the fuel.

Party A nominates a volume of its own gas to Party B, the converter (i.e. a power station). The resultant electricity is scheduled into the account of Party A. On a regular basis Party A will make a payment to Party B based on the availability of Party B.


Answer:

If there is no transaction between the two parties in relation to a wholesale energy product, then this would mean there are no reportable transactions under the reporting obligation of REMIT. Market participants should assess if they enter into transactions for the delivery of the energy commodity or for the provision of services.

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FAQs on transaction reporting – Question II.3.2.12

Data field (28)

ANNEX II – Table 1 Examples 4.01-4.04 for Bilateral trades off-OMP versus Table 1 Examples 1.02-23.02 for Executions of non-standard trades

For the examples of Table 1 for Bilateral trades off-OMP, Field 28 has been populated with “00:00Z/24:00Z” which is in line with guidance in the TRUM.

However for examples of Table 1 for Execution trades, Field 28 has been left blank.

So that we can programme our systems in a consistent manner to populate this field for Table 1 under Phase 2, is it acceptable to always populate this field with “00:00Z/24:00Z”  regardless of whether the Table 1 is a bilateral or an execution trade?


Answer:

Field 28 should be populated with “00:00Z/24:00Z” in line with the guidance in the TRUM. However, when Table 1 is used for the reporting of execution under the framework of non-standard contracts, Field (28) can be left blank as indicated in the examples available in Section II of Annex II to the TRUM.

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FAQs on transaction reporting – Question II.3.2.9

Data field (24) to (31)

Table 2 Fields 24 to 31 – Data fields related to fixing index details

For non-standard trades with the delivery price linked to a formula, if the formula includes an FX index used to convert the currency of the fixing into the currency of settlement, does that FX index need to be reported in this section.

Annex II: Example 9.01 – Oil Index Gas Physical Formula Deal.

The above example in the TRUM would imply the answer to this question is NO – i.e. you do not have to report FX indexes in this section.

Could ACER explicitly confirm this and detail any other types of indexes or fixings that would NOT need to be reported in this section (if any)?


Answer:

There is no need to report an FX index in the fixing index details session (fields 24 to 30 of Table 2). If any FX index has to be reported, it can be reported in the formula. Only indexes related to the energy commodity should be reported in the fields from 24 to 30 of Table 2.

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FAQs on transaction reporting – Question II.3.2.7

Data field (21)

Table 2 Field 21 – Volume optionality

How do we differentiate between “C” for Complex and “O” for Other?

Especially as there are no examples in the TRUM that use “O”.


Answer:

From the Agency’s point of view, “C” for Complex should cover all the cases where the volume optionality cannot be classified as one of the non-Complex options (i.e. Variable, Fix or Min/Max). We are currently not aware of any possible use of “Other”.

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FAQs on transaction reporting – Question II.3.2.2

Data field (11)

Frequently Asked Questions (FAQs) on REMIT transaction reporting – II.2. Questions related to standard contracts Question 2.1.26

The question addresses the issue of assigning a UTI for back loaded standard contracts and states that as the field is mandatory that a UTI is required, but that this doesn’t have to match with the other market participant.

Under the obligation to report non-standard contracts, there is the same issue with regards to the Contract ID for contracts that are subject to back loading; as such the same logic should apply.

Party A and Party B have to report a non-standard contract that is subject to the back loading requirement. As this contract was in existence prior to the obligation to report, a Contract ID will not have been allocated to the contract.


Answer:

Non-standard contracts that are subject to the back loading requirement under REMIT should be reported with a Contract ID, but there would be no expectation that the Contract ID used will match between the two market participants for back loaded contracts.

The Contract ID is required because otherwise the market participant will not be able to link the executions to the contract. The Contract ID can be anything the market participant would like to submit as long as it is unique to the market participant and does not need to match the Contract ID of the other market participant.

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FAQs on transaction reporting – Question II.2.1.30

Data Field (35) and (38)

Reporting negative prices & resulting negative notionals

We wish to get clarification on how to report the following scenario under REMIT from 7th April 2016 onwards:

In some cases a trade may be for a “”negative”” price. This is not the same as the trade being the “”other way around””, i.e. a “”buy”” instead of a “”sell””.

Is it permissible to report negative prices in the various fields, i.e. fields 35 or 57 of table 1, or field 15 of table 2?

The same question would apply to resulting notionals.


Answer:

If the Price of the trade is negative, this should be reported with a negative number. For notional values, these should always be reported in absolute value.

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FAQs on transaction reporting – Question II.2.6.2

Frequently Asked Questions (FAQs) on REMIT transaction reporting – II.2.6 Questions related to bilateral trades Question 2.6.1

The question asks how to report where one of the market participants may be not a REMIT market participant. The answer recommends that a generic ACER Code ACERNONMP.EU is used so that the obligation to report can be fulfilled.

Market Participant A reports a transaction with Market Participant B who is not registered with any National Regulatory Authority (NRA) and does not have an ACER code and hence is identified using ACERNONMP.EU. A month later Market Participant B is registered with an NRA and get their ACER code and uses this for reporting all transaction post receipt of the ACER code. All previous transactions reported still identify Market Participant B with the generic ACER code ACERNONMP.EU.


Answer:

Market participant (MP) (A) reports a transaction with MP (B) which is identified using ACERNONMP.EU in MP (A)’s report. A month later when MP (B) is registered with the competent NRA and informs MP (A) of its ACER code (or any other reportable code) will be able to report all its transaction post registration with the NRA.

Because previously reported transactions by MP (A) still identify MP (B) with the generic ACER code (ACERNONMP.EU), MP (A) should send a modification report to update the code of MP (B) in MP (A)’s reports.

MP (B) will only be able to report transactions identifying itself in Field 1 (ID of the market participant or counterparty) once it has been registered with the National Regulatory Authority (NRA). At that point MP (B) will be able to report all its transactions (past and future transactions) identifying itself in Field 1.

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FAQs on transaction reporting – Question II.3.1.11

If a non-standard trade is transacted and reported under Table 2, and a Day 1 cross delta trade is also performed with the same counterparty and reported under Table 1, does the Table 1 trade need to be linked to the Table 2?

Also is the Table 1 trade classed as an execution and therefore reported each month after invoicing, or just reported once as a bilateral trade?

We enter into a non-standard trade which is a Calendar strip of monthly options to purchase a physical spark spread position – i.e. similar to the example provided in Appendix A.  The non-standard option deal will give a delta of being Long Power / Short Gas.

To hedge the position, we therefore at the same time enter into a fixed price physical transaction with the same counterparty to Sell Power & Buy Gas.

Whilst the 2 trades are booked independent as the flow of one is not dependent to the other, they are still linked in the sense that the second trade is a direct hedge of the first trade and performed with the same counterparty.

Our interpretation is that the non-standard trade would be reported using Table 2.  The fixed price physical hedge would then be reported under Table 1, and linked to the Table 2 trade via Field 32.  However the Table 1 trade would be classed as a bilateral trade and not an execution trade and therefore only reportable once (assuming no lifecycle events) and not each month the trade deliveries.


Answer:

In the Agency’s view that the delta trade performed with the same counterparty and reported under Table 1 is a separate transaction unless it is executed within the framework of a non-standard contract.

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FAQs on transaction reporting – Question II.3.1.12

Article 7 (6) of Commission Implementing Regulation (EU) No. 1348/2014

Transaction Reporting User Manual (TRUM) – Annex II Examples of transaction reporting

Should lifecycle events be reported to ACER for transactions that have been reported on the back loading requirement?

Market participant concluded bilateral contract outside an organized market place before 7th April 2016. Regarding to the fact that market participants shall report contracts which were concluded before the date on which reporting obligations becomes applicable and remain outstanding on that date, Market participant reports this contract within 90 days after 7th April 2016 in the context of back loading requirement.

If the terms of the original contract (e.g. price or quantity) are modified after 7th April 2016 should market participant reported this fact (lifecycle event) to ACER?


Answer:

Contracts that are back loaded and then amended are subject to the life cycle event reporting.

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FAQs on transaction reporting – Question II.3.1.13

Reference to documents: Article 3 (1) of Commission Implementing Regulation (EU) No. 1348/2014 – Transaction Reporting User Manual (TRUM) – Annex II Examples of transaction reporting

In connection with practical example indicated below we would like to ask how such a trading situation should be reported?  Please indicate what combination of trading scenarios included in Annex II must we choose?

Trading scenarios included in Annex II envisage two steps: reporting bilateral contract and execution. What kind of reporting scenarios should be chosen when trading activities include three (or more) sequence? Example indicated below:

1.       Parties concluded General Agreement X (and they didn’t conclude any Individual Contract), there is no specified price and volume; after a few months.

2.       Parties concluded Individual Contract with maximum quantity, but they didn’t specify price; after a few months.

3.       Parties concluded Individual Contract with defined quantity and price.


Answer:

The FAQs document on transaction reporting (please see question 1.1.11) and Annex II to the TRUM address this question. Master agreements are not reportable. If the first report is about the non-standard contract, then executions under the framework of that non-standard contract have to be reported.

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