FAQs on transaction reporting – Question II.2.1.42

Data Fields (49) and (50)

Could the Agency clarify further “contract start date and delivery start date may be different: e.g. the contract starts on 1 January 2017, but for peak contracts the delivery starts on Monday morning, which is 2 January 2017.“ statement available on its Open letter on REMIT transaction reporting data quality?


Answer:

As indicated in the letter, market participants should refer to the Agency’s guidance on transaction reporting, namely the TRUM, Annex II to the TRUM and the FAQs on transaction reporting and they should also liaise with the RRMs reporting on their behalf as they may provide with additional instructions.

Based on the Agency’s schemas, and the ISO 8601 standard which says “Midnight is a special case and may be referred to as either “00:00” or “24:00″, our understanding is that midnight may be represented as either 00:00:00, 24:00:00 or 23:59:59.

For example, 2016-08-01 00:00:00 represents the same date and time of 2016-07-31 23:59:59 or 2016-07-31 24:00:00.

However, according to the guidance, 23:59:59 and 24:00:00 should not be reported for delivery start time. Time 23:59:59 or 24:00:00 on Day X should be reported as 00:00:00 in day X+1. The same applies to 06:00:00 and 05:59:59 to represent the end of a gas day.

Example: a typical yearly electricity baseload contract is wrongly reported if the delivery start date and time is 2016-12-31 00:00, 2016-12-31 23:59:59 or 24:00:00. The delivery start date and time should be reported as 2017-01-01 00:00:00.

With regard to “contract start date and delivery start date may be different: e.g. the contract starts on 1 January 2017, but for peak contracts the delivery starts on Monday morning, which is 2 January 2017” reporting parties should pay attention to the guidance.

REMIT transaction reporting fields include Field N. (53) “Days of the week” which plays a pivotal role in the simplification of the reporting of delivery profiles. Please see also FAQs on transaction reporting – Question II.2.1.40.

When “Days of the week” is reported correctly, the reported delivery profile will always be the same of the “actual delivery profile” of the contract.

Case 1 – delivery period falls within the calendar period

For electricity contracts, e.g. see example 2.11 in Annex II to the TRUM, a report for the monthly electricity peak load delivery for August 2014. The hourly delivery profile is defined by the fields:

Field N. (49) “Delivery Start Date”: 01/08/2014 identifies the date at which the delivery of the commodity starts as specified in the contract.

Field N. (50) “Delivery End Date”: 31/08/2014 identifies the date at which the delivery of the commodity ends as specified in the contract.

Field N. (53) “Days of the week”: WD identifies on which days of the week the delivery takes place, i.e. week days, as specified in the contract.

Field N. (54) “Load Delivery Intervals”: 08:00/20:00, as specified in the contract

In this specific case 1 August 2014 is Friday, therefore the physical delivery starts on that date. 31 August 2014 is Sunday, thus the physical delivery ends on Friday 29 August.

Case 2 – delivery period falls outside the calendar period

Furthermore, reporting parties should also pay attention to some special circumstances.

For gas contracts, e.g. see example 2.8 in Annex II to the TRUM, given a gas day 06:00 on day D to 06:00 to D+1 may affect the reporting of their monthly contracts. A monthly gas delivery for August 2014, with physical delivery starting on 1 August 2014 delivers gas from 06:00 to 06:00 and the actual physical delivery ends on 1 September 2014 at 06:00. Therefore, the correct way of reporting this contract is:

Field N. (49) “Delivery Start Date”: 01/08/2014

Field N. (50) “Delivery End Date”: 01/09/2014

Field N. (53) “Days of the week”: empty to indicate every day

Field N. (54) “Load delivery intervals”: 06:00/06:00 Another special circumstance is when a monthly electricity off-peak load delivery for August 2014 start at 19:00:00 on 31/07/2014. These are typical monthly contracts but the delivery period falls outside the calendar days, rather than within them.

We are aware that these are industry standards and are used by Organised Market Places (OMPs) and the Agency would expect the reporting of delivery Start and End Date as shown above and in Annex II to the TRUM. The Agency is also aware that in most cases the same standards are used in bilateral trades (non-OMPs trades).

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.2.1.37

Data Field (48)

A Market Participant is buying gas for its own needs (fuel gas) outside an OMP via bilateral contract. The delivery point of the gas under the contract conditions (where the commodity changes hands) is an Entry point ABC from production facility. The point ABC is a connection point between the production facility and the gas transmission system of the TSO.

For reporting purposes under the requirements of Article 3(1)(a) of Commission Implementing Regulation (EU) N1348/2014, what data shall be provided in the respective field of schema REMITTable 1 or REMITTable 2: DELIVERY POINT OR ZONE – the EIC of the Entry point ABC or the EIC of the Balancing zone to which the gas is entering?

If the EIC of the Entry point ABC shall be filled in the XML field DELIVERY POINT OR ZONE, the MP needs to add said EIC code to the list of valid EICs. Could you please confirm that it will be possible to add such an EIC via the Agency’s web-tool for mapping/supply of EIC information, e.g. via using “Other” in the point type drop down?


Answer:

The EIC of the Balancing zone should be reported. There is no need to add the Entry point ABC via the Agency’s web-tool for mapping/supply of EIC information.

The same would apply to Domestic/Industrial aggregate points and Distribution zones/networks. If these points are connected to a balancing zone from where the gas/electricity is withdrawn/supplied from, the EIC of the balancing zone should be reported.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.2.1.38

Data Field (48)

A Market Participant is buying gas for its own needs (fuel gas) outside an OMP via bilateral contract.

The delivery point of the gas under the contract conditions (where the commodity changes hands) is a connection point between a storage facility and gas transmission system. The point name is XYZ. Point XYZ is bidirectional.

XYZ (entry) is the point direction from the Storage facility to the Gas transmission system;

XYZ (exit) is the point direction from the Gas transmission system to the Storage facility.

Q. 1  For reporting purposes under the requirements of Article 3(1)(a) of Commission Implementing Regulation (EU) No 1348/2014, what data shall be provided in the respective field of schema REMITTable 1 or REMITTable 2:

  • DELIVERY POINT OR ZONE, if the commodity changes hands at XYZ (entry) or
  • the EIC of the connection point between a storage facility and gas transmission system (XYZ entry) or the EIC of the Balancing zone to which the gas is entering?

Q. 2  For reporting purposes under the requirements of Regulation (EU) No 1348/2014, point 3.1 (a), what data shall be provided in the respective field of schema REMITTable 1 or REMITTable 2: DELIVERY POINT OR ZONE, if the commodity changes hands at XYZ (exit)?


Answer:

Q 1. The Balancing zone the gas is entering into.

Q 2. The Balancing zone the gas storage facility belongs to.

Q 3. There is no need to add a connection point between a storage facility and gas transmission system via the Agency’s web-tool for mapping/supply of EIC information.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.2.1.39

Data Field (48)

Could the Agency clarify the reporting of EICs and their mapping to the balancing zones/areas, interconnection points, LNG and storage facilities?


Answer:

In the Transaction Reporting User Manual (TRUM) after consulting the industry through two public consultations, the Agency has indicated that the Energy Identification Code (EIC) to be reported for transaction reporting purposes for Table 1 and Table 2 has to identify the commodity delivery point or zone.

This field reports the EIC Y code (or an alternative code to be agreed with the Agency if the EIC is not available) to identify the delivery and/or balancing point for the contract. In addition, the TRUM clarifies that since gas can also be delivered at the interconnection point, then the EIC Z Code for that interconnector may be used.

Furthermore, in the FAQs on transaction reporting – Question II.3.1.23, the Agency has indicated that where the gas is delivered at an LNG or a gas storage facility, then the EIC W code for that facility should be reported.

Based on more than 1 billion transactions (Table 1 and Table 2) reported to the Agency, it was found that market participants and organised market places are using more than 4000 codes to indicate the delivery points. In some occasions more than 1000 different codes were used to indicate the same balancing zone.

Since the Agency (supported by the input provided by the industry) does not find this diversification reasonable and has seen that 95% of the overall transactions have been reported with the correct EICs, on 26 June 2017 the Agency has published Annex VI to the TRUM (including the list of accepted EICs) in the REMIT portal and will only consider the codes listed in the list of accepted codes.

In the Agency’s view, if 95% of the reported transactions are compliant with REMIT, there is no reason for the remaining 5% of transactions to be reported with alternative codes.

Market participants that use different codes for nomination purposes at domestic/industrial aggregate points, distribution zones/networks or production sites should report in any case the EIC of the balancing zone these points are connected to. While they may want to keep using those codes for nomination purposes, they will need to translate those codes into the EIC of the balancing zone they are related to when reporting the transaction to the Agency for REMIT purposes.

With regard to interconnection points, the Agency has explained in Annex VI to the TRUM that the reportable Y EIC code has to belong to the interconnection point where gas is delivered and then transferred to the other side of the interconnection point by the system operator. This case applies to unbundled interconnection capacity only.

In Annex VI to the TRUM the Agency has explained that only the EICs in the list of accepted codes are reportable codes. All the other codes available in the sheet “EICs Validity Check” and flagged as “Invalid” , “ENTSO-E” and “Missing” (please carefully read Annex VI to the TRUM) are not considered compliant with the Agency’s guidance according to Article 5(2) of Commission Implementing Regulation (EU) No 1348/2014.

However, in order to help market participants and organised market places to comply with REMIT, the Agency has given the opportunity to clear their transaction reporting history (related to the EICs) through the online “EIC mapping form” (please see Annex VI to the TRUM for the link).

The online form allows reporting parties to map a previously reported EIC (Missing, Invalid, ENTSO-E list) to a code listed in the “List of Accepted EICs” and to report a code for a zone/area/facility that is not included in the “List of Accepted EICs” (or changing its name/function).

However, market participants that have submitted new codes for domestic/industrial aggregate points, distribution zones/networks or production sites connected to a balancing zone, should not expect the inclusion of those codes in the list of accepted codes, unless the Agency believes there is reasonable ground for their inclusion in the list.

The Agency has already updated the list of EICs codes to accommodate TSOs or market participants requests where the Agency believed there was a reasonable ground for the inclusion of new EICs (this is visible in the EIC list of accepted codes spreadsheet attached to Annex VI to the TRUM).

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.2.1.40

Data Field (48)

A Market Participant is buying gas for its own needs (fuel gas) outside an OMP via bilateral contract. The location where commodity changes hands under the contract conditions is a Gas storage facility.

For reporting purposes under the requirements of Regulation (EU) No 1348/2014, point 3.1 (a), what data shall be provided in the respective field of schema REMITTable 1 or REMITTable 2: DELIVERY POINT OR ZONE – the EIC of the Gas storage facility or the EIC of the Balancing zone to which the Gas storage facility belongs?


Answer:

 

Assuming that the seller is withdrawing the gas from the system and injecting it into the storage, then handing it over to the buyer, or if the seller sells the gas that he already owns in the storage to the buyer, the EIC of the Gas storage facility should be reported.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.1.1.29

The TSO in AAA, XXX, shows the occurred imbalances of previous periods and the active companies shall try to find a partner to offset the positions on bilaterally basis. If the companies cannot find offsetting volumes the TSO finally balances the accounts.

Could you please specify if pre-arranged contracts to offset the volumes are regarded as balancing contracts or as bilateral contracts which needs to be reported under REMIT?

In case they have to be reported, we would like to make ACER aware that the transaction timestamp is after the delivery start date which seems to be conflicting according to remarks in the letter to improve the data quality.

To our understanding only contracts with the TSO are defined as balancing contracts and the contracts needs to be reported as Table 2 contracts with monthly executions of the exchanged volumes to avoid balancing.


Answer:

Please refer to Question 3.1.50. In the Agency’s view, a balancing trade is a contract between a party and a System Operator (SO), in most cases TSO, who is in charge of keeping the energy in the network/system (either gas or electricity) in balance.

It is the Agency’s understanding that in “…day after markets”, and any other retro-deal market, market participants balance/adjust their positions with other market participants. If this is the case, these contracts should be reported by both parties as wholesale energy products.

In the Agency’s view, balancing trades are well defined in Articles (2)9 to (2)11 of COMMISSION IMPLEMENTING REGULATION (EU) No 1348/2014, in the sense that they are related to balancing energy and services:

(9) ‘balancing energy’ means energy used by TSOs to perform balancing;

(10) ‘balancing capacity (reserves)’ means the contracted reserve capacity;

(11) ‘balancing services’ means

  • for electricity: either or both balancing capacity and balancing energy;
  • for natural gas: a service provided to a TSO via a contract for gas required to meet short term fluctuations in gas demand or supply.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.1.1.30

Company deconsolidation from the group perimeter

The companies “XXX” and “YYY” are part of the same group and both registered MPs subject to REMIT. The companies “XXX” and “YYY” entered into transactions but accordingly to Article 4(1) of Commission Implementing Regulation (EU) No 1348/2014 they did not send on a regular basis any reporting related to the contracts.

On 1 July the company “XXX” is going to be deconsolidated from the consolidated financial statement of the company “YYY”. From a reporting point of view, should the contracts in place be reported to ACER? With which timetable? What is the contract date that should be used?

With reference to the reporting of the outstanding contracts, our interpretation is that they should not be reported because agreed out of normal market rules in an infra group context.

In case the Agency believes that those contracts have to be reported, our interpretation is that

  • the reporting should be done in T+1 month from the date of deconsolidation of company “XXX”
  • the contract date should be the same of T.

Answer:

As on 1 July the company “XXX” is going to be deconsolidated from the consolidated financial statement of the company “YYY” and it changes status, in the Agency’s view it is reasonable that company XXX should report all its contracts on T+1 month from its status change with the date of its status change.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.1.1.31

As on 1 July the company “XXX” is going to be deconsolidated from the consolidated financial statement of the company “YYY” and it changes status, in the Agency’s view it is reasonable that company XXX should report all its contracts on T+1 month from its status change with the date of its status change.

1         Case1: TSO inserts buy offer for block contract 15:00 – 18:00 at 14:30 (in Balancing phase) with BAL parameter. Other market participant inserts sell offer for the same contract at 14:31 with price and volume which fully match the offer inserted by TSO. The trade match time is 14:40 (in balancing phase).

Which data should be reported in this case to ACER?

2         Case2: TSO inserts buy offer for block contract 15:00 – 18:00 at 14:30 (in Balancing phase) with BAL parameter. Other market participant inserts sell hourly offers 15-16, 16-17 and 17-18 (the same time period as block contract inserted by TSO) at 14:31 with price and volume which fully match the block offer inserted by TSO (cross trade enabled – matching of block contracts with hourly and quarterly contracts). The trade match time is 14:40.

Which data should be reported in this case to ACER?

3         Case3: TSO inserts buy offer for block contract 15:15 – 15:45 at 15:05 (in balancing phase) with BAL parameter. Other market participant inserts sell offer for the same contract at 15:06 with price and volume which fully match the offer inserted by TSO. The trade match time is 15:06 (in balancing phase).

Which data should be reported in this case to ACER?

1.  As is written in the TRUM, we are obliged to report offers and trades inserted/concluded outside the balancing phase. In this case, the block contract starts in the regular Intraday trading and ends in the Balancing phase.

Because we cannot divide the block contract into part of Intraday and part of Balancing phase we are planning to report both block offers and trades as is inserted/matched in the trading platform.

2.  In this case one block contract is matched with 3 hourly contracts and last hour of the block contract is in Balancing phase.

With the same reason as it mentioned on topic 1, we are planning to report all offers (block contract and 3 hourly contracts) and also all trades.

3.  Since offer and trade were submitted/concluded in a balancing phase it is our understanding that these market data will not be reported to ACER.


Answer:

We consider the interpretation provided above reasonable. Whenever a contract for balancing purposes cannot be separated from a contract for the supply, that contract should be reported as contract for the supply.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.1.1.32

We are having some issues with the submission of back loading transaction as they are rejected by a validation rule.  Could the Agency clarify further if back loading transactions can still be reported to the ARIS system?


Answer:

Commission Implementing Regulation (EU) No 1348/2014 clearly establishes that details of wholesale energy products in relation to the supply of electricity and gas executed at organised market places, including matched and unmatched orders, entered into application as of 7 October 2015 and for any other transactions as of 7 April 2016.

The Commission Implementing Regulation also establishes that details of wholesale energy contracts which were concluded before the date on which the reporting obligation becomes applicable and remain outstanding on that date shall be reported to the Agency within 90 days after the reporting obligation becomes applicable for those contracts. Please see also paragraph 3.4 “Start of reporting and reporting frequency” in the TRUM available in the REMIT portal.

This means that back-loading of transactions concluded at organised market places was due by no later than 90 days after 7 October 2015 and 90 days after 7 April 2016 for any other transactions.

The Agency’s system was set to allow back loading of historical data skipping several validation rules. This was done through the submission of an XML file with a date in the filename prior (<) to the date of 5 Oct 2015 00:00:00Z. In this case most of the validation rules were ignored.

This was done to allow market participants to report their back-loading transactions even in those cases where they did not have the full set of information as required by Commission Implementing Regulation (EU) No 1348/2014 for reportable records of transactions, including orders to trade, entered into as 7 October 2015 and 7 April 2016.

However, the Agency had left open the back-loading channel for more than one year in addition to the deadlines set by the Commission Implementing Regulation: 90 days after 7 October 2015 and 90 days after 7 April 2016.

The Agency would like to take this opportunity to reiterate that any transaction executed at an organised market place has to be reported on T+1 day basis and any other transaction on a T+1 month basis and that any transaction reported 90 days after 7 October 2015 and 90 days after 7 April 2016 cannot and will not be considered back-loading, but rather late reporting.

In cases of late reporting, market participants and organised market places should liaise with their RRM as these regularly receive instructions on this topic from the Agency.

The Agency would like to remind that late reporting may constitute a breach of Article 8(1) of REMIT.

RSS_Icon Last update: 08/12/2017  

FAQs on transaction reporting – Question II.3.3.1

I would like to discuss another trading example and ask you how to report it. Below you’ll find my reporting proposal.

Scenario:

  • buy, “strip of daily option”, gas, bilateral, physical settlement, price 0,5 €/MWh,
  • total deal volume 27.000 MWh within three month (December – February), exercising the option is just possible at 15 days per month on a day ahead basis,
  • December quantity 0-20 MW, volume = 7.200 MWh,
  • January quantity 0-25 MW, volume = 9.000 MWh,
  • February quantity 0-30 MW volume = 10.800 MWh,
  • strike price 30 €/MWh.

Could you please help me in that case?


Answer:

[UPDATED] based on additional input provided by the Agency’s stakeholders

Our understanding is that the option described above can be reported with Table 2 as a non-standard contract. Its executions shall be reported with Table 1.

Please see Q. 3.1.28 whether the execution should be reported as EXECUTION or BILCONTRACT contract, also considering that examples reported in Annex II to the TRUM are non-exhaustive.

RSS_Icon Last update: 10/07/2017  

RSS_Icon Subscribe to this Category’s RSS