FAQs on transaction reporting – Question II.1.1.28

Related documents: the answer to question no. 3.1.1 from Section II.3.1 of the document Frequently Asked Questions (FAQs) on REMIT Transaction Reporting

Having regard to the obligations imposed on the participants in the wholesale electricity and gas markets under Article 8(1) of Regulation (EU) no. 1227/2011 of the European Parliament and of the Council of 25 October 2011 on wholesale energy market integrity and transparency (REMIT) as well as Commission Regulation (EU) no. 1348/2014 of 17 December 2014 on data reporting, implementing Article 8(2) and Article 8(6) of Regulation (EU) no. 1227/2011 of the European Parliament and of the Council on wholesale energy market integrity and transparency (Implementing Regulation), given emerging new doubts as to interpretation, the participants in the wholesale electricity and gas markets in xxxxxx, who are members of the xxxxx Association of Energy Trading (hereinafter TOE), consider it necessary to ask ACER to explain the reporting practices regarding contract entered into by Seller (Party A) and Buyer (Party B), who under a single contract purchases electricity/gas meant for both further resale by the Buyer (Party B) and Buyer’s own purposes.

Under such contracts, after the end of a billing period, Buyer (Party B) shall determine the percentage of the electricity/gas volume allocated to further resale and how much of the total electricity/gas Buyer (Party B) consumed for own purposes.

The question considers the following types of contracts:

  1. OTC without trade balancing service, based on a product listed on an organized market place (base, peak, etc.);
  2. OTC without trade balancing service, not based on a product listed on an organized market place, e.g. schedule-based (but with volume and price determined by the time of conclusion of the contract);
  3. OTC with trade balancing service, settled on the basis of electricity meter readings.

In the case of contracts described in Items 1 and 2, the total contract volume (the volume sold by Party A to Party B) is determined by the time of conclusion of the contract, but the share of the volume allocated to resale by Buyer (Party B) and the share of the volume allocated for Buyer’s own purposes remains unknown until after the service is provided.

In the case of contract described in Item 3, the total volume of sale is unknown when the contract is concluded. Instead, it is defined after the service is provided. Similarly, the breakdown of the total volume into the resold and own purposes becomes known only after the service is provided.

It is important to note that according to the Xxxx law, the entity reselling to end users, who are the customers purchasing electricity/gas in order to satisfy their own demand, has to purchase a specific number of certificates of origin (e.g. from renewable sources of energy, from cogeneration, energy efficiency certificates), proportionally to the volume supplied to such customers.

Moreover, the sale of electricity/gas for own purposes of the end user is subject to excise duty. The cost of such certificates of origin as well as the amount of excise duty are reflected in the price of electricity/gas sold to the end user, increasing it. Seller (Party A), who purchases electricity not for own purposes but for further resale, is not obliged to purchase a specific number of certificates of origin, and therefore such customer buys electricity at a price including neither the cost of certificates of origin nor the amount of excise duty.

For the above reasons, the discussed type of contract determines two different prices: Price X for electricity/gas to be further resold by Buyer (Party B), to which Seller (Party A) does not have to add the cost of purchasing certificates of origin or excise duty (lower price); and Price Y for electricity/gas to be consumed by Buyer (Party B), which includes the cost Seller (Party A) incurs in relation to purchasing certificates of origin and the amount of excise duty (higher price). Both Price X and Price Y are specified in the contract as fixed and uniform prices (i.e. they are not set down as a formula indicating separate constituents of the electricity/gas value, the value of certificates of origin and the amount of excise duty).

The above means that in the case of the contracts described in Items 1 and 2 above, even though the total sale volume is known when the contract is signed, the total price invoiced by Seller (Party A) and paid by Buyer (Party B) is known only after the delivery, since the total price depends on the way the volume is divided, according to the allocation and the application of Price X and Price Y to the respective parts of the volume. On the other hand, in the case of those contracts, the total value of the “black” energy sold (excluding the value of certificates of origin and excise duty) is known as early as at the time of concluding the contract, since the value is determined by Price X.

Therefore, it is necessary to obtain ACER guidelines, addressing the following question:

(i) Should the contract described above be reported in accordance with the electricity/gas price specified in the contract, excluding the cost of certificates of origin and excise duty (i.e. Price X) for the entire volume, irrespective of the allocation of the electricity/gas sold,

(ii) or should both prices (Price X and Price Y) resulting from such a contract be reported, broken down into the volume of energy allocated for further resale and separately for the energy allocated for consumer’s own purposes,

(iii) or should a part of contract including the volume of energy allocated for further resale according to the “black” energy price (Price X) be the only part subject to reporting, even though for this volume the contract stipulates the application of Price Y (including the cost of certificates of origin and excise duty)?

TOE members request that a binding interpretation of the presented question be issued by acknowledging that the reporting model proposed below is correct in the light of the REMIT Regulation and implementing regulations, and that no other model fully pursues the objectives of the Regulation.

In the opinion of the enquirers (PL Markets participants), the types of contracts described above are subject to reporting, according to the electricity/gas price determined for the part of contract subject to further resale (Price X), for the entire energy volume under the contract, irrespective of the allocation of energy, because the price is the “black” energy price with no additional constituents (the cost of certificates of origin, excise duty).

Therefore, the types of contracts described in Items 1–3 above shall be reported in the following manner:

  1. The contract specified in Item 1 shall be reported as a standard contract (since its features correspond to the contract listed on an organized market place), in which the total amount of energy and the “black” energy price are known when the contract is signed.
  2. The contract described in Item 2 shall be reported as a non-standard contract, in which the total amount of energy and the “black” energy price are known when the contract is signed (i.e. immediately in accordance with Table 1).
  3. The contract described in Item 3 shall be reported as a non-standard contract, in which the “black” energy price and the volume shall be reported after the service is provided when the billing period has finished (i.e. the contract shall be reported according to Table 2 and executed according to Table 1).

The above stance is based on the answer to question no. 3.1.1 from Section II.3.1 of the document Frequently Asked Questions (FAQs) on REMIT Transaction Reporting, wherein the Agency points out that additional fees, taxes and costs shall not be subject to REMIT reporting. Moreover, it should be pointed out that the aim of the REMIT regulation is to provide objective and reliable information regarding the prices of electricity/gas on wholesale markets in the European Union.

Therefore, submitting reports in which, due to national specificities, any price constituents other than the price of electricity/gas itself such as additional taxes (e.g. excise duty) or other constituents related to the execution of state policy regarding renewable sources of energy or energy efficiency shall result in the submitted information not fulfilling the primary goal of such reporting, since it shall not provide reliable information on the price of electricity/gas on the wholesale market in Xxxx. Moreover, a report encompassing information on the price including all the derivatives mentioned above would make it impossible for the Agency to carry out simple and reliable evaluation of the relations between the prices of electricity/gas on separate state markets within the European Union, which would therefore negate the primary goal of the Regulation.


Answer:

In our understanding there are at least two contracts subject to REMIT reporting:

(1)   Contract for the entire energy volume between Party A and Party B, and

(2)   Contract subject to further resale between Party B and other party

Therefore, the types of contracts described in Items 1–3 above shall be reported in the following manner:

  1. The contract specified in Item 1 shall be reported as a standard contract (since its features correspond to the contract listed on an organized market place), in which the total amount of energy and the “black” energy price are known when the contract is signed.
  2. The contract described in Item 2 shall be reported as a non-standard contract, in which the total amount of energy and the “black” energy price are known when the contract is signed (i.e. immediately in accordance with Table 1).
  3. The contract described in Item 3 shall be reported as a non-standard contract, in which the “black” energy price and the volume shall be reported after the service is provided when the billing period has finished (i.e. the contract shall be reported according to Table 2 and executed according to Table 1).

If the total volume is partially allocated (resold) to another party it should be reported as a separate contract between Party B and the other party.

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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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FAQs on transaction reporting – Question II.3.1.38

Reference to documents: Ref [1]: The XSD that defines how the Table1 fields can be put together in the XML: ”REMITTable1_V2.xsd” Ref [2]: ACER_REMIT_TRUM_ANNEX_II_v2.0.pdf

We want to repeat the Delivery Profile section of Table1 for each “Delivery point or zone”. This does not seem to be possible according to Ref [1].

For example: We have a non-std contract (using Table2) for a “delivery point or zone”= Sweden (“10YSE-1——–K”). For this contract we will have executions (using Table1 for this), in up to four different “delivery point or zone”s (LUL:”10Y1001A1001A44P”, SUN:“10Y1001A1001A45N”, STO:“10Y1001A1001A46L”, MAL:“10Y1001A1001A47J”).

What we really would like is to be able to repeat only the fields: [48, 55 and 57] four times, i e we want to state “Delivery capacity” and “Price/time interval quantity” for each of the four delivery points respectively, while all other fields in the report are the same. This does not seem to be possible according to ref [1].

We have seen examples in the pdf that are close to what we want, see ref [2]:

– pages 210-211: field 48 is multiplied

– page 58: fields 54-57 are multiplied

– page 131: fields 49-57 are multiplied.

Our question is whether our example with having at least these three fields together, repeated [48,55 and 57], also could be possible?

Our interpretation is that with the current XSD it is not possible to achieve what we want to do.


Answer:

Based on the information provided above, it is our understanding that each execution for each delivery point should be reported separately. The FAQs document on transaction reporting has already addressed this question, please see Question 3.1.6.

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FAQs on transaction reporting – Question II.3.1.39

As we do not find a relevant transaction reporting examples suitable to our case, please find enclosed the description of our specific transaction and how we propose to submit it.

For its procurement of grid losses, TSO X tenders on yearly basis a certain amount of power to the market:

  • This is a yearly shaped profile with a fixed volume, e.g. 10 lots à 43395 MWh per lot for the year 2017 (8760 hours) were tendered in 2015/ 2016 with a certain shape.
  • Market participants willing to participate in the tender could offer their prices for the overall profile (e.g. EUR 31, 69) and the market participants with the cheapest price are contracted.
  • We consider that as a non-standardized transaction, but with a fixed volume and price, so will use TABLE 1 for reporting, see example below.
  • For field 40 “Quantity / Volume” we will use the average clip size rounded with two decimal places, i.e. 43.395 MWh / 8760 hours = 4,95 MW.
  • In field 54 “Load Delivery Intervals” we enter “00:00/24:00” per default.

Please find the complete example and how we intend to report in the Excel file enclosed.

We would welcome, if you could approve our suggestion and add the example to the ANNEX II of the TRUM, so we could communicate accordingly to our counterparties.


Answer:

Based on the information provided above, it is our understanding that this is a BILATERAL contract with shaped profile. Each hour with different quantity and price should be reported in the report.

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FAQs on transaction reporting – Question II.3.1.40

Related documents: Article 2, Article 2(2) and (3) of 1348/2014, Article 5(1) а,b (2) of 1348/2014; Article 7 (2) of 1348/2014; Regarding field TRUM Table 1 Transaction Timestamp field 30 and reporting Table 1 – bilateral in T+1

How to classify (standard or non-standard) complex day-ahead hourly electricity products executed bilaterally outside the organised market place is not admitted to trading at an organised market place and if classified different than our view then when to report and with which table?

  1. With some of our partners we trade day-ahead hourly electricity products executed within the framework of general/master agreement bilaterally outside the organised market place. This master agreement sets the rules for trading activity of the two counterparties to the contract and it is specifying the range of the volumes available for trading as sometimes these volumes can differ regarding the buy and sell positions in the counterparties portfolios and these positions, during the trade period (one month) will be technically still open until the end of the month when is the invoicing date and the correct price and quantity can be discovered.

In our opinion, this contract may be classified as non-standard complex shaped/profile contract as it is not traded at an organised market place, but only bilaterally between the two parties and it is not admitted to trading at an organised market place (not visible to the market, not available for trading to market participants, would be traded only once and would then expire and not be tradable any more).

Our understanding is that we should report the abovementioned trade with Table 1 to identify the details of transactions executed within the framework of non-standard contract reported with Table 2. This execution will be reported once the delivered quantity and the price are known after the invoicing cycle, but no later than 30 days after the discovery of price and quantity. Can you confirm this?

Also, could we use the details (time of the invoicing) from the invoice for filling the Transaction Timestamp in the Table 1 field? For this kind of contract our positions will become clear and will be known after the invoicing cycle, so that is our only reasonable option.

  1. With other partners we have master agreement and annex based executions with clear and closed positions regarding the price and quantity. In our opinion, this annex may be classified as non-standard contract for base load, pick load off-pick load annex contract as it is not traded at an organized market place, but only bilaterally between the two parties. Could we report this contract just with Table 1 as Bilateral on T+30 or Bilateral on T+1?
  2. The qualification whether the contract is “standard contract” or “non-standard contract” is specified by ACER`s list of standard wholesale energy contracts as it defines the types of such contracts. Decisive for the reporting as standard contract or non-standard is the fact whether a contract is or is not listed as such in the Agency’s REMIT database.

According to the primary criterion stated by Article 2(2) and (3) of the REMIT Implementing Regulation if contract (for example in our case day-ahead hourly electricity products) has been traded bilaterally and has not been admitted to trading at an organised market place (not visible to the market and not available for trading to market participants and would be traded only once and would then expire and not be tradable any more), but in the same time this kind of contract has been published in the ACER list of standard contracts, (for example Bulgaria Baseload (CET 00-24) with delivery zone 10YCB-BULGARIA-F). Does the fact that the contracts which have been published in ACER`s list as standard for 10YCB-BULGARIA-? delivery zone makes these contracts standard, despite the fact that are traded bilaterally and have not been admitted to trading at an organised market place? How do we need to report, for example this year contract Baseload 00-24 CET with delivery zone 10YCA-BULGARIA-R? Could you please answer when do we need to report the contract: on T+1 or T+30 as Bilateral with Table 1?


Answer:

Please see FAQ 3.1.28.

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