FAQs on transaction reporting – Question III.4.1.4

We have finished our preparations to be able to report transactions. It is unclear to us however, how we should report our transactions.

Our assumptions are based on the document ACER: FAQs_on_Transaction_Reporting_20160324.pdf, more specifically on question 1.1.15

We uses 2 types of contracts:

  1. Master agreement in which we agree with our customer (utility/producer/consumer) to automatically close its hourly open position against APX/BELPEX prices (bilaterally, we are not a member of the exchange and not an OMP. At the end of the month we create an invoice.
  2. Master agreement in which we agree with our customer that he can buy from us or sell to us intraday (ex-post) volume. At the end of the month we create an invoice or credit note where we settle the volumes against the imbalance price.

We believe both types of contract are non-standard contracts with a volume and a price that are known during the month. That would mean that we would be allowed to report monthly.

Can you confirm this interpretation?

– Both master agreements should be reported as non-standard contracts.

– Volumes and prices can be reported as Table 1 transactions

Then there is the question of how to handle the fact that the same transaction (1 per day per market and per customer) can contain both buy and sell volumes.

Then there are 3 options:

– use the “C” and use either positive or negative values for buy and sell in the individual hours

– use the “B” and use negative values if we are the seller

– split the transaction in a “B” and an “S”

The last option is not preferable, as we don’t really have 2 transactions.


Based on the information provided above, “C” should be used.

In addition, the Agency has addressed the issue of reporting of master agreements in the FAQs on transaction reporting.

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FAQs on transaction reporting – Question III.4.1.1

Who reports the nomination data cross border capacity allocation in case a single point nomination mechanism exists between two bidding zones under the jurisdiction of two TSOs?


In order to avoid double reporting, the Agency will accept one report for the nomination data allocated cross border capacity from one of the TSOs reporting on behalf of both or by a third party RRM reporting on their behalf. The Agency needs to be informed of the preferred reporting method through the RRM registration process. The reporting delegation will also have to be identified in the market participation registration form of the relevant TSOs.

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FAQs on transaction reporting – Question III.4.1.2

How to report when a continuous explicit intraday cross border capacity allocation method is in place?


In case the relevant allocation rules define that the allocated intraday cross border capacity is automatically nominated with no possibility of intervention from the market participant and that the amounts of allocated and nominated intraday cross border capacity are equal, then there is no need for the relevant TSOs or third party acting on their behalf to submit both allocated and nominated information. Only the nominated cross border capacity will be reported to the Agency by the reporting party.

In case the relevant allocation rules allow the freedom of the market participant to nominate a different amount of cross border capacity to the allocated amount, then both the allocated and the nominated reports will have to be submitted to the Agency.

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FAQs on transaction reporting – Question III.4.1.3

Reference to documents: Implementing Acts – Article 7 (5)

What is the reporting timeframe for Secondary Power & Gas Transportation under Table 3 & 4?  Per the Implementing Acts, Article 7 (5), the reporting timeframe for Primary Transportation has been defined as T+1, but there is no mention of Secondary Transportation.

Reporting timeframes for REMIT reportable transactions are generally either T+1 or T+30.  Could ACER confirm what is the timeframe for Secondary transportation?


Details of contracts referred to in Article 3(1)(b)(i) of Commission Implementing Regulation (EU) No 1348/2014 shall be reported as soon as possible but no later than on the working day following the availability of the allocation results. Any modification or the termination of the concluded contracts shall be reported as soon as possible but no later than on the working day following the modification or termination.

The Agency currently considers secondary transportation contracts are not standard contracts and they therefore have to be reported on a T+1 month basis.

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