FAQs on transaction reporting – Question III.4.2.19

Does the definition of Secondary Gas Transportation also included zero priced entry assisted capacity that is often bundled with the purchase of beach gas, and therefore is reportable under REMIT?

A certain transaction for us is the purchase or sale of physical gas at a Beach location with other Market Participants. As part of that contract is the inclusion of free (i.e. zero priced) entry assisted transportation capacity which allows us or the Market Participant to flow the gas from the Beach location into the UK National Transmission System (NTS).

Is the embedded transportation in such contracts reportable under Table 4?

We deem such transactions not to be reportable under Table 4 as the purpose of the underlying transaction is not to trade capacity. In addition, the capacity part of the deal cannot be separated and traded in isolation in these deals.

Could ACER confirm this view is correct?


Answer:

According to REMIT, transportation contracts should involve two or more locations or bidding zones concluded as a result of a primary explicit capacity allocation by or on behalf of the TSO.

It is the Agency’s view that entry assisted transportation capacity which allows market participants to flow the gas from a non-balancing area to a balancing area is not a reportable contract.

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FAQs on transaction reporting – Question II.3.1.17

REMIT Implementing Act Article 5(1)(b) and Annex, table 1 data field 31 (Unique transaction ID), table 2 data field no 11 (contract ID).

We understand that market participants need to agree on their method of generating a Contract ID – this can include using the UTI algorithm provided by ACER. However, what should a MP do if its counterparty provides the ID after T+1 or T+30 or indeed not at all and they have not agreed to use the ACER algorithm? This is particularly of concern as the use of the ACER algorithm is not mandatory.

Under REMIT, phase 2 transactions need to be provided either under table 1 (for contracts that specify and outright price and volume) or under table 2.

In submitting a table 1 or 2 report the UTI field must be completed. However, it is possible a counterparty, who is not using the ACER algorithm, may not provide their UTI to us to enable us to report in the necessary timescales.

We are engaging with our CPs to ensure this does not occur but it is always a risk.

Our preferred approach is to:

1) Submit a temporary UTI, calculated based on the ACER algorithm.

2) Once we have received the UTI from the CP an ‘error’ report will be submitted to remove the previous report and a ‘new’ transaction report with the correct UTI will be submitted.

As an alternative to 2) we are also happy to simply submit a modify report if that is preferable to ACER.  Can ACER please confirm this is acceptable?


Answer:

Market participants should submit a temporary UTI, then once they have received the UTI from their counterparty, a ‘Modify’ report will be submitted to modify the previous report recalling the old UTI. In the schema there is a field called “AdditionalUtiInfo” field where the old UTI should be reported in the modified report. e.g.

Using Schema Table 1_Version 2

1st report Using Schema Table 1_Version 1

<uniqueTransactionIdentifier>UTI123</uniqueTransactionIdentifier>

<actionType>N</actionType>

2st report Using Schema Table 1_Version 1

<uniqueTransactionIdentifier>UTI456</uniqueTransactionIdentifier>

<previousUniqueTransactionIdentifier> UTI123 </previousUniqueTransactionIdentifier>

<actionType>M</actionType>

Using Schema Table 1_Version 1

1st report Using Schema Table 1_Version 1

<uniqueTransactionIdentifier>UTI123</uniqueTransactionIdentifier>

<actionType>N</actionType>

2st report Using Schema Table 1_Version 1

<uniqueTransactionIdentifier>UTI456</uniqueTransactionIdentifier>

< additionalUtiInfo> UTI123 </ additionalUtiInfo>

<actionType>M</actionType>

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FAQs on transaction reporting – Question II.3.1.18

Reference to documents: TRUM – Table 2 Reporting

We can trade transactions which will be reportable under Table 2, for which a premium or fee is payable at inception, regardless of the delivery or flow of the underlying commodity, however the deal is not considered an option.

We are therefore unsure as to where to report the deal premium or fee. If the trade was an option, it would be reported under Field 15, but this could already be populated with the pricing formula of the trade.

As per example 9.01 in Annex II of the TRUM which is an annual gas swing contract. If a fee or premium was payable for that contract on transaction date, regardless of the final delivery flow, where in Table 2 would that premium be recorded?

An obvious place would be Field 15, but this has already been populated with the pricing formula for transaction.

A possible solution would be to describe the formula in Field 15 and then add the premium as an absolute amount at the end of the formula. Would this be acceptable to ACER?


Answer:

When a transaction reportable under Table 2 includes a premium or fee payable at inception, regardless of the delivery or flow of the underlying commodity and the deal is not considered an option, that deal premium or fee, if it pertains to the service the trade is providing and unrelated to the volume of said product, would not be reportable.

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FAQs on transaction reporting – Question II.3.1.19

Reference to documents: ACER_REMIT_TRUM_v2.0, point 5

Question 1:

What has to be reported in the monthly reports of power Non-standard contracts, Table 1?

Question 2:

What has to be reported in the monthly reports of gas Non-standard contracts, Table 1?

Question 3:

Backloading for non-standard contracts table I: reporting obligation starting July 6th, 2016?

Question 1:

  • the total volume and the resulting average price of the contract (1 report) OR
  • the volume summarised by each transmission system operator (4 TSOs) (1 report including 4 volumes and prices) OR
  • the volume summarised by each transmission system operator (4 TSOs) (4 reports)

Question 2:

  • the total volume and the resulting average price of the contract (1 report) OR
  • the volume summarised by each gas market area (2 market areas) (1 report including 4 volumes and prices) OR
  • the volume summarised by each gas market area (2 market areas) (4 reports)

Question 3:

In our understanding the backloading of bilateral non-standard contracts have to be reported from July 6th on: these are contracts which were concluded before April 7th and are still in delivery since April 7th or will start in the future.

  • Is it correct that we report the framework contracts until July 6th and the first monthly table 1 report will be send in August?

Question 1:

  • the volume summarised by each transmission system operator (4 TSOs) (1 report including 4 volumes and prices)

Question 2:

  • the volume summarised by each gas market area (2 market areas) (1 report including 4 volumes and prices)

Question 3:

  • Is it correct that we report the framework contracts until July 6th and the first monthly table 1 report will be send in August?

Answer:

It is the Agency’s understanding that each transaction with each transmission system operator (different delivery point) has to be reported separately.

With regard to the backloading of bilateral non-standard contracts it is the Agency’s understanding that contracts which were concluded before 7 April and are outstanding on 7 April have to be reported by 6 July 2016.

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FAQs on transaction reporting – Question II.3.1.20

Is a Hydro Storage Virtual Power Plant deal considered to be a contract for the supply of electricity and therefore reportable as a non-standard transaction under REMIT?

An example term sheet for such a deal would be:

Period: Cal-16

Delivery Point: French Power

Storage Volume: 50,000 MWh

Max Storage Level: 50,000 MWh

Min Storage Level: 0 MWh

Initial Storage Level: 30,000 MWh

Final Storage Level: 30,000 MWh

Inflows: 150,000 MWh – These would have a Hourly MW profile

Outflows: 50 MW – Daily nomination

The holder of the contact would then effectively be able to take physical power from the writer as long as they operated within the above constraints. The power taken would be at zero price in return for a premium paid upfront.

In the draft FAQ’s issues after the Dec-15 ACER roundtable meeting, we note that Virtual Gas Storage contracts are not considered contracts for the supply of gas and therefore not reportable.

Based on this, we do not deem a Hydro Storage Virtual Power Plant deal to be a contract for the supply of electricity due to the significant similarities between this type of transaction and that of a Virtual Gas Storage transaction.

Could ACER confirm this view is correct?


Answer:

If the holder of the contact is able to take physical power from the writer, this is a contract for the supply of electricity. This is a reportable contract pursuant to Article 3 of Commission Implementing Regulation (EU) No 1348/2014.

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FAQs on transaction reporting – Question II.3.2.10

Data field (24) to (30)

Reference to documents: TRUM – Table 2 Reporting – Fixing Index Details (Fields 24-30)

Are FX indexes reportable under this section of Table 2?

If we have transaction to deliver physical gas, with the GBP or EUR price payable linked to a complex formula of USD Oil, the formula will contain a FX conversion index such as Bank Of England reference rate. Is that FX index also reportable as a fixing index under this section of Table 2?

Example 9.01 in Annex II would seem to suggest the answer is no.

Based on Example 9.01, our interpretation is that the answer is No. Could ACER confirm this explicitly as we would like to understand why FX indexes are treated differently from oil commodity indexes, and therefore if there is anything else that is not reportable under this section?


Answer:

In the FAQs document the Agency has already indicated that 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. This would include also oil and coal or any other energy commodity to fix the price of gas or electricity.

Examples of non-standard contracts reportable with Table 2 and available in Annex II to the TRUM, such as 9.01-13.01-14.01-25.01, were provided to the Agency by market participants. These examples clearly indicate that, in the industry’s view, Oil Index and Coal Index should be reported.

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FAQs on transaction reporting – Question II.3.2.8

Data field (24)

Reference to documents: Transaction Reporting User Manual, page 91

Is it mandatory, to fill Table 2, Field 24? If not, what are the features of the contract that release the obligation to report this information? TRUM shows a list of possible values to fill – it allows “Other”, suggesting that this field covers any situation that may occur in practice. Moreover, description does not include any exceptions concerning reporting obligation, which took place in many other fields (in such cases ACER stipulated, that the data are not required if certain conditions are met). On the other hand, i.e. example 2.01 (p. 182 of Annex II to TRUM) field is left blank, indicating existence of specific features of the contract, for which the field may be left blank. We expect the field to be obligatory, despite missing values in provided examples.


Answer:

Table 2 field 24 is NOT a mandatory field in the XSD schema and it should be used according to the examples provided in Annex II to the TRUM.

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FAQs on transaction reporting – Question II.3.4.6

Regarding contracts with a joint venture of producers of certain fields, it could be the case that there are separate contracts with each of the parties participating in that field, but that invoicing is done with only one partner, often referred to as ‘the operator’ of the field. Do we have to report one execution on the basis of this invoice and refer to only one of the contracts’ IDs, or do we have to report the invoice as many times as the number of counterparties to contracts related to the same field? In the latter case, do we have to report the same amount multiple times.


Answer:

Where there are separate contracts with each of the parties participating in that field, those contracts should be reported separately, allocating the delivered volume to the respective contracts (counterparties) and report as many transactions as the number of counterparties to contracts related to the same gas field.

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FAQs on transaction reporting – Question II.1.1.20

Could ACER provide us with additional guidance on the distinction between standard contracts traded outside the organised market places and bilateral contracts that are non-standard contracts? It would be useful to have clear guidance on the reporting time line, e.g. T+1 day or T+1 month.


Answer:

The Agency has already provided guidance on the definition of standard contract admitted to trade on organised market places in the TRUM. However, the Agency understands that there might be some circumstances where market participants may not have full visibility to the specifications of the standard contracts traded on organised market places.

Therefore, whenever two market participants enter into a bilateral contract agreed outside an organised market place and they do not have the certainty that their contract is the same as the one traded on organised market places, it can be assumed that the bilaterally agreed contract normally entails elements of customisation.

These elements of customisation distinct the bilateral contract from contracts concerning a wholesale energy product admitted to trading at an organised market place. They may therefore report such a contract on a T+1 month basis and, where the contract has a defined price and quantity, with Table 1 of the Annex to the REMIT Implementing Regulation.

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FAQs on transaction reporting – Question II.1.1.21

We have one question regarding the following contract situation:

There is one contract between company A and a group of contract partner/owner (owner B, owner C and owner D – one production unit with an aggregation of generation units). Company A sells monthly electricity for the production unit (contract partner)¸ having monthly one price and one amount on the invoice. The Acer Code of which owner (owner B, owner C and owner D ???) do we have to report, since the REMIT IT of RRM Services allows only to fill in one Acer Code. Do all owner have to register? The production unit (aggregation of generation units) has > 10 MW.


Answer:

Based on the information provided above, the reporting party has to allocate the delivered volume to the respective contracts (counterparties) and report as many transactions as the number of counterparties.

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