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.3.1.8

How to report a bilateral contract (initially classified as a non-standard contract and also reported in a non-standard format) in cases of any price fixing events (e.g. the client exercises an option)? This especially concerns such events which could be interpreted as a standard contract in a stand-alone perspective. (Vanilla) options are considered as being standard contracts (Table 1) and reportable in Phase 1 if executed over an OMP or identical to a product admitted to trading over an OMP (although the REMIT reporting requirement would be met if the trade falls within the scope of EMIR and has been reported as such).


Answer:

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

Please see the example in Annex II to the TRUM. In Section 2 of the annex there are several examples on how to report bilaterally traded contracts and executions under those non-standard contracts.

If the price fixing event (e.g. the client exercises an option) is related to a non-standard contract reported with Table 2, then the event should be reported as execution with (Table 1) under the framework of a non-standard contact and not be interpreted as a standard contract. 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.

On the contrary, vanilla options that are considered as standard contracts should be reported with Table 1 and reportable in Phase 1 if traded over an organised market place and do not have reportable executions associated to them.

RSS_Icon Last update: 10/07/2017  

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  

FAQs on transaction reporting – Question II.3.1.15

Reference to documents: TRUM V2.0 , 3.2.6, page 20

TRUM V 2.0 3.2.10, pages 26-26; TRUM Annex II v 2.0* (2015-11-16) pages  6-9; TRUM Annex II v 2.0*, example 3.09

Reporting of Executions in case of a standard/non – standard Option contract (volume optionality)

As understood, EXECUTIONS need to be reported in case volume is not defined when concluding the contracts.

However, it is not clear if the same logic applies with Option contract with a definite strike prices and delivery period. As described in TRUM, an option exercise is not considered a lifecycle event. In the example 3.09 (option via a broker platform), it is not clear whether any subsequent event (“execution”) needs to be reported in order to specify the final volume.

A swing option, traded outside OMP

-fixed premium

-fixed strike price

-fixed delivery period

-maximum daily volume

-minimum total volume (for the entire delivery period)


Answer:

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

The reporting of these type of flexible contracts is based on the reporting of non-standard contracts with Table 2 followed by EXECUTION or BILCONTRACT contract EXECUTION (s) no later than 1 month after the price and the volume are known. 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  

FAQs on transaction reporting – Question II.2.5.4

Articles 40(1), 40(2) and 44(2) make clear the backloading requirements that Market Participants should consider the minimum requirement for the reporting of contracts which were concluded before the date on which the reporting obligation becomes applicable and remain outstanding on that date i.e. 7th April 2016.

Where other information which is required to be reported under REMIT can be extracted from market participants’ existing records, market participants shall also report that information.

But could ACER please provide some clarity as to whether trades would need to be backload reported if trades have a delivery and settlement date prior to the 7th April 2016 but where there may be some scenarios whereby there will be some cash flows/payments that will not be able to be made until after this date but will not impact the trade or the delivery.

An example of this may be the result of the way that a trade is priced e.g. the trade is agreed and concluded pre- 7th April 2016 but priced as an average over all of April 2016 hence the price will not be known until it is calculated after 7th April 2016.

On the basis that all aspects of the trade will be concluded/ settled/delivered prior to the 7th April 2016, XXXX would like to confirm ACERs view that these would be out of scope for the backloading requirement based on:

–   the agreement and conclusion of the trade and/or any delivery will have taken place prior to the 7th April 2016 and that the outstanding cash flow is not material in the context of REMIT transparency or in relation to market manipulation;

–   in the spirit of what REMIT is trying to achieve, reporting these trades to ACER would add little apparent value in terms of transparency, market manipulation or market impact and that

–   the TRUM seems to hint (although not explicit) that the delivery of the contracts is the key factor for reporting requirement generally (3.2.1 point (iv)).


Answer:

Since the contract and all its aspects have been concluded/ settled/delivered prior to 7 April 2016 the obligation to report backloaded contracts does not apply for the above-mentioned scenario.

RSS_Icon Last update: 10/07/2017  

FAQs on transaction reporting – Question II.3.4.7

Reference to documents: TRUM 2.0 page 20

We  would like to discuss a trading example and ask you how to report it:

Scenario:

  • Company A sells electricity (bilateral, physical settlement) to Company B for the whole year to spot market conditions
  • Company B pays twelve equal monthly payments to Company A. The amount of the payments is estimated before the beginning of the year. The estimation is based on the volume that was sold the year before and the estimated prices in this year. The monthly bills therefore don’t display a volume.
  • At the end of the year, there is a final invoice. The final invoice is offset with the twelve payments. The final invoice displays the sold volume in this year (it is calculated after the whole year) and the calculation of the difference between the twelve monthly payments and the sold volume to a specific price (derived by the spot market). The final invoice can be positive or negative depending on whether the sum of the monthly payments is above or below the sold volume x sold price.

In our understanding we should use REMIT Table 2 scheme to report the contract (no quantity and price is known before the final invoice). And for the execution it is our understanding that we report the transaction for the whole year using the final invoice with the defined price and volume at the end of the year (table 1)?

In our understanding we shouldn’t report the monthly payments (TRUM 2.0 page 20) because there is no specifying of an outright volume and price.


Answer:

Based on the information provided above, it is our view that the contract should be reported by using Table 2 and one EXECUTION at the end of the year. Please note that this would apply only to contract with pre-payments.

RSS_Icon Last update: 10/07/2017  

FAQs on transaction reporting – Question II.3.4.8

The question is about submitting the notional amount (Data Field R1.38). We would do so in a monthly rhythm. There are three dates where we get new information about the amount in month M, i.e. M+1WD, M+14WD, and 2M-10WD (WD being working days). The initial amount could be corrected twice in the course of two month following the month of delivery.

We wonder if we are to correct execution messages as well and if we have to do so every month separately or after the end of the calendar year for the whole delivery year.

In the FAQ document we found Question 3.4.3 which reads that “…the Agency currently would not expect any life-cycle event based on actual values available from the DSOs.” How is this quote to be interpreted to the effect of submission of executions?


Answer:

As stated in FAQ 3.4.3 there is no expectation to update submitted EXECUTION reports unless Market Participants prefer to do so.

RSS_Icon Last update: 10/07/2017  

FAQs on transaction reporting – Question II.3.6.4

Related documents: II.3.6 of the Frequently Asked Questions

Question relates to the reporting of executions under back loaded nonstandard contracts.

According to II.3.2 of FAQs, an execution completed before 7 April 2016 does not need to be reported. Executions with delivery period extending beyond 7 April 2016 need to be reported. However, as the deadline for backloading of nonstandard contracts is 7 July 2016, the questions are:

  1. Does an execution with a delivery period ending before the nonstandard contract is back loaded need to be reported?
  2. If yes, what is the deadline for reporting such an execution? Should it be reported within 30 days of the end of the delivery period, even if this is a date earlier than 7 July 2016 (in which case the nonstandard contract should be back loaded not later than the date of reporting of the execution)? Or should such an execution be reported only when the nonstandard contract is back loaded, even if this falls later than 30 days from the end of the delivery period of the execution.

Answer to the second question of II.3.6 of FAQs (which probably should be properly marked as question 3.6.2, instead of 3.6.1) suggests that only executions with delivery periods ending after a nonstandard contract is actually back loaded are reportable. This would mean that executions with delivery period ending after 7 April 2016 but before the nonstandard contract is actually back loaded (which can happen by 7 July 2016) would not be reportable at all. We are not clear if this was the actual intention of the Agency.

As a follow up question: when new executions of a back loaded contract are reported after the backloading is done, do the data reported by each of the counterparties regarding such executions need to match? Many Xxxx market participants are reporting to me that they have significant difficulties in agreeing with some counterparties how the historical contracts are to be reported and it is quite likely that several back loaded contracts will be reported by each of the respective counterparties differently (with non-reconciled data). I would greatly appreciate your input on this. My understanding is that in case of back loaded contracts both data reported by the two counterparties under table 2 and data reported under table 1 for executions of back loaded contracts are not required to match.


Answer:

Executions under the framework of non-standard contracts with a delivery period ending before the nonstandard contract is back loaded do not need to be reported.

Criteria for back loading are more relaxed. Please refer to TRUM Annex II, e.g. Example 4.05 to see the differences in the back loaded contract reported by two counterparties.

RSS_Icon Last update: 10/07/2017  

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.


Answer:

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.

RSS_Icon Last update: 10/07/2017  

RSS_Icon Subscribe to this Category’s RSS