Q&As on REMIT – Question III.2.11.

We would like to register as an RRM. Is the registration process connected with any kind of fees?


Answer:

Currently, no fees are charged by the Agency from the RRM applicants at any stage of the RRM registration process. However, the registration process may involve additional investment from the RRM applicant, in order to meet the technical and administrative requirements laid down in the Requirements for the registration of Registered Reporting Mechanisms.

RSS_Icon Last update: 22/10/2018  

Q&As on REMIT – Question III.2.24.

[** Merged with Q II.4.20. **]

Which RRMs need to be identified in Section 5 of the market participant registration form in CEREMP?


Answer:

The market participant is obliged to choose all RRMs reporting its data, with exception to RRMs listed in Section 6.2.1 of the RRM Requirements.

A: For the first phase of reporting (deadline – 7 October 2015), the market participant is obliged to identify RRM(s) in Section 5 of the market participant registration form only if:

  1. the data is reported through an organised market place (OMP), trade matching or trade reporting systems that is different from the OMP where the transactions were executed.

The indication of the RRM in Section 5 of the registration form will not be required if the data is reported by:

  1. the OMP on which the transactions were executed;
  2. ENTSO-E as regards the data referred to in paragraphs (1) and (2) of Article 8 of Commission Implementing Regulation (EU) No 1348/2014;
  3. ENTSOG as regards the data referred to in Article 9(1) of Commission Implementing Regulation (EU) No 1348/2014.

 

B: For the second phase of reporting (deadline – 7 April 2016), additionally, the market participant is required to identify RRMs that will report second phase data on its behalf.

However, such identification of the RRM will not be required for the reporting of data in case:

  1. the reporting delegation applies only to a particular transaction and the counterparty to the transaction reports on behalf of the market participant;
  2. a TSO is in charge of reporting transportation data pursuant to Article 6(2) of Commission Implementing Regulation (EU) No 1348/2014;
  3. of a TSO is in charge of reporting data referred to in Article 8(3) and 9(2) of Commission Implementing Regulation (EU) No 1348/2014;
  4. of an LNG system operator as regards the data referred to in Article 9(5) of Commission Implementing Regulation (EU) No 1348/2014;
  5. of a storage system operator as regards the data referred to in Article 9(9) of Commission Implementing Regulation (EU) No 1348/2014.

RSS_Icon Last update: 22/10/2018  

Q&As on REMIT – Question III.2.40.

What happens if an RRM cannot send transaction reports on time?


Answer:

The Agency has established the ARIS Contingency Plan which is available to RRMs in the documentation section of the RRM Admin Profile. The Contingency Plan provides all instructions on what RRMs and market participants have to do in case of different scenarios that may impact the reporting.

As for the other obligations between the market participant and its RRM, the Agency points out that their data reporting agreement should take into account the ARIS Contingency Plan. Please note that if an RRM is not able to report its data according to the requirements set out by the Agency, the ARIS Contingency Plan is to be followed.

Potential sanctions for the breach of reporting obligations as laid down in Article 8 of REMIT are defined at national level.

All questions about the application of the Contingency Plan should be addressed to the Agency’s Central Service Desk: servicedesk@support.acer-remit.eu.

RSS_Icon Last update: 22/10/2018  

Q&As on REMIT – Question III.2.49.

[** Question number changed from Q III.8.4. **]

In which language have the documents to be submitted in the RRM application process, in the official language of the issuer of the document or in English?


Answer:

According to Article 33(1) of Regulation (EU) No 713/2009 establishing an Agency for the Cooperation of Energy Regulators, and Regulation 1/1958 determining the languages to be used in the EU, documents can be submitted in any official language of the EU.

However, Article 33(2) of Regulation (EU) No 713/2009 also provides that the Agency’s Administrative Board shall decide on the internal language arrangements for the Agency and the Administrative Board decided that the internal working language of the Agency is English. Therefore, the working language for the examination of RRM applications by the Agency will be English. In this respect, the Agency strongly prefers to receive documentation in English, and the RRM applicant is thus invited to send its application in English as translating documents submitted in other EU languages may require additional time to process the application.

RSS_Icon Last update: 22/10/2018  

Q&As on REMIT – Question III.2.50.

[** Question number changed from Q III.3.13. **]

Could reportable wholesale energy contracts from market participants registered in one Member State be reported by an RRM in another Member State?


Answer:

Yes. The market participant can choose RRM(s) from different Member States.

RSS_Icon Last update: 22/10/2018  

Q&As on REMIT – Question III.2.47.

A holding, which is not itself a market participant, owns several entities that are renewable energy producers and thus are registered as market participants under REMIT. These renewable producers are only legal entities and do not have any employees. One of them will register as RRM and report data on behalf of the other market participants within the holding (intra group RRM). How should the intra group RRM fill in the documents required during the RRM registration process and who bears the legal responsibility for the data reporting?


Answer:

As a general principle, the legal responsibility for data reporting is with the market participant. Therefore, if a market participant decides to delegate the data reporting to an RRM, Article 11(2) of Commission Implementing Regulations applies. It specifies how the responsibility for the reporting is divided between a market participant and an RRM.

If an intra group RRM applicant does not have any employees, it should clearly indicate who has the RRM Administrator and RRM Compliance roles in all documents which are submitted during the RRM registration process (e.g. RRM Application Form, Power of Attorney or Non-Disclosure Declaration).

RSS_Icon Last update: 29/04/2016  

Q&As on REMIT – Question III.2.48.

If I am an already approved RRM or an RRM applicant in the registration process and would like to ask a question about the application of the Contingency Plan, who should I contact?


Answer:

All questions about the application of the Contingency Plan should be addressed to the Agency’s Central Service Desk: servicedesk@support.acer-remit.eu.

RSS_Icon Last update: 29/04/2016  

Q&As on REMIT – Question III.2.18.

It is possible to cancel an already started RRM registration if the requirements described in the Technical Specifications for RRMs cannot be met? Is there a formal format for how to request for cancelation and where is it available?


Answer:

If the RRM applicant would like to cancel/stop its registration process before it is completed, an RRM Administrator has to notify the Agency by sending an email to servicedesk@support.acer-remit.eu. The Agency will then terminate the registration process for the RRM applicant. However, all requirements laid down in the Non-Disclosure Declaration (NDD) will still apply.

RSS_Icon Last update: 24/03/2016  

Q&As on REMIT – Question III.2.28.

Could you please explain how to fill in the information under Section 5 of the registration form (public list of RRMs)? E.g.: If a market participant ‘A’ wants to report data on behalf of other market participants belonging to the same group, would this market participant ‘A’ appear in the public list of RRMs (Section 5 of the registration form) for selection to all market participants?


Answer:

As a general rule, a market participant should have a contractual agreement in place with an RRM for delegation of data reporting before it selects this RRM in Section 5 of the registration form (public list of RRMs). Moreover, market participant should be aware that selecting an RRM in Section 5 of the registration form does not confer any legal obligation on that RRM to report on its behalf.

The Agency wants to bring the market participants’ attention to the fact that not all reporting parties will be made available for selection to all market participants in Section 5 of the registration form (e.g.: ENTSO-E, ENSOG). However, in case where an RRM is considered as an intra-group RRM, i.e. reporting data only on behalf of a market participants in the same group (definition of group to be found in the Directive 2013/34/EU), this intra-group RRM will all the same appear for selection to all market participants in Section 5 of the registration form (public list of RRMs). Indeed no difference will be made in the public list between third-party RRMs and intra-group market participant RRMs.

RSS_Icon Last update: 24/03/2016  

Q&As on REMIT – Question III.2.46.

Will TSOs be visible in Section 5 of the registration form in order for market participants to be able to select them?


Answer:

Only TSOs selecting the below RRM types will be visible in Section 5 of the registration form:

(i) ‘RRM type: MP reporting for the group’ under the stage: Additional Information Submission; or

(ii) ‘RRM type: RRM services available to any market participant’ under the stage: Additional Information Submission.

RSS_Icon Last update: 24/03/2016  

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