Regarding the testing phase, could you detail this part of the registration process? What kind of data is supposed to be sent to the Agency?
This information is available on the REMIT Portal in the RRM Requirements document and also in the RRM Technical Specifications documentation made available to RRM applicants after online acceptance of the Non-Disclosure Declaration. Please refer to the aforementioned documents.
Last update: 29/05/2015
In the RRM requirements document, the Agency states that it may give a precise time slot for the testing of an RRM applicant. Will the date for the IT testing be proposed by the market participant or does the Agency plan to give an exact time slot for testing (e.g. some concrete period)?
The testing is part of the RRM registration process and will be mainly automated. Therefore, no additional communication with ACER will be necessary. Only in exceptional circumstances, the Agency may allocate specific time slots to a particular RRM. In such a case, the Agency will communicate this to the relevant RRM applicant in advance.
Last update: 29/05/2015
During the RRM registration we have to specify whether we will be reporting trade data, fundamental data, or both. In case we indicate both, but in the end our customers do not request fundamental data reporting, could we revoke this decision to avoid the testing of this kind of reports?
The selected interfaces and schemas during the registration process will be those which will have to be tested in the testing phase during the RRM registration process (Testing Framework). Upon successful results, and all other required steps being successfully fulfilled, the applicant may be approved as an RRM. If in the future, the RRM wishes to modify previous choices or add additional interfaces and/or schemas to its profile then this will be accommodated by the system via a profile update. However, before being able to use the additional interfaces/schemas, it is mandatory that testing via the Testing Framework is run successfully. Access to the Testing Framework remains permanently available to the RRM.
Last update: 29/05/2015
[** Merged with Q II.4.20. **]
Which RRMs need to be identified in Section 5 of the market participant registration form in CEREMP?
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:
- 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:
- the OMP on which the transactions were executed;
- ENTSO-E as regards the data referred to in paragraphs (1) and (2) of Article 8 of Commission Implementing Regulation (EU) No 1348/2014;
- 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:
- the reporting delegation applies only to a particular transaction and the counterparty to the transaction reports on behalf of the market participant;
- a TSO is in charge of reporting transportation data pursuant to Article 6(2) of Commission Implementing Regulation (EU) No 1348/2014;
- 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;
- of an LNG system operator as regards the data referred to in Article 9(5) of Commission Implementing Regulation (EU) No 1348/2014;
- of a storage system operator as regards the data referred to in Article 9(9) of Commission Implementing Regulation (EU) No 1348/2014.
Last update: 22/10/2018
Are market participants allowed to register as RRMs (e.g. via subsidiary companies) and report their own standardised contracts executed at organised market places?
Market participants cannot report details of wholesale energy products executed at organised market places by themselves, regardless of whether they register as an RRM or not. Article 6(1) of Commission Implementing Regulation (EU) No 1348/2014 defines the reporting channels for the reporting of details of wholesale energy products executed at organised market places, including matched and unmatched orders, to the Agency. Therefore, it is the Agency’s understanding that reporting channels for the details of wholesale energy products executed at organised market places are: organised market places, trade matching systems or trade reporting systems. The organised market place where the wholesale energy product was executed or the order was placed shall, at the request of the market participant, offer a data reporting agreement.
Last update: 31/08/2015
Article 6(1) of Commission Implementing Regulation (EU) No 1348/2014 defines that organised market places shall, at the request of the market participant, offer a data reporting agreement. If market participants wish to report data through the organised market places, do organised market places necessarily have to become a RRM or would they be allowed to delegate the actual data reporting to a third-party?
In line with Article 6(1) of Commission Implementing Regulation (EU) No 1348/2014, the reporting of details of wholesale energy products executed at an organised market place should be carried out by the organised market place concerned, or through trade matching or trade reporting systems. The organised market place concerned has to offer a data reporting agreement if requested by market participants. Nevertheless, there is no obligation for the organised market place itself to become an RRM.
The organised market place can delegate the actual reporting of the data to a third-party (which has to be an RRM). In this case Article 11(2) of Commission Implementing Regulation (EU) No 1348/2014 applies. Finally, in line with Article 6(1) of Commission Implementing Regulation (EU) No 1348/2014, the organised market place is allowed to delegate data reporting only to another organised market, a trade matching or a trade reporting mechanism.
Last update: 31/07/2015
Would it be permitted for an RRM to offer “holiday fees” on the REMIT service to its customers (market participants) during an initial period, having those costs subsidized by other incomes of the RRM?
Please note that the Agency has no power to review or approve the fees that RRM will apply for reporting of data to the market participants. However, the Agency would like to stress that RRM’s pricing policy applied should comply with the requirements of competition law.
Last update: 31/08/2015
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?
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.
Last update: 24/03/2016
What if the RRM wants to revoke the power of attorney submitted to the Agency during the RRM registration process at a later stage?
RRM applicants or registered RRMs are obliged to inform the Agency on any revocation of their power of attorneys and to submit the valid power of attorneys together with the updated application forms without any delay.
Last update: 30/09/2015
The RRM Application Form requests the details of a person responsible for compliance of the RRM. What are the responsibilities of this person and is he/she personally liable e.g. for any RRM failures to comply with REMIT?
With regard to the person responsible for the RRM compliance, such person shall be responsible for the process of RRM registration and reporting. A potential personal liability of this person is governed by the relevant national law applicable for the RRM.
Last update: 30/10/2015