Q&As on REMIT – Question III.2.27.

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?


Answer:

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.

RSS_Icon Last update: 31/08/2015  

Q&As on REMIT – Question III.2.26.

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?


Answer:

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.

RSS_Icon Last update: 31/07/2015  

Q&As on REMIT – Question III.2.2.

How can I become a Registered Reporting Mechanism (RRM)?


Answer:

To become a Registered Reporting Mechanism (RRM), the Agency has set up two distinct processes for potential applicants being either (i) market participant RRM or (ii) third-party RRM.

The major difference between market participant and third-party RRM registration lies in the fact that the first step of the Identification stage is handled via a separate path.

A. If applicants who are not market participants wish to establish themselves as RRMs, then they shall perform a third-party registration via the RRM Registration module that ACER has made available on the REMIT Portal. The registration is initiated through: https://www.acer-remit.eu/ceredp/home where the RRM Applicant will have to complete the first identification step and submits it for ACER’s approval.

B. Market participants shall first proceed with a market participant’s registration through their respective NRA. In the majority of cases, this is done via CEREMP. In certain cases this is done via other systems the NRAs have established to manage their market participants registrations under Article 9 of REMIT. At the last step of the market participants registration, the market participants have the option to either select to which RRM they delegate the responsibility of reporting on their behalf, or to indicate their ‘Intention to become a Reporting Entity’ (for self-reporting purposes and/or to offer reporting services to others), or both. In the case of CEREMP, this is done in Section 5 of the registration process.

As soon as the NRA approves this first Identification step in CEREMP, the market participants who have indicated their intention to become RRMs will receive an invitation to proceed to the 2nd step of the Identification stage.

From that point onwards all steps for the registration process are similar for all RRM applicants (market participants and third-parties). Please see a below diagram:

The Agency will ensure a proportionate treatment of the different categories of reporting parties throughout the registration process. This is especially the case for the attestation stage during which all reporting entities wishing to become RRMs shall submit documentation describing the procedures aimed at ensuring the timely transmission of data and their business continuity plan. When assessing compliance with these requirements, market participant RRM applicants are relieved from providing certain documents as specified in Section 5 of the RRM Requirements document. More information on the RRM registration process can be found here: https://www.acer-remit.eu/portal/rrm-registration-doc.

RSS_Icon Last update: 31/07/2015  

Q&As on REMIT – Question III.2.20.

Are the requirements to become a Registered Reporting Mechanism the 13 specified requirements in the official document “RRM Requirements” (Section 5), or are there some other requirements (e.g. cost related)?


Answer:

The RRM requirements are defined in Section 5 of the RRM Requirements document. The RRM technical specification documentation provides additional information on how to meet these requirements, which is available to the RRM applicant after the signing of the Non-Disclosure Declaration. This additional information is relevant to security and data validation.

RSS_Icon Last update: 29/05/2015  

Q&As on REMIT – Question III.2.21.

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?


Answer:

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.

RSS_Icon Last update: 29/05/2015  

Q&As on REMIT – Question III.2.22.

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)?


Answer:

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.

RSS_Icon Last update: 29/05/2015  

Q&As on REMIT – Question III.2.23.

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?


Answer:

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.

RSS_Icon Last update: 29/05/2015  

Q&As on REMIT – Question III.2.13.

We are an ETRM provider and need to support our clients with their reporting obligations by developing a direct interface to connect with the ARIS system. We would therefore need the technical documentation although we are not an RRM. How can we receive the relevant documentation?


Answer:

There are two possible ways to receive the RRM technical specification documentation as an ETRM provider:

Firstly, service providers have the possibility to receive relevant documentation from their clients/customers within the limitations of the Non-Disclosure Declaration. In order to get access to the relevant documentation, a client/customer has to register to become an RRM.

Secondly, the ETRM provider could initiate its own RRM registration until the stage of the RRM technical specification documentation is reached, following the signature of a Non-Disclosure Declaration, and then inform the Agency about the cancellation of the registration.
From the Agency’s point of view, the first alternative seems to be the more advisable one.

RSS_Icon Last update: 29/05/2015  

Q&As on REMIT – Question III.2.14.

What will happen if at the time of registration a market participant has not yet decided on the delegated party for reporting on behalf of the market participant (concrete RRM)? Is there any chance not to fill Section 5 of the registration form at the first time of registration but only at a later stage?


Answer:

Yes. It is not necessary to provide information in Section 5 of the registration form if it is not available yet. It can be updated at a later stage.

RSS_Icon Last update: 29/05/2015  

Q&As on REMIT – Question III.2.15.

If a TSO plans to report transactions as well as fundamental data on its own, does it still need to be registered as an RRM? If yes, by when would the TSO need to be registered as RRM (is there any deadline)?


Answer:

Any reporting entity that submits data to the Agency has to be registered as an RRM. Registration should be completed before the reporting obligation applies at the latest.

RSS_Icon Last update: 29/05/2015  

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