Q&As on REMIT – Question III.4.2.

Are RRMs allowed to report fundamental data directly to ACER on behalf of market participants for “Unloading and Reloading of LNG” and for “Amount of gas stored” or, on the contrary, are the TSOs and SSOs the only entities that can delegate their reporting of this kind of data to another RRM?


Answer:

In line with Article 9(5) 9(7) and 9(9) of Commission Implementing Regulation (EU) No 1348/2014, the market participants can delegate the reporting obligation to LSO/SSOs respectively or to any other registered RRM.

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Q&As on REMIT – Question III.4.3.

Could you please specify who should report different types of fundamental data defined in Articles 8 and 9 of Commission Implementing Regulation (EU) No 1348/2014, and when?


Answer:

The following tables illustrate the reporting of different types of fundamental data and relevant reporting timelines:

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Q&As on REMIT – Question III.3.12.

Should wholesale energy contracts concerning very small amounts of energy be reported to the Agency?


Answer:

Wholesale energy contracts are to be reported to the Agency in line with Article 3(1) of Commission Implementing Regulation (EU) No 1348/2014. However, small contracts for the physical delivery of

(i) electricity produced by production units with capacity of equal or less than 10 MW, or

(ii) gas produced by production units with capacity of equal or less than equal or less than 20 MW,

shall be reportable only upon reasoned request of the Agency and on an ad-hoc basis, unless concluded on OMP. The Commission Implementing Regulation (EU) No 1348/2014 defines the reporting of small contracts in its Article 4(1)(b) and (c).

Please note that the Market Monitoring Department of the Agency adopted a ‘No-action letter’ to provide time-limited no-action relief from the requirement to report contracts and details of transactions in relation to those contracts listed in Article 4(1)
of Commission Implementing Regulation (EU) No 1348/2014 upon reasoned request of the Agency.

The No-action letter is available here: https://www.acer-remit.eu/portal/acer-staff-letters-doc.

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Q&As on REMIT – Question III.4.4.

Should the TSOs report fundamental data to the Agency directly, or through the ENTSOs’ platforms? Is there an overlap between data sent by TSOs directly to the Agency and through ENTSOs?


Answer:

Article 8(5) of REMIT indicates that the reporting obligations on market participants shall be minimised by collecting the required information or parts thereof from existing sources where possible. For this reason, fundamental data is reported to the Agency through:

(i) ENTSO-E in line with Article 8(1) and (2) of Commission Implementing Regulation (EU) No 1348/2014; and

(ii) ENTSOG in line with Article 9(1) of Commission Implementing Regulation (EU) No 1348/2014.

TSOs are required to report the fundamental data defined in Articles 8(3) and 9(2) of the same Implementing Regulation.

Taking into consideration the above division of reporting, there should be no overlap between data sent by TSOs directly to the Agency and through ENTSOs.

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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.

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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.

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Q&As on REMIT – Question III.3.14.

What is the definition of ‘trade reporting system’ under REMIT?


Answer:

A “trade reporting system” according to Article 6(1) of Commission Implementing Regulation (EU) No. 1348/2014 is to be understood as a person who centrally collects and maintains the records of transaction, including orders to trade, of wholesale energy products in order to provide the service of reporting records of transactions to the Agency, including orders to trade, of wholesale energy products on behalf of market participants.

According to the Agency’s understanding this requires the trade reporting system to provide the third-party data reporting service as a regular occupation or business that shall treat all information collected in a non-discriminatory fashion and operate and maintain appropriate arrangements to separate different business functions from ancillary third-party services such as trade confirmation, trade matching, bringing together of multiple third party buying and selling interests or clearing services.

For REMIT purposes, it is important to ensure that a level playing field in the post-trade sector is not compromised by a possible natural monopoly in the provision of trade reporting services. Therefore, trade reporting systems are required to provide their reporting services on fair, reasonable and non-discriminatory terms, subject to necessary precautions on data protection.

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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.

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Q&As on REMIT – Question III.3.15.

What is the definition of ‘trade matching system’ under REMIT?


Answer:

It is the Agency’s understanding that a ‘trade matching system’ according to Article 6(1) of Commission Implementing Regulation (EU) No. 1348/2014 means a third party electronic matching system to match wholesale energy contract transactions, including the matching system for buy and sell orders to match transactions in a wholesale energy product. This includes e.g. third party trade confirmation systems.

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Q&As on REMIT – Question III.2.16.

How long does the Agency expect that the registration of a reporting entity (e.g. a market participant or a TSO) as an RRM will take?


Answer:

Provided that all required actions are performed by the RRM applicant in a prompt way and without significant delay, and subject to available resources at the Agency, the registration process takes approximately three months.

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