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?
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.
Last update: 08/12/2017
Subscribe to this Page’s RSS