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FAQs on transaction reporting – Question II.3.1.30

As OMP we are planning to expand our portfolio of services with implementation of a centralized market for bilateral contracts. Our trading activities will be based on two matching mechanisms: auctions based mechanism and continuous trading mechanism. Therefore, we will offer standardized products as base load, peak load, off peak load products with different delivery time intervals (hourly products, weekly, monthly, half-year, year, etc.) via continuous trading mechanism. Our REMIT reporting problem issue is that we cannot classify some of our products that we will offer through this auctions market mechanism according to ACER manuals criteria.

Our OMP will act as a central counter party for the products traded via the auctions based trading mechanism as the products traded on the continuous trading screen will be dealt bilaterally.

For example, we will offer a product that according to REMIT guidance could not be classified as block hour and neither as base load, so we could not decide how to classify in the list with standard contracts or more precisely, is it possible to standardize products with daily deviations of +/- 10% or 20% traded via auctions trading mechanism?

Also, how do we need to report offers and trades for products traded via auctions mechanism? May be we need to report them on T+1 with table 1, but for a one-year delivery contract, dealt on auctions mechanism we will have different quantities each hour in the coming days with possibility for different daily deviations between  +/- 20%?

We have classified and specified in ACER`s list of standard contracts product Customizable (+/20%) one-year Base Load with deviations in the load of +/- 20%. This product will be available for trading via our OMP auctions trading mechanism. Every day, MP may have different quantities with +/- 20% for each hour during one-year period.

This kind of contacts usually on XYZ market are reported via Table 2 and as execution with Table 1 after the delivery and after counterparts have received invoices clarifying the prices and the quantity. As OPM, how do we need to report this contract as the future quantities will not be clear to us at time when this contact is concluded, as the quantity deviations will be dealt between the both parties one day before the delivery day?

As the MP`s will have agreed one contract by OMP auctions mechanism with defined terms of payment, what is the right way to report this kind of trades? Do we need to report on a daily basis the different quantities under one-year Customizable (+/20%) Base Load product for this contract every day regarding the nominations schedules not clarifying that this kind of contact is one-year contract under which conditions MP could trade +/-20% deviations from the base load or do we need report this kind of contract just once on T+1 after the auction is finished?

If we have one year contract with base load 10 MW and +/-20% deviations at price of 30 Euro/MW, than the MP that won the auction session will have contract for execution and the buyer will need to send nominations schedules to the seller day before the delivery day regarding his needs, with quantities between 8 MW and 12 MW at price of 30 Euro/MW. If this contract is been concluded once on auctions mechanism at the OMP together with this contract details, what is the right way for reporting?

The auction is anonymous and XXXX is always central counterparty. For example:

  1. company A initiates an auction for sale;
  2. XXXX on behalf of company A holds an auction, as XXXX publishes the auction on the webpage and in the ETS;
  3. company B and C are the buyers;
  4. XXXX signs a contract for purchase with company A and two contracts for sale with companies B and C;
  5. company A sends nominations to the TSO for delivery and to XXXX for consumption;
  6. XXXX sends nominations for delivery to the TSO for company B and C and companies B and C also sent nominations for consumption to XXXX;
  7. companies A, B, C remain anonymous for each other, as they sign contracts only with XXXX.

Answer:

Based on the information provided above, although the exchange acts as counterparty it seems that the auction is organised on behalf of one party and there is no organised market place. Please see Question 1.1.15.

Therefore, based on the above assumptions,  the Agency would expect the following transaction reports on a T+1 month basis the following transactions:

Sell Side: One report for a contract between:

  • MP1 (the generator) and other market participant (OMP ID) of the exchange to be reported with Table 2 (including the details of the Price, quantity and any flexibility of the contracts)

When the exchange has an ACER code (e.g. is also an RRM) or an LEI (the one used for the registration to the list of OMPs) one of the two can be used. However when the OMP does not have and ACER code or an LEI but only a MIC code, then a fictitious code such as  XMIC00000.EU can be used (where XMIC is the MIC code of the exchange acting as central counterparty, please see also  Q. 2.1.5).

Buy side: several reports as many buyers entered into transaction, between:

  • MP2 (the buyer) and other market participant (OMP ID) to be reported   with Table 2 (including the details of the Price, quantity and any flexibility of the contracts)
  • MP3 (the buyer) and other market participant (OMP ID) to be reported   with Table 2  (including the details of the Price, quantity and any flexibility of the contracts)
  • MP….. (the buyer) and other market participant (OMP ID) to be reported   with Table 2  (including the details of the Price, quantity and any flexibility of the contracts)

All the above with the same CONTRACT ID.

Table 2 has a field called CONTRACT ID (rather than UTI) and this should be filled in with the same ID for all the above transactions.

At this point, the following should be considered:

1) If the total quantity it not know prior to the delivery and the delivery is nominated every day during the contract, e.g. a contract for December is nominated daily according to the flexibility of the contract, meaning that the total volume on 30 November is not known, then the execution should be reported according to the example in Annex II, Section 2 of the TRUM .e.g. once a month after the delivery on a T+1 month basis.

Please see Annex II of the TRUM for further guidance. The final agreed delivered volume and price, from the sell side and from the buy side should be reported with Table 1 as EXECUTION and linked to the CONTRAC ID reported in Table 2.

2) If the price and volume are fix prior to the delivery e.g. are known in November for all the delivery period of December, both party have agreed on the final volume and price. Once these are set, cannot be changed and therefore these contracts a forward contracts. The final agreed delivered volume and price, from the sell side and from the buy side should be reported with Table 1 as BILCONTRACT contract and linked to the CONTRAC ID reported in Table 2.

Please note that given the complex nature of these contracts, if they have a defined volume and price prior to delivery of the commodity, these executions should be treated as forward contracts (please FAQs document on transaction reporting, Question 3.1.14 and 3.1.28), meaning that they are reportable as BILCONTRACT contracts linked to TABLE 2 which was previously reported. This implies that the report has to represent the same granularity of information of any other BILCONTRACT contract (please see examples in Annex II, Section 1 for bilateral contracts) and not the type of information with the granularity of the EXECUTION as per ANNEX II, Section 2.

Irrespective of the type of execution, e.g. BILCONTRACT contract or EXECUTION, these have to be reported with Table 1 within 1 month from when the price and quantity are known and, they should include:

Sell Side: One report for a contract between:

  • MP1 (e.g. the generator) and other market participant (OMP ID) to be reported with Table 1 (including the details of the price and quantity, and if the contract is BILCONTRACT type one, with a full delivery profile of the contract). Please see Annex II for examples.

Buy side: several reports as many buyers entered into transaction, between:

  • MP2 (the buyer) and other market participant (OMP ID) to be reported with Table 1 (including the details of the price and quantity, and if the contract is BILCONTRACT type one, with a full delivery profile of the contract). Please see Annex II for examples.
  • MP3 (the buyer) and other market participant (OMP ID) to be reported with Table 1 to be reported with Table 1 (including the details of the price and quantity, and if the contract is BILCONTRACT type one, with a full delivery profile of the contract). Please see Annex II for examples.
  • MP….. (the buyer) and other market participant (OMP ID) to be reported  with Table 1 (including the details of the price and quantity, and if the contract is BILCONTRACT type one, with a full delivery profile of the contract). Please see Annex II for examples.

All of the above (both sell side and buy side) with the same UTI (only for BILCONTRACT contract type) in Table 1 and (still in table 1) Linked transaction ID reporting the CONTRACT ID previously reported with Table 2.

Please note that while there is no obligation for the exchange that is organising the auction to report the market participants records (the obligation lays with market participant) nothing prevents the exchange to provide the reporting service to their clients.

In addition, as already stated in Question 1.1.15, if the Auction is or is not a multilateral system (or any other system or facility in which multiple third-party buying and selling interests in wholesale energy products are able to interact in a way that results in a contract) and therefore not an Organised Market Place, has to be assessed by the person who runs the Auction.

Last update: 14/12/2016   RSS_Icon Subscribe to this Page’s RSS