II.4.39.

When does a company that  only engages in intragroup trading need to register by? 

Answer: Market participants who engage in intragroup trading via an organised marketplace shall register by 7 October 2015. Unless concluded on an organised marketplace, intragroup contracts shall be reportable only upon reasoned request of the Agency and on an ad-hoc basis.

While the Agency has provided time-limited no-action relief from the requirement to report upon reasoned request for such contracts until 31 December 2016^[12], market participants are required to submit the registration form to the national regulatory authority prior to entering into a transaction that is required to be reported to the Agency in accordance with Article 8(1) of REMIT.

As such, market participants that only engage in intragroup trading outside of an organised market place should register by 7 April 2016, in line with the start of transaction reporting for any contracts which have been concluded outside an organised market place.

[12] Please note that the effectivity of the ‘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 expired on expired on 31 December 2017. The No-action letter is available here: https://www.acer.europa.eu/remit-documents/guidance-remit-application..