III.3.44.

Are Virtual Trading Points (VTPs) considered as organised market places (OMPs) under Article 2(4) of Commission Implementing Regulation (EU) No 1348/2014? If not, is the contract for the supply of natural gas to a single consumption unit with a technical capability to consume below 600 GWh/year concluded on the VTP reportable to the Agency?

Answer: The Agency is of the view that, as long as the VTP serves merely as a virtual entry/exit point that enables grid users to transfer energy within the market area or entry/exit system without the need to book capacity and does not offer services that are characteristic to organised marketplaces it is not to be considered an OMP. Hence, an assessment needs to be made to verify whether the VTP fall under the definition of organised marketplace as defined by Article 2(20) of REMIT, in which case they should be included in the list of organised marketplaces. Please refer to Annex IX of the TRUM for further information about the criteria of organised marketplaces.

If the VTP does not qualify as organised marketplace, market participants are required to analyse if their contracts for supply of natural gas fall under Article 3(1)(a)(vii) of Commission Implementing Regulation (EU) No 1348/2014, i.e. contracts for the supply of electricity or natural gas to a single consumption unit with a technical capability to consume 600 GWh/year or more. If the technical capability to consume is below 600 GWh/year the contract for the supply of natural gas to such single consumption unit will not be reportable.