Do TSOs need to report gas trade notifications at virtual trading hubs?
Article 9 of the REMIT Implementing Regulation: Rules for the reporting of fundamental data on gas
Paragraph 2: Gas TSOs or third parties on their behalf shall report to the Agency and, at their request, to national regulatory authorities in accordance with Article 8(5) of Regulation (EU) No 1227/2011 day-ahead nominations and final re-nominations of booked capacities specifying the identity of the market participants involved and the allocated quantities. The information shall be made available no later than the following working day.
….(f) for physical and virtual hubs.
Commission Regulation (EU) No 312/2014 establishing a Network Code on Gas Balancing of Transmission Networks
Article 4: BALANCING SYSTEM
Section 3. Network users shall have the possibility to enter into a legally binding agreement with a transmission system operator which enables them to submit trade notifications irrespective of whether they have contracted transport capacity or not.
Article 9(2) of the REMIT Implementation Regulation requires to report nominations and re-nominations at virtual hubs. At the same time Commission Regulation (EU) No 312/2014 defines that for virtual trading hubs there is only trade notification used and no nomination/re-nomination needed (as no capacity allocated).
Answer: In the Agency’s view trade notifications from TSOs at virtual trading hubs do not have to be reported as nominations if no nominations/re-nominations are required according to Commission Regulation (EU) No 312/2014. All the details should be reported by market participants as a supply contract.