Duplication of data fields between LNG transaction and Fundamental data reports.
A comparison of the data to be provided for LNG transaction and fundamental data reporting has identified areas for potential duplication of reporting. Recital 19 of REMIT notes that any kind of double reporting should be avoided.
Our view is to reduce duplicate reporting it would be helpful if ACER could enable, via a “No-action letter” Market Participants to use the execution files to also fulfil the obligation to report LNG Participant Activity Fundamental Data.
Rationale: we are aware that the REMIT implementing regulation requires reporting of both executions and fundamental data for a delivery of an LNG cargo. However, there is a need to avoid double reporting arising from Recital 19 of REMIT.
Answer: The data fields collected for LNG transaction data and LNG fundamental data are defined in Commission Implementing Regulation (EU) No 1348/2014. Although some data fields for LNG fundamental data are also present in executions of LNG transactions, the scope of fundamental data is broader.
According to Article 10(3) of Commission Implementing Regulation (EU) No 1348/2014, the Agency shall establish procedures, standards and electronic formats based on established industry standards for reporting of information referred to in Articles 6, 8 and 9 of the said regulation. Its Article 9 determines rules for the reporting of fundamental data on gas.
From Article 10(3) of Commission Implementing Regulation (EU) No 1348/2014 it is clear that separate procedures and formats have to be established for fundamental data reporting under REMIT.
Please note that the Agency already aims at minimising the reporting obligation on market participants as much as possible by collecting the required information from existing sources where possible.