Question 1.1.1
Reference to documents: Section 3.4.2 of the REMIT TRUM on Page 31
“Details of standard contracts, including orders to trade, shall be reported no later than on the working day following the conclusion of the contract or the placement of the order. Any modification or the termination of the concluded contract or the order placed shall be reported no later than the working day following the modification or termination”.
OMPs, Market Participants and RRMs need further clarification regarding the definition of a “Working Day” for management of their internal systems.
Further clarification is also needed for ACER in relation to their expectations of, “the next working day”
OMPs such as XXX Futures EU and XXX Spot (collectively “the Exchanges”) operate in multi-time-zone markets and their established support systems and processes are configured accordingly. The Exchanges use trading days with each trading day corresponding to an underlying processing day. The Exchanges appreciates that a trading day may not have the same definition as a “Working Day”.
The Exchanges request that ACER confirm that it is happy to accept that the below as being in conformance with the definition of a “Working Day”.
XXX has identified the following “processing window” times;
|
Data for prior day loaded through UTC Time |
Window of data reported to REMIT for a processing day |
Daylight Time (Summer) |
22:45:00 |
22:45:00.000 – 22:44:59.999 |
Standard Time (Summer) |
23:45:00 |
23:45:00.000 – 23:44:59.999 |
These times correspond with the XXX’s internal systems. XXX believes that these processing day times should be compatible with ACER’s definition of a “working day”.
Furthermore, taking into consideration that REMIT reportable data should be reported on the next working day, please could ACER clarify whether it is happy to receive REMIT data on the following basis.
Trading Day |
Reported to ACER |
Monday |
Tuesday |
Tuesday |
Wednesday |
Wednesday |
Thursday |
Thursday |
Friday |
Friday |
Monday |
Saturday |
Monday |
Sunday |
Monday |
These times take into account the various necessary maintenance windows for the Exchanges markets.
Answer
Working days should be understood as business days rather than the exchange trading days. This implies that bank holidays are not working days.
For further reference related to distinguishing working days and public holidays from a REMIT reporting perspective, please consult Question III.3.27 in the Q&A document available in the REMIT Documents section of the ACER website.