Question 1.1.32

We are having some issues with the submission of back loading transaction as they are rejected by a validation rule. Could the Agency clarify further if back loading transactions can still be reported to the ARIS system?

Answer

The Commission Implementing Regulation establishes that details of wholesale energy contracts which were concluded before the date on which the reporting obligation becomes applicable and remain outstanding on that date shall be reported to the Agency within 90 days after the reporting obligation becomes applicable for those contracts.

The Agency’s system was set to allow back loading of historical data skipping several validation rules. This was done through the submission of an XML file with a date in the filename prior (<) to the date of 5 Oct 2015 00:00:00Z. In this case most of the validation rules were ignored. 

This was done to allow market participants to report their back-loading transactions even in those cases where they did not have the full set of information as required by Commission Implementing Regulation (EU) No 1348/2014 for reportable records of transactions, including orders to trade, entered into as 7 October 2015 (Phase 1 of REMIT reporting) and 7 April 2016 (Phase 2 of REMIT reporting). 

This means that back-loading of transactions concluded at organised market places was due by no later than 90 days after 7 October 2015 and 90 days after 7 April 2016 for any other transactions. Meaning, the back-loading of transaction, i.e. submitting data for which several validation rules were not applicable, ended for Phase 1 on 5 January 2016 and for Phase 2 on 6 July 2016.

However, the Agency had technically left open the back-loading channel for more than one year in addition to the deadlines set by the Commission Implementing Regulation, but has discontinued this possibility since 30 June 2017.

The Agency would like to take this opportunity to reiterate that any transaction executed at an organised market place has to be reported on T+1 day basis and any other transaction on a T+1 month basis and that any transaction reported 90 days after 7 October 2015 and 90 days after 7 April 2016 cannot and will not be considered back-loading, but rather late reporting.

Additional information:

Transactions that are back loaded (submitted to the Agency’s ARIS information system prior to legislative deadlines) and are changed (amended) after that are subject to the lifecycle event reporting that is possible for back loaded data since 10 November 2017. As previously reported back loaded data might not be compliant with the current set of validation rules for REMIT reporting, the following two scenarios apply:

• in case the field that triggers the validation rule causing the rejection of the record is not part of the key that uniquely identifies the record (such as for example TRUM Field No (48) Delivery point or zone for REMIT Table 1), the reporting should be done via the regular reporting channel, i.e. the full set of information as required by Commission Implementing Regulation (EU) No 1348/2014 and compliant with the TRUM and the currently enabled validation rules in ARIS (REMIT Information System) should be reported using the regular file name convention (YYYYMMDD_REMITTable1_V3_ACERCode_SeqNum.xml.asc.pgp, where YYYYMMDD is the date of submission);
• in case the field that triggers the validation rule causing the record rejection is part of the key that uniquely identifies the record (such as for example TRUM Field No (21) Organised Market Place ID/OTC for REMIT Table 1), the originally reported record (for which the lifecycle event has to be reported) should be firstly invalidated with action type “E” (error) via the parallel reporting channel using the file name convention in which the date of submission is replaced with “20000101” (20000101_REMITTable1_V3_ACERCode_SeqNum.xml.asc .pgp). Reporting of the corrected record with action type “N” and the subsequent modified records with action type “M” (or cancelled record with Action type “C”) should be reported via the regular reporting channel, i.e. the full set of information as required by Commission Implementing Regulation (EU) No 1348/2014 and compliant with the TRUM and the currently enabled validation rules in ARIS (REMIT Information System). 

Market participant that needs to report outstanding historical contract not reported in the REMIT back loading period (2015/2016) can still report it by submitting relevant records with action type “N” (New) via regular reporting channel meaning that the full set of information as required by Commission Implementing Regulation (EU) No 1348/2014 and compliant with the TRUM and the currently enabled validation rules in ARIS (REMIT Information System) should be reported using the regular XML file name convention.