Question 2.1.54 Local flexibility products

Our Exchange plans to offer the possibility to trade Local Flexibility Products within the EU. Such products are designed to solve local congestions on the grid of DSOs or the TSO through the trading of electricity. Local Flexibility Products are offered on markets characterised by a single buyer, that is the System Operator, representing the interests of DSOs and the TSO and multiple sellers. Local Flexibility Products can be traded as part of auction or continuous trading within the day-ahead or intraday timeframe. When operating a flexibility market, precise asset location information is necessary for the System Operator to manage congestion and frequency.

We would like to clarify whether the product concerning such congestion management (local flexibility) is subject to REMIT reporting requirements. Additionally, we are seeking guidance on ACER's expectations regarding the reporting of transaction data for trading activities related to congestion management.

Answer: 

It is the Agency’s understanding that in case of Local Flexibility Products the platform offered by the Exchange is used by, on one side, the TSO/DSOs (via the System Operator) to access the liquidity of the Exchange to coordinate their congestion management solutions, and, on the other side, by the Exchange members. Despite the presence of an aggregator (i.e. the System Operator) with the function to reduce congestion in the electricity grid, this arrangement represents the bringing together of multiple third-party buying and selling interests in wholesale energy products in a way that results in a contract.  

Therefore, both orders and trades should be reported to ACER in accordance with Article 3(1)(i) and (ii) of REMIT Implementing Regulation. The contracts related to these new products are considered as standard contracts traded on an OMP and, thus, shall be listed in ACER’s List of Standard Contracts.

When reporting Local Flexibility Products under REMIT, the following transaction reporting requirements shall be followed with regards to specific data fields, also with the purpose to correctly flag these transactions as related to products for congestion management:

• Since the contracts related to Local Flexibility Products are considered as standard contracts traded on an OMP, they shall be reported using Table 1 of the Annex to REMIT Implementing Regulation.
• Both Data Field (21) Contract ID and Data Field (22) Contract name shall start with the prefix “CM_”, followed by the Contract ID and Name, respectively, assigned by the OMP. The prefix ‘CM’ shall stand for ‘Congestion Management’.
• Data Field (27) Organised market place ID/OTC: This field identifies the organised market place on which the order was placed and the trade was concluded related to the Local Flexibility Product.
• The Extra field available in the REMITTable1 electronic format shall be used to report the locational information by reporting the respective EAN code as the unique identification number that links the respective connection point to a specific user/address. It will represent the required locational information in the Extra field. For example, if the EAN code is 123456789012345678, it is to be reported as follows:

REMITTable1_V2<Extra>EAN==123456789012345678;EAN==123456789012345678</Extra>

REMITTable1_V3<Extra>EAN==123456789012345678</Extra>