Is it necessary, after reporting a concluded future contract F OMP SK BL CAL-21 (fulfilment in the middle of the year 2020) during the physical delivery period to report every change in open position i.e. every day by modifying original report from middle of the year 2020? Please keep in mind, that physical delivery reports will be reported via OMP (as RRM).
a) 2.June 2020: Buy FYBY OMP Slovakian Power Base Year 2021 (Financial product).
b) 2.June 2020: Report this Financial product (REMIT).
c) 31.December 2020: Buy Physical product on Spot platform for next Business day (i.e. 1.1.2021)
d) 31.December 2020: Report this Physical trade (REMIT).
e) 31.December 2020: Report change of open position of Financial product (REMIT)?
f) Repeat c) and d) and e) every day until 30.December 2020.
Is it necessary to report e) a change of open position (period between a) and f))of Financial product a) which was already reported b) during the period of physical delivery c) i.e. every day of 2021?
If we buy 10 MW of yearly financial product, we have open position of 87 600 MWh (this trade will be reported to REMIT). Starting of 31.12.2020 this open position will be decreasing every day because of realizing daily physical trades of electricity for own consumption:
- After 31.12.2020 remain open position will be 87 600 – 24*10 = 87 360 MWh (240 MW will be physically buy at spot and this physical trade will be reported to REMIT)
- After 1.1.2021 remain open position will be 87 360 – 24*10 = 87 120 MWh (240 MW will be physically buy at spot and this physical trade will be reported to REMIT)
- After 30.12.2021 remain open position will be 240 – 24*10 = 0 MWh (240 MW will be physically buy at spot and this physical trade will be reported to REMIT).
Our question is if we need to report every day to REMIT change of open position of financial product i.e. first day 87360 MWh, second day 87120 MWh etc. until last day 0 MWh, or physical daily reporting is sufficient.
Please note that, according to the information provided, there is no need to include the modification of the financial open position in data reporting.