How should we populate field (4) “ID of the other market participant or counterparty” in a bilateral transaction when the other counterparty to the contract may not be a REMIT market participant, a REMIT market participant not registered with any NRA yet or a non-EU market player?
As indicated in Annex III to the TRUM, under “Wholesales Energy Markets: physical vs financial markets” section on page 1, there are circumstances where market players trading wholesale energy products may not be REMIT market participants.
When a market player is a REMIT market participant and enters into a bilateral transaction (e.g. a financial swap related to gas delivered in the EU) with a non-REMIT market participant (a firm that only trades OTC bilateral financial products related to the EU gas or electricity and never enters into a physical trade), the REMIT market participant may need to populate field (4) with a code to indicate that the counterparty to the trade is not a REMIT market participant. If this is the case market participants reporting bilateral trades concluded with non-REMIT market participants should report a fictitious ACER code as follows:
- ACERNONMP.EU – when the reporting party knows that the counterparty is a non-REMIT market participant
Please note that the above is only valid for field (4) ID of the other market participant or counterparty.