Related documents: Article 2, Article 2(2) and (3) of 1348/2014, Article 5(1) а,b (2) of 1348/2014; Article 7 (2) of 1348/2014; Regarding field TRUM Table 1 Transaction Timestamp field 30 and reporting Table 1 – bilateral in T+1
How to classify (standard or non-standard) complex day-ahead hourly electricity products executed bilaterally outside the organised market place is not admitted to trading at an organised market place and if classified different than our view then when to report and with which table?
- With some of our partners we trade day-ahead hourly electricity products executed within the framework of general/master agreement bilaterally outside the organised market place. This master agreement sets the rules for trading activity of the two counterparties to the contract and it is specifying the range of the volumes available for trading as sometimes these volumes can differ regarding the buy and sell positions in the counterparties portfolios and these positions, during the trade period (one month) will be technically still open until the end of the month when is the invoicing date and the correct price and quantity can be discovered.
In our opinion, this contract may be classified as non-standard complex shaped/profile contract as it is not traded at an organised market place, but only bilaterally between the two parties and it is not admitted to trading at an organised market place (not visible to the market, not available for trading to market participants, would be traded only once and would then expire and not be tradable any more).
Our understanding is that we should report the abovementioned trade with Table 1 to identify the details of transactions executed within the framework of non-standard contract reported with Table 2. This execution will be reported once the delivered quantity and the price are known after the invoicing cycle, but no later than 30 days after the discovery of price and quantity. Can you confirm this?
Also, could we use the details (time of the invoicing) from the invoice for filling the Transaction Timestamp in the Table 1 field? For this kind of contract our positions will become clear and will be known after the invoicing cycle, so that is our only reasonable option.
- With other partners we have master agreement and annex based executions with clear and closed positions regarding the price and quantity. In our opinion, this annex may be classified as non-standard contract for base load, pick load off-pick load annex contract as it is not traded at an organized market place, but only bilaterally between the two parties. Could we report this contract just with Table 1 as Bilateral on T+30 or Bilateral on T+1?
- The qualification whether the contract is "standard contract" or "non-standard contract" is specified by ACER`s list of standard wholesale energy contracts as it defines the types of such contracts. Decisive for the reporting as standard contract or non-standard is the fact whether a contract is or is not listed as such in the Agency's REMIT database.
According to the primary criterion stated by Article 2(2) and (3) of the REMIT Implementing Regulation if contract (for example in our case day-ahead hourly electricity products) has been traded bilaterally and has not been admitted to trading at an organised market place (not visible to the market and not available for trading to market participants and would be traded only once and would then expire and not be tradable any more), but in the same time this kind of contract has been published in the ACER list of standard contracts, (for example Bulgaria Baseload (CET 00-24) with delivery zone 10YCB-BULGARIA-F). Does the fact that the contracts which have been published in ACER`s list as standard for 10YCB-BULGARIA-? delivery zone makes these contracts standard, despite the fact that are traded bilaterally and have not been admitted to trading at an organised market place? How do we need to report, for example this year contract Baseload 00-24 CET with delivery zone 10YCA-BULGARIAR? Could you please answer when do we need to report the contract: on T+1 or T+30 as Bilateral with Table 1?
Please see FAQ 3.1.28.