I have questions regarding REMIT reporting obligations.
1. As it is noted in the Fundamental Acts market participants are obliged to report contracts concluded outside organized market but which have defined quantity and price as Standard Contracts with the deadline of one working day. Our questions regarding this type of contracts are as follows:
- What if the price is defined but quantities are flexible during the contract duration does this mean it should be reported as Standard Contract with deadline of one working day?
- What if the price is contracted in one currency but denominated and paid by the customer in another currency does this considers as defined price? Example: we have contracts signed with defined fixed prices in EUR but this price changes on monthly basis due to conversion of price from EUR to HRK.
2. What is the deadline for bilateral contracts signed outside the organised market place for sublet of transportation capacity? If we understand it correctly these contracts should be reported within the same deadline as non-standard contracts (this means the deadline is 30 days)?
If the price is defined but quantities are flexible during the contract duration, this it is a non-standard contract, unless traded on Organised Market Place. Please see FAQ 1.1.20 for the timeline of reporting.
Based on the information provided above, it is our understanding that if the contract is signed with defined prices in EUR, this is by definition a contract with defined price. This contract should be reported with the price in EUR by both sides of the contract. It is our view that the fact that the contract is registered in another currency in the market participants’ systems, being subject to currency fluctuations, does not change the nature of the contract itself.
Bilateral contracts signed outside the organised market place for sublet of transportation capacity should be reported within the same deadline as non-standard contracts, T+1 month.