Related documents: REMIT Implementing Regulation Art 3.
REMIT requires the reporting of contracts in wholesale energy products to ACER. However, certain transactions may be split into separate ‘legs’ for the purpose of recording the information in market participants systems. These contracts may have more than one counterparty, relate to more than one product, e.g. LNG and natural gas, contain multiple delivery points and have more than one price setting mechanism. It should be noted that these ‘legs’ do not represent executions.
To report these ‘legs’ as a single contract it would be necessary to aggregate them together. Aggregation may reduce transparency of the data provided to ACER, particularly if the contract is reported as table 1 as no execution data will be reported. In addition, it is currently not possible, for all contracts, to aggregate and report the contract as a single message under table 1 due to limitations with the schemas, e.g. different legs may have different transaction details. Any solution, if possible, will, at best result, in a considerable loss of detail of contract information. Aggregation will also involve considerable effort on the part of market participants in terms of changes required to systems. This seems inefficient given the small number of such transactions.
Finally, we understand that other market participants face this issue. Therefore, different reporting by CPs may make matching more difficult for ACER, so guidance in this area would be very helpful.
Example: In this example there is only one contract between MP1 and MP2/MP3. However, the contract is booked as a number of different deals in the trading system due to product, locational and pricing factors. We note that there are no current examples of how to report such a trade within the TRUM.
|Deals booked in trading system||Product||Location||Formula|
For table 1 we would prefer to report the individual ‘legs’ of the contract separately and to use the ‘Linked ID’ field generated separately by each market participant for each report to recognise that the reports are related. We would finally note that such contracts only represent a handful of the overall transactions currently undertake.
Based on the information provided above, it is our view that each party should report a separate contract by using Table 2. For example, in the case of a tri-party agreement, contracts between MP1 and MP2, and MP1 and MP3 shall be reported by using Table 2 and individual executions after that agreement shall be reported by using Table 1.
Each party should report a separate contract (Table 2), e.g. a tri-party agreement, MP1 with MP2, MP1 with MP3 and individual executions after that.