Question 3.2.6 Data field (21), (22) and (23)
We hereby request your answer to our below questions in connection with the interpretation of the reporting obligations under the “Implementing Acts.
On the basis of Article 5 (1) of the Implementing Acts, details of transactions executed within the framework of non-standard contracts specifying at least an outright volume and price shall be reported using Table 1 of the Annex. According to Section 3.2.5 of the REMIT Transaction Reporting User Manual, even if the contract is considered a non-standard contract, but has an agreed price and quantity, the contract has to be reported using Table 1 of the Implementing Acts.
Can you please confirm that our below interpretation is correct, or in case any of our below statements would not be correct, we would be grateful if you could please provide us with your interpretation:
- Fields No 21 to 23 of Table 2 of the Implementing Acts provides for the possibility to report optionality of the volumes supplied under a given contract. In our interpretation, the right of the purchaser under the Contract to waive its right to off-take a pre-defined percentage of the monthly and daily volumes of electricity may be reported in Fields No 21 to 23 of Table 2.
The above interpretation is correct. Market participants may refer to Annex II to the Transaction Reporting User Manual (TRUM) which contains examples of transaction reporting for both standard and non-standard contracts. Section (2) of Annex II contains examples of non-standard contracts to be reported with Table 2 of the Annex of the REMIT Implementing Regulation.
In Annex II of the TRUM, our understanding of the reporting of non-standard contracts and the execution under non-standard contracts is presented. In addition, some basic rules for their reporting are listed.
The Guidance is supported by examples of non-standard contracts which include the possibility to report optionality of the volumes supplied under a given contract.