We need to understand how quantity data for Non-Standard Contracts are required for transaction reporting according to REMIT.
We act as Direct Marketer in Germany with a portfolio of wind and solar based virtual power plants. Typically these PPAs are agreed with a 1-2 year duration. We just purchase from the power plant operator the whole production based on actual values.
When we sign the contract we need to report such a new deal with Action Type New and Quantity field empty (because the actual values are not available yet. The actual values are available from the DSOs (around 99% completeness) until 10 working days after each delivery month, and they are usually available with 100% completeness before the Balance Circle Agreement (8 months after delivery month).
The question is now when we need to report modified transactions for these PPAs and based on which data? Shall we report each month the actual values of the previous delivery month even if they are not yet complete?
Another question is the 30 day rule. Is the obligation to report the transaction within 30 days only related to new transactions (Action Type new) or also related to any modifications later on?
Further question regarding Field 41 Delivery Area: What should be represented by this Y EIC Code – the TSO area (which is a 16 digits Y Code) or the DSO Delivery area (which is a 16 digits Y Code as well). I´m already sure the balance circle of the Balance Responsible is not meant as this a 16 digits X Code.
For the purpose of the reporting of the details of transactions executed within the framework of non-standard contracts specifying at least an outright volume and price, reportable with Table 1 of the Annex to the REMIT Implementing Regulation (EU) No 1348/2014, the Agency understands that these transactions should be reported according to the billing cycle industry standards as the invoicing date is the last point in time that price and quantity can be discovered.
The Agency understands that the billing cycle industry standards refer to calendar months and therefore twelve transactions per year (if the executions take place every month of the year) are expected to be reported not later than 30 days after the discovery of price and quantity – in your example the 30 days period (i.e. T+1 month) will start from 10 working days after each delivery month.
Although the 100% correct values are available from the DSOs after 8 months, the Agency currently would not expect any lifecycle event based on values available from the DSOs.
With regard to the timing of the reporting, if a “new” report is due to be reported on T+1 basis, all the lifecycle events related to that report have to be reported on a T+1 basis. If a “new” report is due to be reported on T+1 month basis, all the lifecycle events related to that report have to be reported on a T+1 month basis.
With regard to the second part of the question, as indicated in the TRUM, field (41) Delivery Area identifies the commodity delivery point or zone. In this specific case, the delivery area is the TSO EIC Y code of the balancing area for which the market participant has a balancing agreement with the TSO. This is the area where the market participant delivers the energy commodity through nominations/scheduling.