We have finished our preparations to be able to report transactions. It is unclear to us however, how we should report our transactions.
Our assumptions are based on the document ACER: FAQs_on_Transaction_Reporting_20160324.pdf, more specifically on question 1.1.15
We uses 2 types of contracts:
- Master agreement in which we agree with our customer (utility/producer/consumer) to automatically close its hourly open position against APX/BELPEX prices (bilaterally, we are not a member of the exchange and not an OMP. At the end of the month we create an invoice.
- Master agreement in which we agree with our customer that he can buy from us or sell to us intraday (ex-post) volume. At the end of the month we create an invoice or credit note where we settle the volumes against the imbalance price.
We believe both types of contract are non-standard contracts with a volume and a price that are known during the month. That would mean that we would be allowed to report monthly.
Can you confirm this interpretation?
- Both master agreements should be reported as non-standard contracts.
- Volumes and prices can be reported as Table 1 transactions
Then there is the question of how to handle the fact that the same transaction (1 per day per market and per customer) can contain both buy and sell volumes.
Then there are 3 options:
- use the "C" and use either positive or negative values for buy and sell in the individual hours
- use the "B" and use negative values if we are the seller
- split the transaction in a "B" and an "S"
The last option is not preferable, as we don’t really have 2 transactions.
Based on the information provided above, "C" should be used.
In addition, the Agency has addressed the issue of reporting of master agreements in the FAQs on transaction reporting.