According to the schema for gas transportation transactions reporting: urn-easee-gas-eu-edigas-remit-gascapacityallocationsdocument-5-1.xsd, the only Primary Market Participant identification coding scheme allowed is 305 (EIC). Please see the document
Edig@s Message Implementation Guidelines, schema: Gas Capacity Allocation, element 18.104.22.168.
In case that a TSO shall report data about a transportation contract concluded outside an OMP and the respective client of the TSO (Primary Market Participant) is not registered as Market participant, neither possess EIC, how shall it be identified in the report file when the only allowed coding scheme is 305?
The Agency, after consulting relevant parties, established procedures, standards and electronic formats based on established industry standards for reporting of information referred to in Articles 6, 8 and 9 of the Implementing Acts. The schemas foreseen for data reporting to the Agency under REMIT were the result of extensive consultations with stakeholders during 2014 and 2015. As a result of the aforementioned consultations, only EIC codes were accepted for identifying the reporting parties when reporting gas and electricity transportation contracts.
All reporting parties need to make sure to apply for an EIC code if they do not have one. The EIC codes can be obtained from the local issuing office. Since the EIC code will be used for reporting, it must be registered by the market participant’s registration as market participant according to Article 8 of REMIT.
Important to note that as of April 2023 also an ACER code can be reported to identify the reporting parties when using the electronic format for the reporting of REMIT Table 4 transactions. For more details please refer to the respective data fields and their description in the TRUM.
Please note that it is the market participant’s responsibility for the completeness, accuracy and timely submission of data to the Agency and, where required so, to national regulatory authorities. Where a market participant reports those data through a third party, the market participant shall not be responsible for failures in the completeness, accuracy or timely submission of the data which are attributable to the third party. In those cases the third party shall be responsible for those failures, without prejudice to Articles 4 and 18 of Regulation (EC) No 543/2013 on submission of data in electricity markets. Market participants using a third party for reporting purposes shall nevertheless take reasonable steps to verify the completeness, accuracy and timeliness of the data which they submit through third parties. This includes the completeness and accuracy of the market participant identification through a relevant identification code.
Potential sanctions for the breach of reporting obligations as laid down in Article 8 of REMIT are defined at national level. In case reporting parties are facing technical issues when reporting data to the Agency, the Agency has established a contingency plan for Registered Reporting Mechanisms which provides all instructions on what reporting parties have to do in case of different scenarios that may impact the reporting. Any such possible technical issues should not be confused with possible breaches of the reporting obligations under REMIT.