Frequently Asked Questions (FAQs) on REMIT transaction reporting – II.2.6 Questions related to bilateral trades Question 2.6.1
The question asks how to report where one of the market participants may be not a REMIT market participant. The answer recommends that a generic ACER Code ACERNONMP.EU is used so that the obligation to report can be fulfilled.
Market Participant A reports a transaction with Market Participant B who is not registered with any National Regulatory Authority (NRA) and does not have an ACER code and hence is identified using ACERNONMP.EU. A month later Market Participant B is registered with an NRA and get their ACER code and uses this for reporting all transaction post receipt of the ACER code. All previous transactions reported still identify Market Participant B with the generic ACER code ACERNONMP.EU.
Market participant (MP) (A) reports a transaction with MP (B) which is identified using ACERNONMP.EU in MP (A)’s report. A month later when MP (B) is registered with the competent NRA and informs MP (A) of its ACER code (or any other reportable code) he will be able to report all its transaction post registration with the NRA.
Because previously reported transactions by MP (A) still identify MP (B) with the generic ACER code (ACERNONMP.EU), MP (A) should novate the trade as soon as the newly received ACER code of MP2 was communicated to MP1 by MP2. Please see FAQ 3.5.3 on novation.
MP (B) will only be able to report transactions identifying itself in Field 1 (ID of the market participant or counterparty) once it has been registered with the National Regulatory Authority (NRA). At that point MP (B) will be able to report all its transactions (past and future transactions) identifying itself in Field 1.