Reference to documents: REMIT Implementing Regulation Article 5
Definitions of known price and volume for reportable executions are unclear. For non-standard supply contracts of gas or electricity, where there is not a fixed price commodity rate defined in the contract, which volume and price is considered to be the reportable execution?
Example: If a customer makes multiple forward-purchases ahead of a delivery month through their supplier for a specific volume for this specific delivery month at a specific price, with any remaining un-hedged volume then priced on a market index; all of which are subsequently used in calculating a weighted average invoice unit rate; what should the customer report?
- Each trade made at the time of trade, only.
- Each trade made at the time of trade, and the remaining volume on the index price at time of invoicing (once volume and price are known).
- Just the final weighted-average unit rate and total consumption at time of invoicing (and then a final monthly average, or each settlement period price).
Our view: Option 1 above.
It is our understanding that only the executions for forward purchases are reportable as it is these transactions which could affect the market.
Based on the information provided above, it is our view that all the contracts have to be reported. If the forwards with defined price and quantity are agreed and the price remains unchanged, then these contracts have to be reported as BILATERAL contracts. Any remaining un-hedged volume priced on a market index should be reported as EXECUTIONS. Please see FAQ 3.1.28