I’m responsible for the obligations regarding REMIT at a German energy service supplier and I have a question regarding the allocation of subordinate balancing groups of our clients to our company’s invoicing balancing group.
Those clients may fix forward transactions (specified amount and price) for certain periods in the future. Furthermore those clients can make such transactions with third parties agreeing upon delivery into our company’s invoicing balancing group. The subordinated balancing groups will then be equalized by our company’s invoicing balancing group. In cases clients did not fix forward transactions with neither party subordinated balancing groups’ consumption will be cleared using Day Ahead prices (/ Daily reference prices for Gas).
It is my understanding that it will be sufficient if both (clients and we) will report the contracts governing the balancing group management between us and client to ACER and will then for each delivery period (every month) notify ACER about the monthly measured consumption rated at the average price resulting from the transactions as described above. The forward transactions fixed with third parties will have to be reported to ACER by our clients and their trading partners directly.
In our view, when market participants fix forward transactions (price and volume) prior to the delivery of the gas or electricity these transaction should be considered as bilateral contracts. Please see FAQ 3.1.14.
For those transactions where market participants did not fix forward transactions and their consumption will be cleared using Day Ahead prices these should be reported with Table 1 as EXECUTIONS under the framework of non-standard contracts reported with Table 2.
If market participants have a non-standard contract with some flexibility/optionality and the opportunity to also fix the price and quantity ahead of the delivery period they should report Table 2 for the non-standard contract, forward trades with fix price and volume within Table 1 and EXECUTIONS for those transaction where the price and quantity was not fixed. Please see FAQ 3.1.28