Question 3.2.14 Data field (30)
All details of transaction executed within the framework of non-standard contracts specifying at least an outright volume and price are not necessarily available to both parties to the contract at the latest by the invoicing date (if we refer to the invoice issuance date). Indeed there may be a significant time gap (sometimes over 30 days) between the date where a producer issues its invoice and the date where the buyer actually receives it. Our below proposal aims at preventing from any breach of timely reporting due to a counterparty. We are requested by our NRA to check with ACER this would not create any operational issues.
For instance, a producer issues an invoice on 2nd February, however this invoice is only sent to the buyer on 28th February and received on 3rd March.
In that situation, the buyer will have all the details of the transaction only from 3rd March and will not therefore be able to use the invoice issuance date. The seller does not have any visibility of the date the invoice will be received and is not able to use the invoice reception date to populate the field.
We noted that ACER publicly stated at several times (in particular at the workshop of January 27th) that the reported transaction timestamps do not need to be the same for both parties.
Besides, during our meeting of January 8th, our NRA confirmed it does not use field 30 for reconciliation purposes unlike the fields related to the price, volume and delivery dates.
In this respect, as a buyer, we intend to populate field 30 with the invoicing reception date and expect sellers (producers) to populate this field with the date of issuance of the invoice.
Our NRA agrees with this methodology, but requested us to check with ACER this would not create any operational issues.
In the examples illustrated in Annex II to the TRUM it is indicated that the time and the date of the EXECUTIONS may be different between market participants. Market participants should report their EXECUTIONS concluded under the framework of non-standards contract within one month from when they know their price and quantity. In those circumstances where market participants do not know the price and volume until they receive the invoice from their counterparty, they should report their EXECUTION within one month from the receipt of the invoice.