A question on behalf of a Market Participant who has traded a gas Swing deal with us (we are an OMP).
There is an assumption that the clients have to report the deliveries that result from the daily exercise/nominations on the swing deal – this is shown in your Annex II examples for bilateral swing deals as 26.01 (swing deal) and 26.02 (execution reports for deliveries) – however, there are no examples for reporting any deliveries from an OMP traded swing deal.
Since an OMP traded swing deal cannot be reported on Table 2, then the rules as they currently stand imply that you cannot use the Table 1 report “executions on a non-standard contract” in the same way as if you had a bilateral Swing deal, because the OMP traded deal is “Standard” by REMIT definitions.
Firstly, can you confirm that clients are expected to report the deliveries resulting from Nomination/Exercise of Swing rights?
Secondly, if the answer to question 1 is true then can you advise how this should be done?
A TTF Cal17 Buyer’s Swing
Hourly Quantity Minimum 0MWh Hourly
Quantity Maximum 300MWh
Total Contract Quantity Minimum 720,000MWh
Total Contract Quantity Maximum 720,000MWh
(i.e. 100% take or pay)
Nominated on UK Working days
(Note that this deal if brokered could be identical in characteristics to a bilateral deal direct between counterparties, which would be reported on Table 2 and executions on Table 1 as EXECUTION reports.)
Based on the information available to us, the assumption that the clients have to report the deliveries that result from the daily exercise/nominations on the swing deal may not be applicable to this case. It depends on whether the option exercise results into the exercise of nominations or into the exercise of a forward contract that leads to nominations. If the former is the case, there is no need to report additional information. If the latter is the case, the contract results into a new forward contract and then this should be reported. Please see Question 1.1.12 of our FAQs on transaction reporting document.
As pointed out in the question, since the OMP traded a swing deal that cannot be reported on Table 2, a workaround to report such swing trades should be applied. For example, we would recommend:
The option should be reported with “Other” in the Option Style field (as opposed to European/American etc.). The Exercise Date field (a repeatable field) should be used to list all the exercise dates.
The premium should be reported as an amount per unit of energy, the same way as a regular Option premium would be reported and in order to report the key additional parameters of the deal the Extra field should be used to provide value pairs. With regard to the use of field “Extra”, this should not be used in other ways unless previously discussed and agreed with ACER. Please also note that Table 1 Schema V1 is different than T1 Schema V2.
For the following fields for hourly delivery contracts:
HourlyQmin = Hourly Quantity Minimum 0 MWh
HourlyQmax = Hourly Quantity Maximum 300 MWh
TotalCQmin =Total Contract Quantity Minimum 720,000MWh
TotalCQmax=Total Contract Quantity Maximum 720,000MWh
Schema Table 1_V1:
Schema Table 1_V2: