Our company entered into a Winter 2015-16 contract in June 2015 which we understand needs to be backloaded to the Agency. Do we need to register with our national regulatory authority?
Answer: Yes. While the contract was concluded before the start of transaction reporting and it remains outstanding at the start of transaction reporting, it has become a reportable contract. Pursuant to Article 7(6) of Commission Implementing Regulation (EU) No 1348/2014, the outstanding contract has to be reported within 90 days of the applicable reporting day.
The market participants should have registered with the relevant national regulatory authority within 90 days following the go-live on 7 October 2015, i.e. by 6 January 2016 at the latest and in any case prior to the reporting of the backloaded contract to the Agency. In order to facilitate the registration and reporting processes, the Agency advises the market participants to register well in advance of reporting of their outstanding contracts.