REMIT Reporting Services and Solutions - July 2015 updated March 2016
Secondly, becoming an RRM involves meeting lesser requirements than to become an EMIR TR. There are still
requirements about security, ability to provide the service and financial stability, but these are lower than for a TR.
As a result, REMIT is likely to see more RRMs than EMIR saw TRs.
Strictly speaking, any entity that sends data to ACER must register as an RRM, including the other 4 “types” of
sender. However a full RRM will send most types of data to ACER if sent to it by a market participant, no matter what
the data type.
Since the requirements to be an RRM are lower than a TR, it is conceivable that a market participant will wish to
become an RRM himself or herself. This would save them paying fees to another RRM and provide direct access to
ARIS. The pros and cons of such an approach are discussed later in this report.
4.9.2
EMIR TR
As outlined above, any trade that is in both EMIR and REMIT does not have to be sent again to an RRM, under the
“avoidance of double reporting” principle. As a result every EMIR Trade Repository is a route to ACER.
Note that some EMIR TRs will also offer “full RRM” services, permitting all data to be sent to them for any regulation.
However not all TRs offer such a service. Those that do are intending to act as a “one stop shop” to which all data
can be sent, no matter where its “final destination”.
4.9.3
Organised Market Place
Any Organised Market Place (i.e. an exchange or broker platform) that supports the trading of covered contracts
must “offer a data reporting agreement” under Article 6(1) of the REMIT Implementing Act. The first reporting data
of REMIT on the 7th October 2015 covers only orders and trades that arise from such OMPs, with an official list of
OMPs having been published by ACER.
An OMP is obliged to offer data reporting (which can be charged for) on any data that arises from the platform. For
an exchange this would generally cover the entire trade lifecycle, whereas for a broker platform it could only cover
execution.
Several later sections will look at OMP reporting in more detail. However it is worth noting that a market participant
is not obliged to report using the OMP channel. Also note that some OMPs are offering “full RRM” services in
addition to the obligatory offerings. Note however that due to the answer given by ACER in the 14th Questions and
Answers document (III.2.43) there is a reduced liability for reporting if a market participant signs the data reporting
agreement offered by an OMP or their preferred RRM.
Each OMP has a different type of offering, and these will also be examined in section 5.4.
4.9.4
Direct reporting
As outlined above, it is possible for a market participant to become an RRM themselves, and this option in clearly
being contemplated by some for the second phase of REMIT reporting. However such reporting is only permitted for
off venue trades. In addition, ACER have, since February 2016, been discouraging market participants from following
this route.
Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC
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