Reports EU Regulations REMIT Reporting Services & Solution | Page 29

REMIT Reporting Services and Solutions - July 2015 updated March 2016 5.7 Reconciliation While the REMIT Implementing Act permits “outsourced delegation”, as outlined in the earlier section, there is a requirement to “take reasonable steps to verify the completeness, accuracy and timeliness of the data”, although not necessarily when signing the OMP’s own agreement. If it is required, data must be reconciled periodically, in two ways: - “Receipts” received from ACER must be examined and compared with what has been sent The data records sent must be checked against source (from the OMP) and records The method of reconciliation will depend on how the data has been sent. In any case, it is considered best practice to perform periodic data checks, to ensure that the regulator has the correct information. The answer of February 16th has given market participants food for thought in terms of their OMP reporting strategy. Many had desired a system where all OMPs would send data to their preferred RRM, consolidating the data and ensuring that agreements, reconciliation and replay were simple. However if the answer is taken at face value, it would appear that reaching such a state now gives rise to an unwelcome additional liability. Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC 28