Reports EU Regulations REMIT Reporting Services & Solution | Page 33

REMIT Reporting Services and Solutions - July 2015 updated March 2016 Executions are to be sent up to one month after the volume and price are known. The ACER documentation states that the latest time that the “clock starts ticking” in when the month’s delivery is invoiced. However if a contract is involved less frequently than monthly it should be reported as monthly anyway. 6.1.5 Secondary transportation REMIT requires that capacity and transportation trades (see section 4.2 for the full definition) be reported using formats 3 (power) and 4 (gas). Primary capacity and transportation is to be reported by the system operator. However market participants must report secondary capacity and transportation as part of phase 2. If the trade is “standard” it must be reported within a day, otherwise within one month. The format 3 uses an “ENTSO-E” format and format 4 uses EDIGas 5.1. There is a full REMIT manual for version 5.1 on the EDIGas web site, as well as the relevant section of the TRUM. The formats are complex and at the time of writing in March 2016 there is still a great deal of confusion over how these formats are to be constructed. So far, ACER have not issued any examples of these trade types. Until the end of 2015, many third party RRMs were not planning to report formats 3 and 4. However some third party RRMs have now reconsidered this, although less functionality is usually offered than for the mainstream formats. Some, but not all, secondary capacity and transportation platforms will also offer to report the trades as a service to their customers. It is likely that the issue of formats 3 and 4 will continue to occupy the market after go live on the 7th April. 6.1.6 Fundamental data reportable by market participants This is discussed on more detail in section 6.6 6.1.7 Backloading As for on venue activity, any trade or contract that is open on the 7 th April must be “back loaded” within 90 days. This is relatively straightforward, except for data reported using the framework/execution construct. Most framework contracts are long term, and will thus be subject to back loading. Execution generally do not have to be back loaded. But there is a question around when to report an execution due after 7th April (say for the month of April), when the parent framework is not yet loaded, since its deadline is in July. Answers from ACER state that you may not load an execution until the framework has been sent. This implies (although not all that explicitly) that if necessary one can defer loading the execution until the back loading deadline if desired. Market participants should rely on their own advice over whether to follow this strategy. Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC 32