REMIT Reporting Services and Solutions - July 2015 updated March 2016
6.2 Meeting the full requirements – what are the options?
We have already examined the options for complying with phase 1 of REMIT in the previous section. This section will
examine how a market participant can meet the REMIT reporting requirements as a whole, considering both phases
of REMIT reporting. It will focus on order and trade data, although there will also be a quick examination of
fundamental data reporting.
In general a market participant has the following high-level options available to meet the reporting requirements:
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Delegation – outsourcing reporting as much as possible.
Direct upload via RRM – using a “full” RRM or TR/RRM to report all of the data, but without software.
Direct sending to ACER – becoming an RRM.
Software – Purchase or build software to be installed on site or as a “managed service” that gathers the data
and sends it to one or more RRMs.
Service – an off-site service, which can gather some of the data and to which the rest may be sent.
It is possible to combine the different methods to form one solution. We will first examine each of the options
available. We will then look at how these may be combined into a workable solution.
6.2.1
Delegation
We have already examined delegation to an OMP in the previous section. However other forms of delegation are
also commonly practiced in trade reporting:
Counterparty delegation is the process where one counterparty of a two-sided trade reports for the other. This
practice is very common for EMIR reporting, where a larger counterparty may report on behalf of a smaller one.
Under EMIR, most recognised Trade Repositories explicitly recognise this type of delegation, allowing for shortened
messages to be sent by the party offering the service so that contract details only need to be sent once.
REMIT does not explicitly recognise such delegation. In fact the REMIT Implementing Act states (Article 6(7)):
“Where a third party reports on behalf of one or both counterparties, or where one counterparty reports the details
of a contract also on behalf of the other counterparty, the report shall contain the relevant counterparty data in
relation to each of the counterparties and the full set of details that would have been reported had the contracts
been reported by each counterparty separately.”
Never the less, it is likely that some counterparties may offer such delegated services to others. This is particularly
likely where a larger company purchases energy from a smaller supplier that is in REMIT (i.e. has a capacity of more
than 10/20MW). Such suppliers will be reluctant to set up technology to report a small number of trades, an