REMIT Reporting Services and Solutions - July 2015 updated March 2016
Third party delegation refers to a situation where an entity that is not party to a trade reports it for one or both
sides. Whilst an RRM and OMP are clearly offering such a service, others may do as well. As with counterparty
delegation, it is feasible that a larger entity may offer a smaller counterparty the service of reporting their trades,
even if they are not party to it. Offering such a service does not necessitate becoming an RRM, since the larger
counterparty can pass the trades on to an RRM who reports it to ACER.
The principle of third party delegation may also be applied across the internal entities within an organisation. Whilst
internal trades are not to be reported under REMIT, one entity within the organisation may report on behalf of
another, to an RRM. If this occurs, third party delegation is effectively taking place.
In both cases, those offering and using such services will need to consider how to get extra data items to the other
party. For example, when using counterparty delegation, some fields, such as the beneficiary ID, or trader ID, will not
be known by the party offering the service. In some cases this could add complexity when using such as service,
although for smaller counterparties without complex trades there are usually simple solutions available. However, as
mentioned above, there are not many of these fields under REMIT, especially since in most cases there will not be a
separate beneficiary.
6.2.2
Direct upload to an RRM without software
It is possible to load data from a market participant’s site straight to a “full” RRM, or TR/RRM, without the use of an
intervening system, by uploading a file with the data one a daily basis, or as required. Many will wish to use a
spreadsheet or csv file for such an upload. However, because many energy trades are deeply hierarchical, this may
be impractical, and instead the data will need to be uploaded in ACERXML, or some other XML format. It is expected
that some RRMs will provide facilities to aid this process, either by offering tools, or by allowing data to be entered
on a web site.
6.2.3
Direct sending of data to ACER
In some cases market participants may elect to become RRMs themselves, so that they can upload the data straight
into ARIS. While this option is not permitted for phase 1 reporting, it is feasible for phase 2, and ACER are expecting
several to take it up, although they have been discouraging this practice due to a possible high workload.
There are certain benefits to becoming an RRM, in particular:
- Fees – there will be no charge from ACER for data uploads
- Control – the market participant has full control over what is reported
- Access to receipts – the receipts are sent directly to the market participant
- Access to information – applying to be an RRM gives access to information from ACER which is not currently
being shared with other market participants
- Lack of dependency – on another entity to be ready on time.
Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC
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