REMIT Reporting Services and Solutions - July 2015 updated March 2016
2.1 This Report
This report focuses on the data collection part of REMIT, with the second of the two deadlines still to pass. We will
examine how to prepare for these deadlines, which fall on the 7th October 2015 and 7th April 2016. While the first
deadline has passed, many will wish to reconsider how to deploy their solutions holistically. The report will examine
the reporting requirements, the infrastructure that is building around the requirements and the various types of
solution that are available to meet the requirements. It ends with a listing of the various solutions on offer from
different vendors. The report is solely based upon the opinion of the authors and does not constitute legal advice. It
is recommended that readers seek legal advice on any matter outlined in this document, and that any information
about third parties be verified directly.
Before looking at reporting it is worth having a brief overview of the other parts of REMIT.
2.2 Inside Information and Market Manipulation
Under REMIT Articles 3 and 5, it is forbidden to utilise inside information for trading activity except in the case of
some narrowly defined exemptions. Inside Information in the context of REMIT includes information related to
physical assets. For example a power station outage, which has not been published, could be considered inside
information.
The approach to inside information in the energy world is to publish it, thus putting it into the public domain. REMIT
stipulates that such publication should be carried out as soon as possible, except in certain circumstances when it
may be delayed. Such circumstances include coverage of an immediate physical loss, or in order to fulfil security of
supply obligations. For the time being most asset owners publish their inside information on their web site, or on
one of several platforms. From 1st January 2017, those publishing inside information will need to do so in RSS or
ATOM using prescribed formats to be found in ACER’s Manual of Procedures.
REMIT also prohibits actual and attempted market manipulation, which can involve any activity that is considered
“abusive”. The act, and also guidance issued by ACER does list some very specific examples, which include
techniques such as “marking the close” and “market cornering”. In many cases the types of abuse are similar to the
financial markets, although the physical side can make it more complex to detect. For example a market cornering
will usually involve manipulating a physical supply and then profiting from a resulting movement on the financial
side.
Both inside information and market manipulation attract the heaviest sanctions under most regimes, which under
some jurisdictions include criminal sanctions.
2.3 Registration
REMIT requires all market participants to be registered in a central database known as the CEREMP, the Central
European Registry for Energy Market Participants. While this database is run by ACER registration takes place at the
local level, with each NRA providing a registration facility. NRAs had a deadline of 17 th March 2015 to get their
systems up and running.
Registration takes place in two parts: Completing the first results in an “ACER code”, a unique identifier provided to
each participant. It also asks for some basic information, including details of certain responsible individuals in the
organisation and the ultimate parent. The second stage involves providing more detailed information, such as the
company structure as well as who will report.
All registrations must be completed by the start of reporting. In many jurisdictions, it has been compulsory to
complete the first stage already. Others do not specify a date. However it has been recommended that all start
registration by the 17th June 2015. Those only reporting second phase data must register before such reporting
commences.
Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC
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