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Examining the new REMIT Quarterly and Q+A documents

ACER have today published both a new REMIT Quarterly and Questions and Answers document (Q+A).  Here we will examine both of these and some other associated document changes, such as those to ACER’s guidance on REMIT.

REMIT Quarterly

The REMIT Quarterly has a few useful pieces of information:

There have been more than 300 RRM applications, mainly from market participants who intend to report off venue data directly to ACER. The Q+A document confirms that market participants may not directly report on venue data even if they register as an RRM. The first page of the quarterly talks about progress in registration of both RRMs and Market participants. It also welcomes the proposals for standard agreements, so long as they are RRM neutral, and comply with the requirements of competition law. This supports ACER’s previously expressed view that a monopoly in this area would not be good for the industry.

The Quarterly then mentions that ACER’s guidance on the application of REMIT has just been updated. There is some much needed clarity on the registration deadlines for market participants (in section 4.6) which has been confusing many, especially around a 17th June deadline. The updated guidance explains that the deadline relates to section 4 of the registration form, where associated company information  must be provided. If registration was started before 17th March, then section 4 was to have been filled in by 17th June. if not, section 4 must be filled in upon registration, which must be completed before reporting starts (7th October for those with on venue trades, 7th April otherwise).

The public consultation on the disclosure of inside information closed yesterday. The quarterly makes reference to this and promises an updated manual in the summer.

The next part of the quarterly refers of the package of documents that ACER publish. Updates have been made to the manual of procedures and schemas. More updates and “fine tuning” of the schemas will take place over the coming months. Updates to the list of Organised Market Places for transportation contracts are to be added on 7th July.

The Quarterly concludes with some statistics. 8 new cases were added last quarter, and one closed. The number of outstanding cases is now at 37. This is before data collection starts. it will be interesting to see how ACER manage the number of cases that will surely be opened once data is coming in, given their budget constraints.

Questions and Answers document

ACER have once again updated the Q+A document, creating the 7th edition. The document contains the following new information:

Supplier who only purchases from a larger supplier (II.4.24) – The answer states that any supplier who purchases gas or power from another market participant, is also a market participant, and therefore must register and report such contracts. Note the wording of this answer, which firstly refers to a suppler, rather than an “end user”, and also one that purchases, i.e. not a producer that only sells energy.

Supply to final customers (II.4.25, III.3.18) – It is confirmed that a final customer that purchases energy to a single consumption unit with capability to consume more than 600 GWh pa should register and report the contract. It is also answered that if one final customer has several consumption units, and they purchase power for a unit which has the capability to consume under 600 GWh per annum, then that contract does not have to be reported,even if they also own units which are over the threshold.

Registration of small producers (III.3.17) – It is clarified that a small producer does not have to register or report, and also that contracts from a production unit under the threshold  (e.g. of 5Mw) also does not have to be reported. However, an intermediary in a chain does have to report a trade “out”. So if a market participant purchases 5Mw of power from a production unit of under 10Mw, then that trade does not have to be reported. But if the same market participant then sells on that power in a new 5Mw contract, that does have to be reported.

Registration questions (II.4.26-II.4.30, III.2.24) – Various clarifications on the data required. III.2.4 highlights that if data is being reported onyl via OMPs and the ENTSOs (and not other RRMs) then no RRM needs to be notified in section 5.

“Self reporting RRMs”  (III.2.25) – It is confirmed that market participant may not report OMP data directly to ACER, although it may be reported via certain non OMP third party RRMs.

Examinations of previous questions can be found here.

Much to do

Now that we have more and more answers, and now that we are seeing offerings from OMPs and others being finalised, market participants  will be a in a position to put their solutions in place, and to select any RRMs being used. The information is becoming available just as we go into the summer season. This will make it challenging to take any holidays.


About avivhandler

Aviv is the Managing Director of ETR Advisory, a niche consultancy focused on the regulation of the commodity, energy and financial markets. He has more than 23 years of experience in the financial, energy and commodity markets, covering regulatory compliance, credit, risk and financial technology. Prior to founding ETR, he was Partner at SunGard Global Services, where he built a Centre of Excellence in European Energy and Commodity Regulation. Before that, he founded Coherence, a consulting firm specializing in credit risk in commodity and energy trading as well as software product management. The credit practice ultimately became part of Sirius Solutions, where he was the Managing Director of Europe. He has also held management roles at KWI and Iris Financial, among other organizations. Mr. Handler holds a degree in computer science from Imperial College, University of London.


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