Three months from today, the first stage of REMIT Reporting will go live, on 7th October 2015. Any orders or trades arising from activity on an Organised Market Place(OMP) must be reported to ACER, using a variety of routes. Each OMP must offer a data reporting agreement to report the data to ACER for a market participant, but it is also possible to report the data via another Registered Reporting Mechanism(RRM). The data can be uploaded from the OMP by the market participant (if the OMP allows it) and sent to an RRM, or some OMPs will send data directly to selected RRMs.
We are finally seeing some announcements from OMPs as to the services that they will offer, pricing and availability. However, with three months to go, it would appear that there is still a great deal of work to do, both for OMPs and market participants.
Market participants need to make sure that they have appropriate arrangements in place for reporting of OMP data, and make a choice for each whether the data is to be directly reported, sent to another RRM or uploaded. Account needs to be taken of which OMPs will offer which services, and to which RRMs they will send data, if any.
Once any decisions are made, agreements need to be signed. While a standard framework has been proposed for broker platforms, careful checks should be made of the terms, particularly in terms of liability. Once these are signed, careful monitoring needs to take place in terms of implementation readiness.
With 93 days to go, every market participant needs to make best use of the time to ensure go live. And once that is over, there is off venue reporting to think about.