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New REMIT Q+A (9th edition) issued by ACER – what’s new?

ACER have just issued the 9th version of their Questions and Answers document on REMIT, which can be found here. There are 7 new answers contained in it, a similar number to the last edition. The following topics have been covered:

Company registration in the “CEREMP”
Company lookup (II.4.35) – it is confirmed that the central CEREMP will be kept up to date and accessible with all registrants.

Registration of companies outside the EU (II.4.36) – such companies must register and put “X”s for the VAT number.

Reporting contracts for less than 10Mw where the installed capacity is higher (II.4.37) – If a single production unit with the capability to produce more than 10Mw (20Mw  for gas) executes a contract for  less than 10Mw, it is confirmed that the contract still needs to be reported, since the reportability of the contract is driven by the unit capacity, not the contract.

May a company report OMP executed orders and trades via a subsidiary that they own? (III.2.25) – No, OMP executed orders and trades must be reported via the OMP, trade matching systems, or trade reporting systems.

May an RRM use a different service to subsidise fees? (III.2.27) – ACER have no jurisdiction over fees, although all fees must comply with competition law. (It is worth noting that fees of EMIR TRs are regulated).

Which RRMs will appear on the list when selecting them in section 5 of the CEREMP? (III.2.28) – There will be no differentiation in this list between third party and self reporting RRMs. When a market participant selects an RRM in this section it does not obligate the RRM to report.

Inside Information Platforms
May an inside information platform, or web site showing such data, disclaim responsibility for the data shown on it? (III.7.4) – The answer seems inconclusive, but suggests that platforms should take responsibility for correctly showing data that is correctly passed to it.

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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