ACER have published an updated version of their Questions and Answers document on REMIT, the 11th version, which can be found here.
The new answers are as follows:
By when does a market participant need to register if they are reporting backloaded contracts? (II.4.41) – Registration must be completed before backloading occurs or is due, whichever is sooner.
What is the responsibility and liability or personnel listed RRM registration process? (III.2.30) – The person is responsible for the reporting and registration process of the RRM. Liability is established by the local regulator. (Note this question is not about the personnel listed as part of CEREMP registration).
Scope of REMIT and Reporting
Are derivatives traded on platforms within the EU, that relate to delivery outside the EU, covered by REMIT? (III.3.24) – If delivery is outside the EU then they do not need to be reported under Article 8 (and in any case many will be reported under EMIR). However the other provisions of REMIT apply.
What is meant by “intra-group contract”? (III.3.25) (Such contracts only need to be reported “on demand”)– Both parties to the contract must be “consolidated on a full basis” as defined by EU regulation 1348/2014.
The new questions from the previous Q+A can be found here.