There are several new answers which include some notes on the often discussed topics of third party delegation, and responsibility for checking data sent on a market participant’s behalf by another party.
Use of RRMs
If delegating all reporting to another counterparty (e.g if a smaller market participant trades with larger ones who offer a delegated service), which RRM should be logged in the market participant’s entry in the CEREMP, if the counterparty is not itself an RRM? (III.2.31) – The ultimate RRM that forms the final link in the chain when reporting to ACER.
When delegating to a third party, who is responsible for the “completeness, accuracy or timely submission of data” under the REMIT Implementing Act Article 11(2)? (III.2.32) – The third party is responsible provided that the data submitted to it was correct. The market participant is responsible for ensuring that the data sent to the third party is correct. If an OMP delegates reporting to another RRM, the OMP is responsible for ensuring that accurate data is submitted to the RRM.
What are “reasonable steps” required to be taken by market participants’ in order to ensure “completeness, accuracy and timeliness of the data” submitted through third parties as defined by the REMIT Implementing Act Article 11(2)? (III.2.33) – RRMs should provide Market Participants with access to their data in the format defined by ACER (i.e. “ACER XML”), so that the information can be verified. Such access should be provided either to the market participant or to a nominated third party, in a non-discriminatory transparent and fair manner. Verification should be undertaken at least quarterly, and more often for larger market participants.
When does the “clock start ticking” in terms of the T+1 next day obligation to report? (III.3.27) – The data must be reporting the next working day, where working day is defined by the market of the participant, rather than that of the RRM.
Does the 600 GWh pa limit refer only to the burning of gas, or also to other purchases e.g. feedstock (III.3.28)? – The purpose is irrelevant in the calculation.
How to report when a continuous explicit intra day cross border capacity allocation method is in place? (III.3.29)? – If the allocation and nomination are the same, only the nomination need be reported. If they differ, both must be reported.
If a single point mechanism exists between two bidding zones under the jurisdiction of two TSOs, who would report? (III.4.5) – Only one TSO need report.
The answers on delegation and data checking will address some of the issues being experienced by market participants. Answers on the second phase of REMIT reporting, relating to off venue trades, are now eagerly awaited.