The Questions and Answers document contains the following new information (as well as new links which are not mentioned here):
Do Market Participants have any record keeping obligations beyond what is required from RRMS? (II.4.42) – No, and the record keeping obligations for RRMs only apply to RRMs. However there may be national and other legislation that applies to Market Participants. (Note that despite this answer, it is best practice to keep records of any activity that has been reported on the market participant’s behalf, including orders. This will aid the audit process and help the market participant if any investigation occurs.)
Are RRMs that are already approved obligated to offer reporting services for off venue activity which must be reported from 7th April? (III.2.34) – No, there is no such obligation, including for OMPs that offer a data reporting agreement as required by the REMIT Implementing Act. However such RRMs may offer such services if they wish.
May an RRM that already offers reporting for on venue reporting (which started on 7th October 2015) offer reporting for off venue reporting? (III.2.35) – Yes this is permitted.
Are RRMs obligated to keep records of receipts received from ARIS on behalf of market participants as well as of data submitted? (III.2.36) – RRMs are obligated to keep records of data submitted, and are recommended to keep records of the receipts.
The latest version of the quarterly mainly contains items previously announced, such as the timeline and recent fine for a breach. There are a few points to note:
- Data volume – The data sent to ARIS has exceeded the expectation of ACER, with over a million records per day being sent.
- Self-reporting RRMs for phase 2 – are advised to focus on the ARIS Data Collection Instance Web User Interface.
- Reporting package and documentation – there are many questions coming in and ACER will organise further round tables before go live.
- CEREMP – There will be a review and consultation around the CEREMP (Central European Register of Energy Market Participants). So far there have been more than 4500 registrations.
- Under review – There are 47 cases of possible breaches under review.
There are now less than three months to go until off venue reporting starts, with much of the market having many unanswered questions. Many are waiting for ACER to make public additional clarifications and answers so that they may proceed with their projects with confidence that they will be complaint on the 7th April.