There is now 1 month to go until the start of “Phase 2” reporting under REMIT, which commences on the 7th April. From that date and onwards, all activity conducted off an Organised Market Place must be reported to ACER, either via a third party Registered Reporting Mechanism (RRM), or by a market participant becoming an RRM themselves.
The reports include all eligible bilateral contracts, including long term agreements such as PPAs etc. which must be reported using tables 1 and 2. In addition, secondary power and gas transportation trades must be reported using tables 3 and 4. Market participants are also responsible for reporting “fundamental” data around daily gas balances in store and certain LNG movements.
Until last month’s public workshop, there had been many unanswered questions about the reporting, for example around “executions”, reports related to long term agreements that inform on actual prices and volumes. The workshop (notes to be found here) answered many of these questions as did several documents issued on the same day, as well as an updated questions and answers document (notes here). However, at this stage there are several open questions, in particular with respect to tables 3 and 4, for which no examples have so far been issued.
It is still possible that new guidance will be issued before the live date, as mentioned in the workshop. However it has also been announced that there will be no schema changes before then, with a more major change to be rolled out next year in the light of experience gained by the go live.
While there is a month to go, much (but not all) of the data only needs to be reported within a month of the event, slightly extending the deadline. In addition, the “backloading” deadline for contracts already open on the 7th is three months after the initial date. Since most long term contracts will fall under this status, in some cases there is a little more breathing space.
Be that as it may, most market participants are likely to have a busy month, not only getting ready to report, but also dealing with any new information which comes to light in the interim.